ESMF Somalia Ed Project P1722434 8th March 2021

FEDERAL REPUBLIC OF SOMALIA
MINISTRY OF EDUCATION, CULTURE AND HIGHER EDUCATION
SOMALIA EDUCATION FOR HUMAN CAPITAL DEVELOPMENT

PROJECT (P172434)
ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

(ESMF)
8th March, 2021

TABLE OF CONTENTS
ACRONYMS AND ABBREVIATIONS ......................................................................................... v
EXECUTIVE SUMMARY ......................................................................................................... vii
1. INTRODUCTION AND PROJECT CONTEXT ............................................................................ 1
1.1 Project Context ................................................................................................................ 1
1.2 The Somalia Education for Human Capital Development Project....................................... 2
1.3 Project Development Objective and Components ............................................................. 2
1.4 Project Beneficiaries ........................................................................................................ 4
2. SCOPE AND METHODOLOGY OF THE ESMF ......................................................................... 6
2.1 Purpose and Scope of the ESMF ....................................................................................... 6
2.2 ESMF Justification ............................................................................................................ 6
2.3 ESMF Principle ................................................................................................................. 6
2.4 Methods .......................................................................................................................... 7
3. POLICY, LEGISLATIVE AND INSTITUTIONAL FRAMEWORKS .................................................. 8
3.1 Overview ......................................................................................................................... 8
3.2 Somalia National Laws, Policies and Legislations .............................................................. 8
3.2.1 Provisional Constitution of the Federal Republic of Somalia .......................................... 8
3.2.2 The Labour Code of 1972 ............................................................................................... 9
3.2.3 The Somali Penal Code of 1962...................................................................................... 9
3.2.4 The Agricultural Land Law (1975) .................................................................................. 9
3.2.5 Family Code of 1975 .................................................................................................... 10
3.2.6 Somalia National Gender Policy (2016) ........................................................................ 10
3.2.7 Somalia National Environment Policy .......................................................................... 10
3.2.8 Somalia National Education Policy............................................................................... 10
3.2.9 Somalia National Construction Standards .................................................................... 10
3.2.10 The Office of the Ombudsman (Established in Article 111J) ........................................ 11
3.3 The National Security Commission ................................................................................. 11
3.4 Laws and Regulations in Federal Member States of Somalia ........................................... 11
3.5 Institutional Capacity for Environmental Management ................................................... 12
3.6 International Conventions and Agreements Signed or Ratified by Somalia ...................... 14
Somalia Education for Human Capital Development Project II (P172434)
3.7 World Bank ESS ............................................................................................................. 15

3.8 World Bank Group EHS Guidelines ................................................................................. 20
3.9 Gap Analysis .................................................................................................................. 20
4. PROJECT BIOPHYSICAL AND SOCIO-ECONOMIC SETTING .................................................... 1
4.1 Introduction .................................................................................................................... 1
4.2 Climate ............................................................................................................................ 1
4.3 Ecosystems ...................................................................................................................... 2
4.4 Socio-economic Environment ........................................................................................... 2
4.4.1 Geography, Landmass and Population ........................................................................... 2
4.4.2 Poverty in Somalia ........................................................................................................ 2
4.4.3 Human Development .................................................................................................... 3
4.4.4 Education...................................................................................................................... 3
4.4.5 Water and Sanitation Hygiene ....................................................................................... 4
4.4.6 Agriculture, Livestock and Livelihoods ........................................................................... 4
4.4.9 Cultural Heritage ........................................................................................................... 6
4.4.10 Security and Conflict Environment............................................................................... 6
4.5 Vulnerability and Social Exclusion .................................................................................... 8
4.6 Gender ............................................................................................................................ 9
5. CONSULTATIONS AND PUBLIC DISCLOSURE ...................................................................... 13
5.1 Introduction .................................................................................................................. 13
5.2 Brief Summary of Previous Stakeholder Engagement Activities ....................................... 13
5.3 The Project SEP .............................................................................................................. 15
5.3.1 Inclusion plan.............................................................................................................. 15
5.3.2 Grievance Redress Mechanism ................................................................................. 16
6. POTENTIAL ENVIRONMENTAL AND SOCIAL RISKS, IMPACTS AND MITIGATION ................. 24
6.1 Introduction .................................................................................................................. 24
6.2 The ESMF Procedures..................................................................................................... 26
6.3 Environmental and Social Screening ............................................................................... 28
6.4 Environmental and Social Risks Rating ........................................................................... 29
6.5 Environmental Risks and Impacts Envisaged ................................................................... 29
6.6 Social Risks and Impacts Envisaged ................................................................................ 30
ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

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6.7 Environmental and Social Benefits ................................................................................. 32

7. ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES ........................... 33
7.1 Environment and Social Risks Mitigation ........................................................................ 33
7.2 Gender Mainstreaming and GBV/SEAH Action Plan ........................................................ 37
7.2.1 Gender Mainstreaming ............................................................................................... 37
7.2.2 Management of GBV/SEAH/SEA Risks ......................................................................... 37
7.3 Resettlement Policy Framework for the Somalia Education Project ................................ 38
7.4 Security Management Plan ............................................................................................ 39
7.5 Environmental and Social Monitoring of Contractors ...................................................... 39
7.6 Environmental and Social Liabilities of Contractors ........................................................ 40
8. ROLES AND RESPONSIBILITIES OF THE IMPLEMENTING ENTITIES ...................................... 41
8.1 Introduction .................................................................................................................. 41
8.2 Overall Project Management ......................................................................................... 41
8.3 Responsibility for the ESMF............................................................................................ 44
8.4 Roles and Responsibilities of the MOECHE ..................................................................... 47
8.5 World Bank Roles and Responsibilities ........................................................................... 47
8.6 Updating the ESMF ........................................................................................................ 47
8.7 Disclosure of Safeguards Instruments ............................................................................. 47
9. SAFEGUARDS CAPACITY NEEDS ASSESSMENT AND TRAINING PLAN .................................. 48
10. MONITORING PLAN ....................................................................................................... 49
10.1 Regular Monitoring and Inspection for Compliance ...................................................... 49
11. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN AND BUDGET ............................... 51
ANNEXES ............................................................................................................................. 66
ANNEX 1: WORLD BANK ENVIRONMENTAL AND SOCIAL STANDARDS .................................. 66
ANNEX 2: INDICATIVE SCREENING CHECKLIST ...................................................................... 68
ANNEX 3: GENERIC CONTENTS FOR SITE-SPECIFIC SUB-PROJECT ESMP ................................. 71
ANNEX 4: PROTECTION OF CULTURAL PROPERTY ................................................................. 74
ANNEX 5: SUGGESTED TEMPLATE FOR SCHOOL CONSTRUCTION ESMP (IN ADDITION TO
CONTRACTOR C-ESMP) ........................................................................................................ 75
ANNEX 6: CONSULTATION MEETINGS HELD WITH KEY STAKEHOLDERS ................................ 79
ANNEX 7: GENDER MAINSTREAMING AND GBV/SEAH ACTION PLAN ................................... 82

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ANNEX 8: INDICATIVE ENVIRONMENTAL STEWARDSHIP FRAMEWORK FOR CONTRACTORS . 83

ANNEX 9: SUMMARY OF KEY E&S ASPECTS DURING THE REPORTING PERIOD ...................... 87
ANNEX 10: WORLD BANK INCIDENT CLASSIFICATION GUIDE ................................................ 92
List of Tables
TABLE 1: KEY PROJECT ESF INSTRUMENTS............................................................................................... XIII
TABLE 2: SUMMARY OF APPLICABLE WORLD BANK E&S STANDARDS (ESSS) ................................................. 16
TABLE 3: GAP ANALYSIS FOR ENVIRONMENTAL AND SOCIAL STANDARDS – AUGUST 2020 .............................. 21
TABLE 4: STAKEHOLDER PLANNING MEETING ........................................................................................... 13
TABLE 5: SUMMARY OF KEY ISSUES RAISED DURING SEP CONSULTATIONS ON 3RD DECEMBER 2020 .................. 14
TABLE 6: ENVIRONMENTAL AND SOCIAL SCREENING TOOL FOR THE SOMALIA EDUCATION PROJECT .................... 26
TABLE 7: ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS MITIGATION ...................................................... 33
TABLE 8: LEADERSHIP OF VARIOUS SUB-COMPONENTS AND ACTIVITIES .......................................................... 43
TABLE 9: PLANNED CAPACITY BUILDING ACTIVITIES.................................................................................... 48
TABLE 10: ESMP AND BUDGET – SOMALIA EDUCATION PROJECT ............................................................... 52
List of Figures
FIGURE 1: MAP OF SOMALIA, SHOWING THE CAPITALS OF THE FMS TARGETED UNDER THE SOMALIA EDUCATION
PROJECT ...................................................................................................................................... 1
FIGURE 1: GRIEVANCE STRUCTURE FOR THE PROJECT ................................................................................. 18
FIGURE 2: GRIEVANCE PROCESS FOR THE PROJECT..................................................................................... 21
FIGURE 4: INCIDENT REPORTING PROCESS ............................................................................................... 50

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ACRONYMS AND ABBREVIATIONS
ABE Alternative to Basic Education

BRA Benadir Regional Administration
CBO Community-based organization
CEC Community Education Committee
CoC Code of Conduct
CPF Country Partnership Framework
CSO Civil society organization
DG Director General
DoECC Directorate of Environment and Climate Change
EA Environmental Audit
ECCE Early Childhood Care and Education
EHSGs Environmental Health and Safety Guidelines
EiE Education in Emergency
ESC Education Sectoral Committee
ESCP Environment and Social Commitment Plan
ESF Environment and Social Framework
ESIA Environmental and Social Impact Assessment
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
ESS Environment and Social Standards
FCV Fragility, Conflict & Violence
FGM/C Female genital mutilation/circumcision
FGS Federal Government of Somalia
FRS Federal Republic of Somalia
GBV/SEAH Gender-based Violence/Sexual Exploitation, Abuse and Harassment
GCF Green Climate Fund
GDP Gross Domestic Product
GEF Global Environment Facility
GHG Greenhouse Gas
GIS Geographic Information System
GNI Gross National Income
GRM Grievance Redress Mechanism
HADMA Humanitarian Affairs and Disaster Management Agency
IA Implementing Agency
ICR Implementation Completion Report
IDA International Development Association
IP Implementing Partner
IPF Investment Project Financing
IPV Intimate partner violence
IVAs Independent Verification Agents
LMP Labour Management Procedures
M&E Monitoring and Evaluation

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MDAs Ministries, Departments and Agencies

MIS Management Information System
MOEACC Ministry of Environment, Agriculture and Climate Change
MoECHE Ministry of Education, Culture, and Higher Education
MoET Ministry of Energy and Transport
MoPIC Ministry of Planning and International Corporation
NGO Non-governmental Organization
OHS Occupation health and safety
OP Operational Policy
OPM Office of the Prime Minister
PCU Project Coordination Unit
PDO Project Development Objective
PIU Project Implementation Unit
PMU Project Management Unit
PWDs People with disabilities
RP Resettlement Plan
RCRF Recurrent Cost and Reform Financing
RPF Resettlement Planning Framework
RVA Rift Valley Institute
SCD Systematic Country Diagnostic
SDG Sustainable Development Goal
SEA Sexual Exploitation and Abuse
SEF Stakeholder Engagement Framework
SEP Stakeholder Engagement Plan
SOPs Standard Operating Procedures
SPVA Somali Poverty and Vulnerability Assessment
TA Technical Assistance
ToR Terms of Reference
TTL Task Team Leader
TVET Technical and Vocational Education and Training
UNDP United Nations Development Program
UNHCR United Nations High Commissioner for Refugees
WBG World Bank Group

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EXECUTIVE SUMMARY
1. Introduction: More than three million children, aged between 6 and 13 years, are reportedly out
of school in Somalia.1 Due to the absence of an enabling environment (including schooling infrastructure),
only few children have the opportunity to attend school in Somalia, with a 30 percent average primary
school enrolment rate that dips to 18 percent in hard-to-reach, less secure southern regions.2 Somalia has
the sixth highest poverty rate in sub-Saharan Africa3 mainly due to this dire economic situation, high levels
of civil unrest and insurgencies, especially in the south, and the prevailing pastoralist and nomadic culture,
which makes sending children to formal schools impractical and impossible for many families.
2. According to the Somali Poverty and Vulnerability Assessment (SPVA), nearly 90 percent of Somali
households are deprived of at least one fundamental dimension: access to income; electricity; education;
or water and sanitation.4 The Somali civil war and the associated violence and collapse of state institutions
has resulted in two generations of Somali children largely missing school. In general, according to the
World Bank, just 55 percent of Somalis can read and write, while only 16 percent of Somalis have
completed primary school (compared to 34 percent in low-income Sub-Saharan African countries). Only
7 percent have finished secondary school (compared to 19 percent in Somalia’s regional peers).5
3. The imperative for improving education sector in Somalia. There is a direct correlation between
improving numeracy and literacy of children and enhancing not only lives and livelihoods but also the
country’s security outlook and future prospects for stability. A recent study by Mercy Corps shows that
children at school in Somalia are less likely to support armed groups than those missing out on education.6
The study concludes that improving access to quality education, combined with civic engagement
opportunities, pulled Somali youths away from supporting violent groups. This is attributed to the youths
being more optimistic about their future job prospects, as well as systemic core outcomes of a well-
structured education system, which imbues more confidence among youths (and children) in the use of
nonviolent means to achieve change in their communities. In addition, new educational opportunities
should seek to address the vast gender disparity that also plagues the education system, where only 25
percent of women aged between 15 and 24 are literate, compared to 38 percent for men (the Borgen
Project, 2020).
4. The Somalia Education for Human Capital Development Project. The proposed project, to be
funded by the World Bank, will focus on increasing access to basic education, with an emphasis on girls,
and improving teacher quality. The proposed interventions aim to create schooling opportunities in
Somalia at the lower primary education level. The project will support activities that promote literacy and
numeracy in the country with the aim of ensuring that schooling leads to learning and that girls participate
equally in schooling. The project is in line with the government of Somalia’s Education Sector Strategic
1
See https://www.unicef.org/somalia/education.
2
See https://borgenproject.org/facts-about-education-in-somalia/
3
World Bank, 2019. Somalia Poverty and Vulnerability Assessment: Findings from Wave 2 of the Somali High
Frequency Survey. Accessed on March 15, 2020, at https://openknowledge.worldbank.org/handle/10986/32323
4
See http://documents.worldbank.org/curated/en/464241565765065128/Findings-from-Wave-2-of-the-Somali-
High-Frequency-Survey
5
World Bank, 2020. Project Concept Note – Somalia Education for Human Capital Development Project.
6
Mercy Corps and University of San Diego, 2018. If Youths are Given the Chance: Effects of Education and Civic
Engagement on Somali Youth Support of Political Violence. Accessed on March 15, 2020, at
https://www.mercycorps.org/sites/default/files/2019-
11/If%20Youth%20Are%20Given%20the%20Chance_LR_FINAL.pdf

vii
Plan (ESSP). The project will specifically support in directly meeting four of the country’s priorities under
ESSP:7
• Strengthen management capacities and systems at federal and state levels, including
improving fiduciary mechanisms and increasing budget allocations to the education sector;
• Support learners and strengthen societal resilience among communities affected by natural
disasters and conflict;
• Continue expanding access to education for children, adolescents and youth, especially those
from disadvantaged groups such as minority groups, nomadic pastoralists, internally
displaced persons (IDPs), orphans, children from single headed households and people with
disabilities; and
• Improve the quality of learning outcomes, especially at early grade levels, and to ensure the
market relevance of learning opportunities.
5. In the long-term, the project will also help in the achievement of peace and stability, as the
interventions will help develop cohorts of school children whose education can contribute to
“peacebuilding and state building processes.”
6. Development objectives. The Project Development Objective (PDO) of the project is: “In unserved
areas, increase access to primary education with a focus on girls and improve quality of instruction.” The
project aims to create schooling opportunities in Somalia at the primary education level and to promote
literacy and numeracy in the country. It seeks to ensure that the schooling leads to learning and that girls
participate equally in schooling. Expected project outcomes are: (i) increased number of children enrolled
in primary school; (ii) increased gender parity in the targeted districts; and (iii) improvements in teacher
quality.8 The project will have four compoments as described below.
Component 1: “Systems building” will focus on the establishment and strengthening of capacity
and institutional systems at the ministries of educations at the Federal and Member State levels
of government, to establish an effective education system with a strong stewardship role for the
Federal Government. This sub-component will be achieved through implementation of activiies
in three sub-components: (1) Subcomponent 1.1: “strengthening government’s stewardship
role,” (2) Subcomponent 1.2: “establishment of a national student learning assessment system,”
and (3) Subcomponent 1.3: “strengthening monitoring and evaluation.”
Component 2: “Expansion of access to quality schooling for the disadvantaged” will focus on
supply-side constraints faced by school going-age children who do not have access to education
due to a dearth of schools or who are inhibited from enrolling in local non-state schools due to
their inability to pay school fees. The component will provide out-of-school children from
disadvantaged backgrounds in the targeted 14 districts with access to good quality schools by (i)
incentivizing nonstate providers to enroll children free of cost; and (ii) building new schools that
provide a minimum package of support that includes teachers, classrooms and school grants to
meet recurrent expenditures of these new schools.
Component 3: “Enhanced instruction quality” proposes to support the development of a 2-year

Teachers Professional Development Program (TPDP). This program will be delivered using a
7
Further details of the ESSP can be obtained at:
https://www.globalpartnership.org/sites/default/files/federal_government_of_somalia_essp.pdf
8
Details on the project components can be found in the Project Appraisal Document (PAD).

viii
blended learning approach and build the capacity of 6,000 teachers. Activities in the TPDP include
defining learning outcomes and associated course structures, creating individual course
frameworks and identifying the content to be covered in each course, developing and refining
course content and materials, and creating a contextually suitable student support system.
Component 4: “Project management” will finance key project staff at the FGS level including a
project director for overall management, project coordinator to work closely with the various
implementing entities, M&E, fiduciary and safeguards staff. Funds will also be provided for office
equipment and furniture to adequately resource project staff to manage implementation. Project
staff will also be hired at the FMS level to manage activities at that level and regularly supervise
project activities.
7. Environment and social Management Framework (ESMF). The objective of this document is to
guide environmental and social screening and assessment of the potential impacts from the project
investments and propose broad mitigation measures. This ESMF ensures that the project activities
scheduled for implementation are compliant with the relevant requirements of national9 and state-level10
policies, regulations and legislations (including any existing school construction and operation standards)
as well as the World Bank Environment and Social Standards (ESSs).
8. This ESMF sets out the principles, rules, guidelines and procedures to assess the environmental
and social impacts of interventions to be funded by the project. Therefore, it directly applies to those
activities that will be financed by the project or which are associated or implemented as a result of project
interventions. This ESMF also highlights the appropriate World Bank’s ESS and relevant existing Somalia
environmental and social regulations and policies which sub-projects and activities financed or related to
this project have to conform to.
9. The ESMF also contains an overview of the baseline environmental and social conditions in the
states identified for support under the Somalia education project, identifies and characterizes potential
environmental and social risks and impacts that might arise out of the implementation of the project’s
activities (“sub-projects”) and proposes mitigation and enhancement measures. This ESMF will, therefore,
be the basis for the preparation of the site-specific Environment and Social Management Plans (ESMPs)
including contractor ESMPs, as required during project implementation.
10. Project Environmental and Social Baseline. The project will support the construction of 180
schools, however, at the time of developing this ESMF the details of the physical infrastructure
investments that will be supported is not yet defined. However, investments are likely to include:
• School construction;
• Construction of staff rooms for use by teachers;
• Construction of storage facilities; and
• Construction of ablution facilities for school-going children and teachers.
11. Environmental Policy, Legal and Institutional Frameworks. The key legal instrument for
managing the environmental affairs in Somalia is the Constitution, specifically Article 25 (“Environment”),
9
Federal Republic of Somalia
10
The respective policies of the federal states that are to be included for support in the project

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Article 43 (“Land”), Article 44 (“Natural Resources”) and Article 45 (“Environment”). In addition, the
Cabinet of the FGS has recently approved the National Environment Policy of Somalia.11
12. Article 25 of the Constitution states that “[every Somali] has the right to an environment that is
not harmful to their health and well-being, and to be protected from pollution and harmful materials.”
The article proceeds to declare that “[every Somali] has the right to have a share of the natural resources
of the country, whilst being protected from excessive and damaging exploitation of these natural
resources.”
13. Article 45 (in Chapter 3 – Land, Property and Environment) exhorts “all people in … Somalia” to
“…participate in the development, execution, management, conservation and protection of the natural
resources and environment…” Article 43, on its part, provides guidelines on environmental and social
safeguards that can be observed. However, there are no standing environmental and/or social safeguards
in terms of legislated and/or drafted regulations.
14. Environmental Risks and Risk Rating. Currently, the environmental risk rating is ‘Moderate’ due
to the p school construction activities. The rating may be amended as more details become available. The
schools to be supported in the project, including any new constructions, will be modelled along the Safe
Schools standards as promoted by UNICEF and which are also related to the EHS standards and the school
environment, ensuring that the schools are designed and constructed to secure the children while at the
same time having minimal adverse environmental risks and impacts. These Standards focus on school
designs for the protection of children and their educational prospects and are relevant for areas prone to
armed conflicts. By following these Standards, the Somali government will ensure that it will provide
access to water and sanitation in school facilities, ensure that the indoor air quality (IAQ) is in compliance
with WHO guidelines, eliminate smoking in schools and ensure that children can safely walk to schools.
This will also meet the recommendations established in the World Bank’s EHS Guidelines.
15. The envisaged environmental risks and impacts include: loss of vegetation, soil erosion, land
clearing, changes of land uses, risk from vehicular traffic, generation of liquid waste, and hazardous wastes
(e.g., use oil, empty paint cans, etc.); risks associated with source of primary supply materials (materials
for school construction, etc.); worker occupational health and safety; construction risks during COVID-19
pandemic. Other risks include solid waste generation and disposal issues; air and noise pollution; fire
hazards; spread of communicable diseases among children; outbreak of pests and vermin; possible
generation of e-waste, especially since the project will support digital delivery of educational materials;
and open pits/quarries following extraction of construction materials. The physical components of the
project are small-scale civil works that are linked to the construction schools and associated infrastructure.
The impact of the civil works is expected to be small-scale, localized and reversible. Therefore, no
significant or irreversible adverse environmental issues anticipated from the activities to be financed
under this project. However, the project will explore the use of safety audits for the education sector, as
is currently done among humanitarian and development partners in the country, to ensure project
activities take into consideration key structural safety considerations in design and implementation.
16. Social Policy, Legal and Institutional Framework: Article 11 (3) of the Constitution states that:
“The State must not discriminate against any person on the basis of age, race, colour, tribe, ethnicity,
culture, dialect, gender, birth, disability, religion, political opinion, occupation, or wealth”. The
11
See https://twitter.com/DECC_Somalia/status/1228003267059253248, a proclamation by the Directorate of the
Environment and Climate Change (DOECC) in the Office of the Prime Minister, issued on February 13, 2020

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Constitution provides for the protection of women12, including the outlawing of female circumcision
(Article 15) and protection from sexual abuse (Article 24(5). Art. 11 provides that all citizens have equal
rights regardless of sex, and that the State must not discriminate against any person on the basis of
gender. Article 14 stipulates that a person may not be subjected to slavery, servitude, trafficking, or forced
labour for any purpose, while Article 24 prohibits sexual abuse in the workplace. The Puntland Sexual
Offences Act 2016 prohibits sexual harassment. Article 24.5 stipulates that all workers, particularly
women, have a special right of protection from sexual abuse, segregation and discrimination in the work-
place. Every labour law and practice shall comply with gender equality in the work-place.
17. The Labour Code of 197213 stipulates that all contracts of employment must include: a) the nature
and duration of the contract; b) the hours and place of work; c) the remuneration payable to the worker;
and c) the procedure for suspension or termination of contract. Furthermore, all contracts must be
submitted to the competent labour inspector for pre-approval. In regards to occupational health and
safety standards (OHS), the employer is obligated to provide adequate measures for health and safety,
protecting staff against related risks, including the provisions of a safe and clean work environment and
of well-equipped, constructed and managed workplaces that provide sanitary facilities, water and other
basic tools and appliances ensuring workers’ health and safety.
18. The Labour Code further forbids work for children below the age of 12, but allows employment
of children between the age of 12-15 years, however the employment has to be compatible with proper
protection, health and the morals of children. The Code also recognizes freedom of association. Employers
are prohibited from engaging in any kind of discrimination or restriction of the right of freedom of
association. Workers are allowed to join trade unions. The Labour Code stipulates the right to equal pay
for the same work. Women are entitled to 14 weeks of maternity leave at half pay.
19. The Somali Penal Code of 1962 criminalizes rape and other forms of sexual violence as well as
forced prostitution. Articles 398-9 provide that ‘carnal intercourse’ and ‘acts of lust committed with
violence’ are punishable with 5-15 years and 1-5 years of imprisonment, respectively. Abduction for the
purpose of lust or marriage is prohibited under Art 401. The Family Code of 1975 sets the minimum age
for marriage at 18 for males and females. Females between the age of 16 and 18 can marry with their
guardian´s consent. Marriage is based on equal rights and duties.
20. Somalia National Gender Policy (2016) includes strategies to eradicate harmful traditional
practices such as female genital mutilation/cutting (FGM/C) and child marriage and to improve services
for the management of GBV/SEAH cases.
21. Social Risks and Risk Rating. The social risk rating is adjudged as ‘High’. The project is designed
to have a positive social impact, purposely targeting poor and disadvantaged populations including IDPs,
minority groups, rural and pastoralist/nomadic communities. A preliminary assessment of potential social
risks and impacts establishes that there are direct risks from project activities related to civil works from
construction of schools, which could lead to land acquisition, restrictions on land use, resettlement and
labour influx. In addition, the use of local labour and the reliance on community partnerships and
management could lead to cases of child labour and forced labour.
12
LOGICA, Gender and Conflict Note Somalia, March 2013, p. 2, accessed at: http://www-
wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2014/03/31/000333037_20140331154002/Re
ndered/PDF/862980BRI0Box30gica0DissNoteSomalia.pdf
13
The Code has recently been revised, but the revisions have not yet been passed and signed into law.

xi
22. The risks of gender-based violence (GBV/SEAH), including sexual exploitation and abuse (SEA) and
sexual harassment (SH), is currently assessed as ‘High’ based on the existing high rates of GBV/SEAH in
the country, extending from conflict and shocks such as droughts, floods and other climate-related
challenges, and social norms that entrench gender inequalities in the country. In addition, because the
project’s scope and focus will be on predominantly rural sites, the proposed scope of works, and the
absence of appropriate institutional structures to manage risks and weak mitigation systems and lower
absorption capacity, has raised the risk rating.
23. The project will be implemented in areas of fragility due to endemic poverty, acute drought, floods
and protracted conflict and insecurity which may make direct access to beneficiaries challenging and
amplify risks related to lack of effective stakeholder engagement, community participation, grievance
redress and application of other risk mitigation protocols. Other cumulative risks include systemic
weaknesses related to MoECHE’s capacity for preventing adverse social impacts on the project and
mitigating and offsetting impacts of social harm whenever they occur.
24. Overall Risk Rating. The engineering capacity of the client is nascent, but growing in regards to
construction of small-scale civil works. However, the client's ability to apply World Bank Environmental
and Social Standard (ESS) is limited, due to a dearth of appropriate technical capacity for safeguards at
the MoE and lack of experience managing environmental and social safeguards. In addition, the country
risks are extensive due to political and security considerations; the limited ability for the World Bank to
supervise environmental and social risk management and lack of standards and institutions in Somalia for
managing environmental and social risk. Therefore, the overall environmental and social risk rating is
“High” under World Bank’s Environmental and Social Risk Classification system (ESRC).
25. Applicable Environmental and Social Standards (ESSs). Due to limited environmental and social
laws and regulations at both national and state levels in Somalia, the project will apply the World Bank
Environment and Social Framework (ESF)14. Eight ESSs are considered relevant to the activities
implemented under the project:
• ESS 1: “Assessment and Management of Environmental and Social Risks and Impacts”
• ESS 2: “Labour and Working Conditions”
• ESS 3: “Resource Efficiency and Pollution Prevention and Management”
• ESS 4: “Community Health and Safety”
• ESS 5: “Land Acquisition, Restrictions on Land Use and Involuntary Resettlement”
• ESS 6: “Biodiversity and Sustainable Management of Living Natural Resources”
• ESS 8: “Cultural Heritage”
• ESS 10: “Stakeholder Engagement and Information Disclosure”
26. Where potential environmental and social risks and impacts are anticipated, the project in priority
order: take measures to avoid, minimize, mitigate, manage or compensate adverse impacts. In addition,
the project will enhance positive impacts in project selection, location, planning, design, implementation
and management.
27. Potential Environmental and Social Benefits of the Project. The anticipated social benefits of the
project include:
14
For better understanding of the World Bank’s ESF, please visit https://projects.worldbank.org/en/projects-
operations/environmental-and-social-framework/brief/environmental-and-social-standards

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• inclusion of out-of-school children in schooling and improvements in learning will lead to a

larger number of students completing lower primary education;
• availability of larger number of cohorts transitioning into secondary schooling;
• improving girls’ participation in schooling by introducing incentives for increasing and
maintaining girls’ enrolment in school will improve the gender situation in Somalia;
• encouraging the recruitment of female teachers and prioritizing support for female teachers
will ensure more women participation in the education sector in Somalia, with positive
downstream outcomes;
• inclusion of training modules in promoting girls’ education and creating safe, inclusive school
environments with specific attention to identifying and addressing violence, including
GBV/SEAH in schools, will ensure safer environments for children at school;
• employment opportunities for the community members through construction, rehabilitation
and maintenance of the school infrastructure; and
• in the long term, the project will contribute towards development of social cohesion and
national stability.
28. The project will have environmental benefits, including the following:
• provision of improved, quality school infrastructure including WASH facilities will lead to
improved hygiene standards, less exposure of school-going children to communicable
diseases; and
• the formalised schooling environment will provide a basis for incorporating environmental
education and stewardship into the school curriculum and activities, resulting in higher
levels of environmental stewardship.
29. Mitigation Measures and Monitoring. In order to address potential adverse environmental and
social risks and impacts, an environmental and social screening process has been proposed under this
ESMF. This will be applied in such a way as to ensure that potential negative risks and impacts of the
project are prevented or mitigated appropriately, while enhancing positive impacts. This will be the
responsibility of the FGS and FMS social and environmental specialists as well as implementing partners
and contractors. The community education committees (CECs) and the social accountability committees
will play a key role in ensuring that the proposed mitigation measures are implemented.
30. To facilitate the mitigation of risks several key ESF instruments including this ESMF will be
prepared and activated in the life of the project, as summarized in Table 1.
Table 1: Key project ESF instruments

# Document Purpose
1. Stakeholder Sets out inclusive and effective mechanisms for engagement of stakeholders at all
Engagement Plan (SEP) levels including feedback and complaints mechanism and transparency. The SEP
include a project side Grievance Redress Mechanism (GRM), Inclusion Plan and an
Information Disclosure Plan.
2. Labour Management Guides how direct and indirect workers will be sourced and managed fairly and
Procedures humanely and in a manner that reduces harm on other workers, students and the
community.
3. GBV Action Plan Articulates the key risks and key mitigation measures for workers, students and the
community, as well as the identification of GBV/SEAH Service Providers and
reporting and referral protocols in the event of cases. It outlines communication
and training requirements for communities and all project related staff, including

xiii
project workers, teachers, and school administrators. An Accountability and

Response Framework will elaborate the adoption of mitigation measures, including
awareness raising, training and use of code of conducts (CoC), and collaboration
with local communities and GBV/SEAH-related service providers
4. Security Management Outlines measures to minimize security risks in the project including the protection
Plan of schools, students, workers and communities and to ensure that security
personnel employed as part of the project do not use undue force or impact
negatively on communities.
5. Resettlement Planning Outlines how land acquisition and/or restriction on land use, which might result in
Framework (RPF) involuntary physical and/or economic displacement will be managed and guidance
on the preparation of Resettlement Plans (RPs), as needed. It will also provide the
protocols for voluntary land donations and agreements.
31. Stakeholder engagement plan (SEP): Engagement and consultations on the project design and
the planned activities and implementation arrangements have been held with key institutional
stakeholders including the relevant Government agencies, development partners and other cooperating
agencies and community representatives. The SEP will be updated and refined during project
implementation as needed. The SEP outlines information disclosure requirement, the project Grievance
Redress Mechanism (GRM), and a plan for inclusion of disadvantaged groups.
32. Grievance Redress Mechanism. The MoECHE will set up a project-specific GRM for people to
report concerns or complaints, if they feel unfairly treated or are affected by any of the subprojects. The
mechanism will amongst other things: provide information about project implementation; provide a
forum for resolving grievances and disputes at the lowest level; resolve disputes relatively quickly before
they escalate to an unmanageable level; facilitate effective communication between the project and
affected persons; and win the trust and confidence of project beneficiaries and stakeholders and create
productive relationships between the parties.
33. The GRM will be implemented at the different levels of the project, including community, district,
FMS and FGS. It will ensure that trusted and accessible mechanisms are available to all stakeholders
including VMGs, and that all complaints and logged and followed up. More details of the GRM can be
found in the SEP.
34. Project Implementation Arrangements. The proposed project will be implemented by the
Ministry of Education, FGS in coordination with FMS. A Project Steering Committee (PSC) will be
established to provide oversight and policy direction while a Project Management Unit (PMU) will be set
at the FGS level to manage the activities. There will be Implementation Units (PIUs) established at the
State level to oversee implementation in the respective districts. The PMT will including a Project
Coordinator, separate Environment and Social Safeguard Specialists and GBV/SEAH specialist,
Communication Specialist and Monitoring and Evaluation (M&E) Specialists. The FMS PIUs will include
Project Managers, a full time Social Safeguard/GBV/SEAH Specialist and a part time Environmental
Specialist. All the positions will be competitively recruited and diversity will be encouraged. These staff
members will be provided with capacity building support in environmental and social safeguards. MoECHE
will work closely with the FMS MoEs and other ministries and departments including World Bank funded
projects and development partners. The school management and community education committees will
lead the project at community level, with the social accountability committees providing an independent
structure to ensure transparency, promote inclusivity and collecting and raising grievances at the
community level.

xiv
35. Technical capacities in the MoECHE are limited, as such, an external third party (an NGO or agency
with requisite skills as will be spelt out in the terms of reference) may be appointed to support the ministry
to carry out training or capacity building on environmental or social aspects of the project. Measures need
to be taken to enhance the safeguards capacity to improve environmental and social performance during
project implementation. This may include safeguards training for staff or communities or CECs or social
accountability committees.

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1. INTRODUCTION AND PROJECT CONTEXT
1.1 Project Context

1. Situated in the Horn of Africa, Somalia is bordered by Ethiopia to the west, Djibouti to the
northwest, the Gulf of Aden to the north, the Guardafui Channel and Somali Sea to the east, and Kenya
to the southwest. With a total land area of 637,657 km2 and situated between 2°S and 12°N latitudes and
41° and 52°E longitudes, Somalia has the longest coastline on Africa's mainland. The country’s terrain
consists mainly of plateaus, plains and highlands. Climatically, hot conditions prevail year-round, with
periodic monsoon winds and irregular rainfall.
2. Somalia is faced with two critical

challenges: (i) creating sustainable internal peace;
and (ii) constructing a path for shared economic
growth and prosperity. Among the most critical
sectors for the emerging state is the education
sector. However, as the country emerges from
nearly three decades of civil strife, the education
sector is in poor shape. Years of internal conflict
virtually wrecked the education system, resulting
in a sector "characterized by poor-quality
education, insufficient numbers of qualified
teachers and inadequate resources," according to
the United States Agency for International
Development (USAID, 2020). Country-wide, more
than three million children, aged between 6 and 13
years, are reportedly out of school. Due to the
absence of an enabling environment (including
schooling infrastructure), only few children have
the opportunity to attend school in Somalia, with a
30 percent average primary school enrolment rate Figure 1: Map of Somalia, showing the capitals of the FMS
that dips to 18 percent in hard-to-reach, less secure targeted under the Somalia education project
southern regions.
3. Somalia has the sixth highest poverty rate in sub-Saharan Africa (World Bank, 2019). The quality
of life in the country is also among the lowest in the world. An analysis of the Human Development Index
(HDI), used to rank countries into four tiers of human development (very high, high, medium and low),
shows that Somalia is in the lowest tier, scoring 160 out of 164 countries. Due to this dire economic
situation, high levels of civil unrest and insurgencies, especially in the south, and the prevailing nomadic
culture, sending children to formal schools is impractical and impossible for many families.
4. According to the Somali Poverty and Vulnerability Assessment (SPVA), nearly 90 percent of Somali
households are deprived of at least one fundamental dimension: access to income; electricity; education;
or water and sanitation. The Somali civil war and the associated violence and collapse of state institutions
has resulted in two generations of Somali children largely missing school. In general, according to the
World Bank (2019), just 55 percent of Somalis can read and write, while only 16 percent of Somalis have
completed primary school (compared to 34 percent in low-income Sub-Saharan countries) and only 7
percent have finished secondary school (compared to 19 percent in Somalia’s regional peers).

1
5. Somalia’s Education Sector Strategic Plan (2018-2020) calls for prominence to be given to three
sectoral priorities: (i) sustenance of education services in emergency context; (ii) strengthening resilience
by overcoming educational inequities; and (iii) implementation of Safe Schools Declaration to protect
education from attack. The proposed project’s interventions will have implications for each of the three
priorities.
1.2 The Somalia Education for Human Capital Development Project

6. The Somalia education project has a tentative project budget of US$40 million, which will be spent
on four components over a period of 5 years. The proposed project aims to create schooling opportunities
in Somalia at the lower primary education level and thereby promote literacy and numeracy in the
country. It will ensure that the schooling leads to learning and that girls participate equally in schooling.
Over the project’s life, dependent on the dedication of adequate investments by government and its
development partners, the proposed project is expected to increase the number of children enrolled in
lower primary school, increase gender parity at the targeted level and increase the share of students
attaining grade level competency in key subjects.
7. The theory of change in education holds that short-term but high-potential interventions can
rapidly increase schooling opportunities, with a deliberate focus on the most disadvantaged communities
in Somalia, specifically those residing in rural areas and girls. The project proposes to leverage Somalia’s
strengths, specifically its high mobile penetration and relatively advanced internet telephony system to
test innovative approaches to enhancing teacher quality and provide effective teaching and learning
materials to students using digital technology. The project will also support the development of a robust
system for regularly and reliably collecting data on sector outcomes. In addition, the project will focus
specifically on building systems to systematically and regularly collect information on student learning
achievements.
1.3 Project Development Objective and Components
8. Project Development Objective. The Project Development Objective (PDO) of the Somalia
education project is: “In unserved areas, increase access to primary education with a focus on girls and
improve quality of instruction.”
9. The project will have four compoments as described below.
Component 1: “Systems building” will focus on the establishment and strengthening of capacity
and institutional systems at the ministries of educations at the Federal and Member State levels
of government, to establish an effective education system with a strong stewardship role for the
Federal Republic. This sub-component will be achieved through implementation of activiies in
three sub-components: (1) Subcomponent 1.1: “strengthening government’s stewardship role,”
(2) Subcomponent 1.2: “establishment of a national student learning assessment system,” and (3)
Subcomponent 1.3: “strengthening monitoring and evaluation.”
Component 2: “Expansion of access to quality schooling for the disadvantaged” will focus on
supply-side constraints faced by school going-age children who do not have access to education
due to a dearth of schools or who are inhibited from enrolling in local non-state schools due to
their inability to pay school fees. The component will provide out-of-school children from
disadvantaged backgrounds in the targeted 14 districts with access to good quality schools by (i)
incentivizing nonstate providers to enroll children free of cost; and (ii) building new schools that

2
provide a minimum package of support that includes teachers, classrooms and school grants to
meet recurrent expenditures of these new schools. Approximately 180 new schools are planned
to be built, which will likely result in 820 new classrooms. All schools will be designed with
functioning WASH facilities. About 820 qualified teachers will be hired to provide instruction to
the 100,000 pupils that will be enrolled in the new schools, 50 percent of whom will be girls.
For the new school construction:

• School location planning. School sites will be selected based on the findings of a needs
assessment survey. Communities that have large numbers of primary-aged girls and boys that
do not have a school (public or non-state) within a 30-minute walk will be prioritized. This
survey will assess land tenure, social issues such as conflict over land, and presence of VMGs,
environmental factors and community support for new schools and will determine the size of
the school to be built (number of classrooms). During survey administration, community-
based organizations will be consulted for advice on school location planning and demand for
schooling.
• Community mobilization. Communities will be mobilized through Village Development

Committees (VDC) in places where there is no CEC to play a key role in selecting the CEC as
per the government CEC policy. The CEC which will be responsible for (i) placement,
construction and management of the new schools (ii) responsible for day-to-day supervision
of the school, including of decision-making on school management related issues and
monitoring teacher attendance in line with government’s policy on CECs; (iii) enrolling
students including meeting minimum targets for girls enrolment and following up on steps to
reduce drop-outs; (iv) identifying potential teachers from their communities, with preference
for female teachers; (v) locating and arranging sites for schools and maintenance of school
facilities; and (vi) submitting periodic reports, including via a mobile app when possible, to
District Education Officers on student, teacher, and school matters.
• School construction. New schools with a proportional allocation of gender-separated

washrooms and water delivery points for each school will be constructed. Construction
specifications for the new classrooms and schools15 will conform to the government’s school
prototypes, align with agreed standards (safe, disability-inclusive, resilient, and climate-
smart), and incorporate a modular approach as appropriate to suit local needs so as to ensure
optimal coverage and minimal distances for children to travel. The MoECHE, with the support
of its construction supervision contractor, will establish guidelines for phasing in the
construction and opening of the schools over 4 years. All new schools will be provided with
furniture for students, teachers, and administrators, as well as a core set of equipment for
teaching and learning, such as white boards or instructional technology for the larger schools.
Component 3: “Enhanced instruction quality” proposes to support the development of a 2-year

Teachers Professional Development Program (TPDP). This program will be delivered using a
blended learning approach and build the capacity of 6,000 teachers. Activities in the TPDP include
defining learning outcomes and associated course structures, creating individual course
frameworks and identifying the content to be covered in each course, developing and refining
course content and materials, and creating a contextually suitable student support system.
15
Approximately 180 new primary schools, providing altogether 820 classrooms.

3
Component 4: “Project management” will finance key project staff at the FGS level including a
project director for overall management, project coordinator to work closely with the various
implementing entities, M&E, fiduciary and safeguards staff. Funds will also be provided for office
equipment and furniture to adequately resource project staff to manage implementation. Project
staff will also be hired at the FMS level to manage activities at that level and regularly supervise
project activities.
1.4 Project Beneficiaries

10. While the project supports country-wide policy and system development, such as the platforms
for teacher development and content delivery to student and Early Grade Reading Assessment (EGRA),
the focus will be on the educationally most disadvantaged parts of the country through Component 2 of
the project to create supply of schooling opportunities with quality. Under the project, priority will be
given to districts in which children do not attend school because of either an inadequate supply of school
places or because they experience social hardships that inhibit their demand for schooling. Districts will
be selected based on current education access rates; those with Gross Enrolment Rates (GER) below 10%
would be considered eligible, with priority given to districts that engage directly in social safety net
support programs, thereby ensuring demand-side support that enables children to attend school. Districts
that are not accessible due to security reasons for adequate supervision by the World Bank will be
excluded at this stage.
11. It is anticipated that two districts each from Banadir, Galmudug, Hirshabelle, Jubaland, Puntland,
Southwest and possibly Somaliland will be selected. Once districts selection has been confirmed, an
assessment of schools will be carried out to prioritize school sites for construction These new schools will
be in areas where there are no existing schools in a 30 min radius thus they are expected to be in rural
areas. This assessment will likely be carried out by a consortium of organizations working in the different
districts using a participatory methodology. The assessment will screen out areas where there is
contested land or multiple claims on land. Consultations with all residents, users and residents on the
siting of the school and agreements on land will be an important aspect of site selection. Consideration
will be made of geographical spread, and inclusivity ensuring that in any particular district all schools are
not selected in one clan’s area. The assessment will also explain the objectives and criteria of the project
and provide information about stakeholder engagement plans and GRM focal points. The assessment will
also help identify the existence and capacity of potential construction companies and their capacity to
comply with E&S requirements as well as measures to prevent elite capture by involving CECs and where
not available the village development committee (VDC) and other representative community structures.
12. The project will benefit approximately 100,000 primary school-aged students, at least 50%)
percent of whom will be girls, in the selected 14 target districts. Benefits will accrue through improved
access to new schools in close proximity to communities enabling children to attend school. The project
targets the areas with the lowest access rates to maximize coverage from investments. Component 2 will
directly benefit these students through the establishment of new schools, provision of teachers and
school grants for teaching and learning materials and support for poor households to send their children
to non-state schools free of charge.
13. Students, teachers and communities country-wide will benefit from improved system
performance and a greater focus on learning outcomes. In particular, interventions under component 3
will benefit students throughout the country through the availability of digital content and improved
instruction and teacher quality. In addition, a total of 6,000 teachers are expected to benefit from

4
professional development through a blended training program. The indirect beneficiaries include traders,
salesmen, IT companies, contractors and primary suppliers.
14. The FGS will be responsible for sustaining the investments in the education sector beyond the
project financing period. This would be done by absorbing the established schools and the teachers into
the Federal and State Education structures. The ongoing restructuring and strengthening of the education
sector will take into account the structures being established through this and other education projects.
15. The project envisages both direct and indirect beneficiaries. The direct beneficiaries will include
school-going children, teachers, parents, communities targeted for support, MoECHE and FMS MoEs.

5
2. SCOPE AND METHODOLOGY OF THE ESMF
2.1 Purpose and Scope of the ESMF

16. This ESMF has been developed due to the fact that specific subprojects, that is the actual schools
to be constructed using project funds, will only be identified during implementation of the project. The
purpose of the ESMF is to ensure that the sub-projects executed under the project address and identify
measures to avoid and minimize negative environmental and social impacts, as much as possible. Where
these cannot be avoided, the impacts are adequately identified, assessed and necessary mitigation
measures designed and implemented following relevant, existing Somalia environmental and social
legislation (where available) and the World Bank’s ESS.
2.2 ESMF Justification

17. The ESMF clarifies appropriate ESS, processes, and mitigation principles, organizational
arrangements and design criteria to be applied to subprojects (see Annex 1 on the list of ESS). These
standards, principles, instruments and other documents are to be prepared during project
implementation by the Project Management Unit (PMU), MoECHE, Project Implementation Units (PIUs)
at the State level in the project-supported localities in Somalia and private sector companies (such as
construction companies and suppliers) participating in the project.
18. The FGS PMU and FMS PIUs will use and refer to this ESMF during project implementation. Where
appropriate, site specific Environmental and Social Management Plans (ESMPs) will detail how voluntary
land donation, inclusion and consultation requirements have been met will be prepared during project
implementation following the guidelines provided in this ESMF (see Annex 4). It remains the responsibility
of the E&S safeguards officers within the PMUs to ensure that the necessary mitigation plans are
developed and adhered to by the various implementing agencies.
19. The specific objectives of this ESMF are to:

▪ Ensure that the implementation of the project, for which the exact locations of the sub-project
sites are not definitively identified at this stage, will be carried out in an environmentally and
socially sustainable manner;
▪ Provide information about scope of adverse environmental and social risks and impacts expected
during sub-project planning, construction and operation, describe the approach to mitigation and
monitoring actions to be taken’ and cost implications;
▪ Clarify the roles and responsibilities for the project: FGS PMU, FMS PIU, district education staff, ,
community education committees (CECs), social accountability committees and rother
representative community structures, contractors, and operators, and other stakeholders with
regard to environmental and social due diligence, management of risks and impacts, and
monitoring; and
▪ Provide the project implementers with an E&S screening process and risk management
procedures that will enable them to identify, assess and mitigate potential environmental and
social impacts of subproject activities, including through the preparation of site-specific ESMPs,
where applicable (the screening checklist is presented in Annex 2).
2.3 ESMF Principle

20. This ESMF will guide the PMU and PIUs in implementing the project in line with World Bank ESF
and Somalia government E&S management standards.

6
2.4 Methods
21. The ESMF was prepared through literature review and stakeholder discussions. The MoECHE-
based project preparation team in Mogadishu, with close coordination with the World Bank, undertook a
review of relevant national legislation, policies, and guidelines, including the World Bank ESS related to
this Project. Key informant interviews were carried out and stakeholder consultations workshops were
conducted in December 2020 and February 2021.

7
3. POLICY, LEGISLATIVE AND INSTITUTIONAL FRAMEWORKS
3.1 Overview
22. This section describes the existing policy, legislative and institutional framework that will be
important for consideration in the design, implementation, monitoring and evaluation of the project. This
section begins with the existing framework in the FGS, before focusing on the respective systems in
Puntland, South-West State, Galmudug, Jubaland states and the Benadir Regional Administration.
23. It is important to note that at the time of the development of this ESMF, South-West State and
Jubaland did not have any significant legislative frameworks governing the management of the
environment and natural resources sector. It was therefore difficult to include the respective policy,
legislative and institutional frameworks for these states in this ESMF. The World Bank has undertaken a
systemic study in South-West State and Jubaland that has identified existing gaps in environmental
regulations, policies and legislation, with a view of capacity enhancement for the two states.
3.2 Somalia National Laws, Policies and Legislations
3.2.1 Provisional Constitution of the Federal Republic of Somalia

24. The key legal instrument for the management of environmental affairs in Somalia is the
provisional Constitution, especially Article 25 (“Environment”), Article 43 (“Land”), Article 44 (“Natural
Resources”) and Article 45 (“Environment”). Article 25 of the Constitution states that “[every Somali] has
the right to an environment that is not harmful to their health and well-being, and to be protected from
pollution and harmful materials.” The article proceeds to declare that “[every Somali] has the right to have
a share of the natural resources of the country, whilst being protected from excessive and damaging
exploitation of these natural resources.”
25. Article 45 (in Chapter 3 – “Land, Property and Environment”) exhorts “all people in … Somalia” to
“participate in the development, execution, management, conservation and protection of the natural
resources and environment.” Article 43, on its part, provides guidelines on environmental and social
safeguards that can be observed. However, there are no standing environmental and/or social safeguards
in terms of legislated and or drafted regulations. The Article also affirms that the FGS shall give priority to
the protection, conservation, and preservation of the environment against anything that may cause harm
to natural biodiversity and the ecosystem.
26. Article 12 of the Constitution addresses issues of application of fundamental rights. Further, the
Provisional Constitution has made commitments on women’s empowerment and gender mainstreaming.
Article 15 (1,2,4) together with Article 24(5) of the Constitution provides for the protection of women16
against all forms of violence and provides for protection from sexual abuse, segregation and
discrimination. Article 11 (1) together with sub article (3) respectively provides that all citizens have equal
rights regardless of sex, religion, social or economic status, political opinion, clan, disability, occupation,
birth or dialect shall have equal rights and duties before the law, and that the State must not discriminate
against any person on the basis of age, race, colour, tribe, ethnicity, culture, dialect, gender, birth,
disability, religion, political opinion, occupation, or wealth. Article 14 stipulates that a person may not be
16
LOGICA, Gender and Conflict Note Somalia, March 2013, p. 2, accessed at: http://www-
wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2014/03/31/000333037_20140331154002/Re
ndered/PDF/862980BRI0Box30gica0DissNoteSomalia.pdf

8
subjected to slavery, servitude, trafficking, or forced labour for any purpose, while Article 24 (5) prohibits
sexual abuse in the workplace. The Puntland Sexual Offences Act 2016 prohibits sexual harassment.
27. On human trafficking, the Constitution states that a person may not be subjected to slavery,
servitude, trafficking or forced labour offences. Every labour law shall comply with gender equality. Article
24(5) stipulates that all workers, particularly women, have a special right of protection from sexual abuse,
segregation and discrimination in the work place. Every labour law and practice shall comply with gender
equality in the work place.
3.2.2 The Labour Code of 197217

28. It stipulates that all employment contracts must include: a) the nature and duration of the
contract; b) the hours and place of work; c) the remuneration payable to the worker; and d) the procedure
for suspension or termination of contract. Furthermore, all contracts must be submitted to the competent
labour inspector for pre-approval.
29. In regards to occupational health and safety (OHS) standards, the employer is obligated to provide
adequate measures for health and safety, protecting staff against related risks, including the provisions of
a safe and clean work environment and of well-equipped, constructed and managed workplaces that
provide sanitary facilities, water and other basic tools and appliances ensuring workers’ health and safety.
30. The Code further stipulates that workers have the right to submit complaints and the employer
must give the complaints due consideration. Remuneration must be adequate in view of the quality and
quantity of the work delivered, and must be non-discriminatory in regards to age, gender and other
aspects. Maximum number of working hours per week are 8 hours per day and 6 days per week. Some
work is considered dangerous and unhealthy and forbidden for women and youth (defined as 15-18 years
of age). This includes the carrying of heavy weight or work at night.
31. The Labour Code further forbids work for children below the age of 12, but allows employment
of children between the ages of 12-15, but employment has to be compatible with proper protection,
health and the moral of children. The Code also recognizes freedom of association. Employers are
prohibited from engaging in any kind of discrimination or restriction of the right of freedom of association.
Workers are allowed to join trade unions. Further, the Labour Code stipulates the right to equal pay for
the same work and women are entitled to 14 weeks of maternity leave at half pay.
3.2.3 The Somali Penal Code of 1962

32. The Code criminalizes rape and other forms of sexual violence as well as forced prostitution.
Articles 398-9 provide that ‘carnal intercourse’ and ‘acts of lust committed with violence’ are punishable
with 5-15 years and 1-5 years of imprisonment, respectively. Abduction for the purpose of lust or marriage
is prohibited under Art 401.
3.2.4 The Agricultural Land Law (1975)

33. The law abolished private ownership of land and converted the land tenure to leasehold, where
families were forced to seek leasehold from the government. Individuals desiring land were to register
their holdings within a 6-month period (upon the enactment of that law). The law does not recognize
customary land holdings.
17
The Code has recently been revised, but the revisions have not yet been passed and signed into law.

9
3.2.5 Family Code of 1975

34. Minimum age for marriage is 18 for males and females. Females between the age of 16 and 18
can marry with their guardian´s consent. Marriage is based on equal rights and duties. A husband can
divorce by repudiation (talaq). The mother retains custody of the children after separation but she loses
custody if she remarries.
3.2.6 Somalia National Gender Policy (2016)

35. The Gender policy includes strategies to eradicate harmful traditional practices such as FGM/C
and child marriage and to improve services for the management of GBV/SEAH cases.
3.2.7 Somalia National Environment Policy

36. The Somali Cabinet, on February 13, 2020, approved the National Environmental Policy. The
stated goal of environmental policy is to improve the health and quality of life of the Somali people. The
development of this policy was backstopped by the Global Environment Facility (GEF) and the United
Nations Development Program (UNDP). This is the first time that an environmental policy has been
developed and taken to Cabinet for approval since the collapse of the previous central administration in
1991.
3.2.8 Somalia National Education Policy

37. The government of Somalia has prepared the Education Sector Strategic Plan (2018-2020).18 This
Plan calls for investment by Somalia’s development partners in the following strategic areas:
• Resilience and education in emergency (EiE);
• Early childhood care and education (ECCE);
• Primary education;
• Secondary education;
• Alternative to basic education (ABE); and
• Technical and vocational education and training (TVET).
38. The project will contribute to the achievement of priority pillars in a number of these strategic
areas, including “resilience and EiE”, “ECCE,” and “primary education.”
3.2.9 Somalia National Construction Standards

39. The Ministry of Public Works and Reconstruction has published national construction standards.
A policy has been announced which established standards for new public construction or renovation
projects funded by, or on behalf of, the Government of Somalia. The policy goal is to provide access to
public buildings by people with disabilities (PWDs). The project will ensure that children with disabilities
are included in the Project.
40. The national standards emphasize and promote “universal design,” meaning that the design of
structures, environments, and services to be usable by all people, to the greatest extent possible, without
the need for adaptation or specialized designs. Under these national standards, normal maintenance, re-
roofing, painting or wallpapering, or changes to mechanical or electrical systems are not alterations and,
therefore, the standards do not apply unless they affect the accessibility of the building or facility. This
standard is important for the project.
18
See https://www.globalpartnership.org/sites/default/files/federal_government_of_somalia_essp.pdf

10
3.2.10 The Office of the Ombudsman (Established in Article 111J)

41. It is stipulated that the office shall (however, it is unclear with the Office of the Ombudsman is
functional at FGS or FMS level):
• Investigate complaints regarding allegations or outright violations against basic rights and
freedoms, abuse of power, unfair behaviour, mercilessness, lack of clemency, indiscipline or
disrespect towards a person that lives in Somalia by an officer who works at the various levels
of government, an apparently unfair behaviour, or act in a corrupt manner, or a behaviour by
an officer deemed as illegal by a democratic society or regarded as mischief or injustice.
• Investigate complaints in relation to the activities of the Public Service Commission of the
government, administrative institutions of the government, and the defence and police forces
whoever such complaints relate to, failure to equally align those services or fair recruitment
among all people in those services or to administer those services fairly.
• Take appropriate steps that the public calls for, to rectify or change items mentioned in
o earlier clauses through a fair, and appropriate process, which include, but are not
limited to:
▪ Consultations and sacrifices among the people concerned;
▪ Reporting on the complaints and matters presented to the Ombudsman, and
submit to the head of the offender;
▪ To forward the matter to the Attorney General;
▪ To bring the matter before a court that forbids improper conduct by an
officer.
3.3 The National Security Commission

42. A National Security Commission shall be established by federal law (Article 111H). The National
Security Commission is an independent entity that comprises security experts from all sectors. The
mandates of the National Security Commission include:
i. Study and develop an integrated security framework to address the present and future needs of
Somalia for review and adoption by the Federal Parliament;
ii. Present proposals to ensure that human security is prioritized and incorporated into the national
security framework;
iii. Develop a framework through which the public may provide oversight and monitor security
related expenditure; and
iv. Seek redress from abuses by security personnel.
3.4 Laws and Regulations in Federal Member States of Somalia

43. Puntland. The National Environmental Policy (2015) provides the overall guiding policies relating
to the management of the environment and natural resources. This policy allows a rationalisation of
administrative regulations and policies to eliminate deficiencies or inconsistencies with other previous
policies. The policy promotes the use of appropriate environmental assessment instruments such as the
Environmental Impact Assessment (EIA) and Strategic Environmental Assessment.
44. The legislative and policy environment in Puntland is still weak, although there has been good
progress compared to the FGS. Puntland’s Constitution envisages, in Article 96, the importance and
protection of the environment. Among the key features include combating deforestation, soil erosion and
pollution. The Constitution forbids charcoal trading in endangered plant and animal species. Prohibition
has been placed too on creating of unsustainable urban-like sprawls in rural settings.

11
45. The existing policies, laws and regulations in Puntland relevant to the Somalia education project
implementation; include:
• Environmental Policy (2014) approved by the Cabinet and Parliament;
• Environmental Management Act (2016) approved by the Cabinet;
• Puntland Rangeland Management Policy, 2nd Edition (2016-2025);
• Puntland Waste Management Policy (2016);
• EIA Act and Regulation (2016) approved by Cabinet and Parliament;
• Puntland Climate Change Strategy (2016); and
• Ministry of Environment and Climate Change Strategic Plan (2016-2020).
• Puntland Sexual Offences Act 2016
46. The environmental licensing process in Puntland is relatively straightforward. Ministries control
the licensing procedures, thus:
• The Ministry of Environment and Climate Change (Puntland) has the powers to grant any of the
licenses sought;
• Every license shall be subject to such conditions as may be specified therein during the issuance
stage;
• The Minister (or any person authorized by him or her) may at any time cancel or suspend any license
granted by or on behalf of the minister;
• Grounds for cancellation include suspicions of infringement of any of the conditions upon which said
license has been granted;
• The minister may, at any time, also vary the conditions of any such license; and
• Any person aggrieved by any order under this clause may appeal to the minister, whose decision shall
be final.
• However, it is unclear if school construction work in Puntland would have to be undertaken subject to
the licensing requirements of the state’s Environmental Impact Assessment Act. Schedule 1 of the
Act19 classifies projects based on likely scale of adverse environmental impacts on the environment.
In this Schedule, small-scale civil works of the nature envisaged in this project are not included.
3.5 Institutional Capacity for Environmental Management
47. Federal Republic of Somalia. The Somali government has introduced changes in the institutional
set-up dealing with environmental issues in the country. A Directorate of the Environment and Climate
Change (“DoECC”) has been formed within the Office of the Prime Minister. The Directorate is mandated
to draft the national environmental policies, regulations and legislations including establishing of the
Environmental Quality Standards, Sectoral Environmental Assessments (SEAs), Environment Impact
Assessments (EIAs) and Environmental Audits (EAs), among others. However, necessary laws or
legislations have not yet been formulated, and no commissions or authorities have been established as of
July 2019.
48. The DoE, part of the Office of the Prime Minister (OPM), takes the lead in the formulation of
environmental policies and laws, coordinates stakeholder consultation and partnerships with state
agencies, local councils, civil society and private sector entities (Somalia State of the Environment Report,
2019). The Directorate is also the operational focal point for multilateral environmental agreements and
funds, such as the Global Environment Facility (GEF), Green Climate Fund (GCF) etc. It is also tasked with
conducting Sectoral Environmental Assessments, EIAs and Environmental Audits (EAs).
19
See https://www.eia.nl/documenten/00000440.pdf

12
49. In November 2020, an environmental impact assessment bill was approved by the Somali cabinet
and sent to the parliament for ratification. The Directorate is also the operational focal point for
multilateral environmental agreements and funds, such as the Global Environment Facility (GEF), Green
Climate Fund (GCF), etc. It is also tasked with conducting Sectoral Environmental Assessments, EIAs and
EAs, although at present there are no enabling legislation or regulations in place, other than the
aforementioned impact assessment bill. The Bank is offering technical assistance to the Directorate on
matters of environmental governance.
50. Jubaland and South-West State. Jubaland and South-West states have Ministries of Environment
and Tourism (MoE&T), which manage environmental related issues within the respective states. The
MoE&T has developed and passed environmental and social impact assessment (ESIA) regulations, which
are meant to govern environmental matters, including licensing of public buildings, such as schools.
51. State ministries in charge of environment and tourism are the principal institutions to be
consulted before, during and after the implementation of all interventions under the Somalia education
project, in so far as they relate to possible environmental and social risks and impact. These ministries are
mandated to supervise and co-ordinate all matters relating to the environment. They will likely want to
review and approve the safeguards documents such as ESMPs and Resettlement Plans (RPs) during minor
civil works implementation in the FMS.
52. Puntland. The Ministry of Environment, Agriculture and Climate Change (MoEACC) deals with
management of environment and natural resources in Puntland. The ministry collaborates with the
Humanitarian Affairs and Disaster Management Agency (HADMA) in the development of climate change,
early warning and drought resilience strategies. It also collaborates in the identification and mapping of
Puntland disaster prone zones.
53. The MoEACC has responsibility for climate change mitigation and adaptation strategies, and has
a five–year plan (2017-2021). Puntland’s disaster management authority, HADMA, is not directly involved
in environment-related activities, but has a key role in disaster preparedness, management and
mitigation. The municipal council of Garowe has overall responsibility for social services, including
education management, within its administrative jurisdiction.
54. The Ministry of Planning and International Cooperation (MoPIC) has a three-year development
plan (2017-2019) covering livestock, agriculture, social services and the environment. The plan was
approved in 2016 by the Puntland Cabinet and is being supported by the UNDP Somali Project Watch
Brief.
55. Benadir Regional Administration (BRA). BRA is a local government entity, established in law and
enshrined in clause 1(b) of article 48 of the Constitution of the Federal Republic of Somalia, which relates
to the structure of the state. Benadir is one of the 18 administrative divisions of Somalia established at
independence in 1960. Benadir itself is comprised of 17 administrative districts that make up the city of
Mogadishu, which is also capital of the Federal Republic. The BRA bears the dual responsibility of
managing the affairs of the region as well as the municipality of Mogadishu. Thus, its administrative head
is also the governor of the region as well as mayor of the city. Law Number 6 relates to local government
and its older version, Law 19, clearly defines the mandates to provide basic services to the city of
Mogadishu, including education services.

13
3.6 International Conventions and Agreements Signed or Ratified by Somalia

56. There are a number of international treaties, agreements and conventions that have been signed
or ratified by Somalia. These conventions and agreements are aimed at halting environmental
degradation and improving the sustainable use of natural resources, and are relevant for the Somalia
education project in various ways. Among the important international conventions related to natural
resource use and management that Somalia is a signatory to, include:
• Convention on International Trade in Endangered Species of Wild Fauna and Flora;
• Convention on the Conservation of Migratory Species of Wild Animals;
• Regional Convention for the Conservation of the Red Sea and the Gulf of Aden Environment;
• Protocol concerning Regional cooperation in Combating Pollution by Oil and other Harmful
Substances in Cases of Emergency;
• UN Convention on the Law of the Sea;
• Protocol concerning Co-operation on Combating Marine Pollution in cases of Emergency in the
Eastern African region;
• Convention for the protection, Management and Development of the Marine and Coastal
Environment of the Eastern African Region (Nairobi Convention); and
• Six ILO fundamental conventions (See the LMP for more details).
57. Somalia has 19 International Labour Organisation conventions – including three abrogated
conventions. These include the following:
i. Forced Labour Convention, 1930 (No. 29)
ii. Freedom of Association and Protection of the Right to Organise Convention, 1948
(No. 87)
iii. Right to Organise and Collective Bargaining Convention, 1949 (No. 98)
iv. Abolition of Forced Labour Convention, 1957 (No. 105)
v. Discrimination (Employment and Occupation) Convention, 1958 (No. 111)
vi. Worst Forms of Child Labour Convention, 1999 (No. 182)
vii. Medical Examination of Young Persons (Sea) Convention, 1921 (No. 16)
viii. Workmen's Compensation (Accidents) Convention, 1925 (No. 17)
ix. Equality of Treatment (Accident Compensation) Convention, 1925 (No. 19)
x. Seamen's Articles of Agreement Convention, 1926 (No. 22)
xi. Repatriation of Seamen Convention, 1926 (No. 23)
xii. Underground Work (Women) Convention, 1935 (No. 45)
xiii. Right of Association (Non-Metropolitan Territories) Convention, 1947 (No. 84)
xiv. Labour Inspectorates (Non-Metropolitan Territories) Convention, 1947 (No. 85)
xv. Labour Clauses (Public Contracts) Convention, 1949 (No. 94)
xvi. Protection of Wages Convention, 1949 (No. 95)
xvii. Recruiting of Indigenous Workers Convention, 1936 (No. 50)20
xviii. Contracts of Employment (Indigenous Workers) Convention, 1939 (No. 64)21
xix. Penal Sanctions (Indigenous Workers) Convention, 1939 (No. 65)22
20
Abrogated Convention - By decision of the International Labour Conference at its 107th Session (2018)
21
22

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3.7 World Bank ESS

58. Relevant ESSs. The World Bank’s ESSs seek to avoid, minimize or mitigate the adverse effects of
development projects it is financing through the Investment Project Financing (IPF) modality. The
compliance with these Standards is required among others, to assure that the project is eligible for World
Bank support. Due to the limitation of applicable national and FMS environmental and social laws and
regulations, the project will apply the World Bank ESF and the attendant standards. Eight ESSs will be
relevant to the project activities are:
• ESS 1: “Assessment and Management of Environmental and Social Risks and Impacts”
• ESS 2: “Labour and Working Conditions”
• ESS 3: “Resource Efficiency and Pollution Prevention and Management”
• ESS 4: “Community Health and Safety”
• ESS 5: “Land Acquisition, Restrictions on Land Use and Involuntary Resettlement”
• ESS 6: “Biodiversity and Sustainable Management of Living Natural Resources”
• ESS 8: “Cultural Heritage”
• ESS 10: “Stakeholder Engagement and Information Disclosure”
59. More details on the ESSs and how they apply to the Somalia education project are enumerated in
Table 2.

15
Table 2: Summary of applicable World Bank E&S Standards (ESSs)23

Standard Relevant? Explanation on application
ESS 1 Assessment and Yes This Standard sets out the MOECHE’s responsibilities for assessing, managing and monitoring environmental and
Management of social risks and impacts associated with each stage of Somalia education project in order to achieve environmental
Environmental and Social and social outcomes consistent with the ESSs.
Risks and Impacts As a result, this ESMF has been prepared, in conjunction with other, appropriate safeguards documentation,
including:
• Resettlement Planning Framework (RPF)
• Labour Management Procedures (LMP)
• Stakeholder Engagement Framework (SEF), which includes an Inclusion Plan and a Grievance Redress
Mechanism (GRM)
• GBV Action Plan
• Security Management Plan
The project will be expected to conduct Environmental Social Impact Assessments (ESIAs) and develop ESMPs for
subprojects as determined necessary (see Annexes 3 & 4 on ESIAs and ESMPS, respectively)
ESS2 Labour and Working Yes While the exact labour use (including the number of project workers, their characteristics and timing of workforce
Conditions mobilization) is to be determined during the implementation of each subproject, the project workers engaged or
employed will include:
• Direct workers (such as consultants hired in the PIU, PMUs, MoECHE, and supervision consultants if required)
• Contracted workers (such as skilled permanent staff of the primary contractor (construction company), skilled
workers engaged by sub-contractors (such as heavy machine operators), and unskilled community members
engaged by the contractor (such as host community members and IDPs including female workers), as well as
staff of third-party monitors working with the project
• Primary supply workers (such as workers to produce essential school construction materials such as aggregates
and building blocks on an ongoing basis for the project)
• Community workers:24 these may include members social accountability committees who will promote
transparency and accountability for the project at community level. And will be clarified in the labour
management procedures.
• Government civil servants such as Federal and State education officers in the ministries and departments, and
district police officers. The civil servants will remain subject to the terms and conditions of their existing public
sector employment, but comply with OHS requirements including security and GBV/SEAH prevention
Potential labour risks and mitigation measures
23
More details at http://www.worldbank.org/en/projects-operations/environmental-and-social-framework/brief/environmental-and-social-framework-
resources
24
There will be a need to confirm if the members of these committees will be voluntary or will be considered project workers.

16
• OHS risks (such as moving equipment and heavy machines, noise, vibration, welding, chemical hazard, working
environment temperature, working at height and safety and hygiene in worker camps)
• Child labour
• Forced labour
• Labour influx
• Labour disputes over terms and conditions of employment
• Discrimination and exclusion of disadvantaged groups (including in payment terms)
• Security risks (workers’ exposure to attacks and children’s security while at school)
• GBV/SEAH
The Labour Management Procedures (LMP) developed for the project, will contain relevant mitigation measures to
be incorporated into procurement documents
ESS3 Resource Efficiency Yes • Because of the nature and relatively moderate scale of the civil works, the risks and impacts related to
and Pollution Prevention resource efficiency and pollution will be minor, temporary, and confined to the area immediately surrounding
and Management the construction.
• The risks related to ESS3 include the normal impacts of civil works (i.e. dust, noise, erosion, surface water
sedimentation, pollution from construction wastes and water use), as well as waste from worker campsites,
unfilled quarries and burrow pits.
• To address these short-term impacts, this ESMF includes standard operating procedures (SOPs)and good
construction management practices, including those proposed in WB Environmental and Health Safety
Guidelines (EHSGs).
ESS4 Community Health and Yes • Community health and safety impacts will be minor, temporary, and confined to the area immediately
Safety surrounding the construction or rehabilitation of schools and classrooms and associated buildings such as
ablution facilities and staffrooms.
• Anticipated risks and impacts include community health and safety risks associated with
construction/rehabilitation work, such as traffic safety, community exposure to diseases (including COVID-19),
hazardous materials and emergency preparedness.
• Open quarries due to sourcing of materials for construction
• To address these short-term impacts, the ESMF includes SOPs and good construction management practices,
including those proposed in WB EHSGs.
• To address potential risks associated with the security personnel to be hired by contractors, the project will
develop and implement a Security Management Plan.
• Assessment of project related GBV/SEAH/SEA will be conducted during project preparation.
• Given the assessment of GBV/SEAH risks for Somalia generally, and considering context of pervasive insecurity,
the project will adopt a robust approach to address potential GBV/SEAH/SEA risks.
• Relevant mitigation measures to address these risks include integrating Codes of Conduct (CoCs) with
GBV/SEAH-related protections, community consultations and mapping activities to identify potential service

17
providers, and establishment of GRM with procedures and channels to enable safe, confidential and ethical
reporting of GBV/SEAH incidents) are articulated in this ESMF.
• Additional considerations include the development of a GBV Action Plan and elaboration of provisions for Third
Party Monitoring.
• The project will also look to include provisions of capacity building and training of relevant stakeholders
including contractors, primary suppliers, third party monitors and project workers, in addition to capacity
building for the MoECHE.
• GBV/SEAH/SEA risks will be monitored throughout project implementation through regular re-assessment with
risk screening tool, particularly as new schools and sub-project locations are determined, and through regular
monitoring engagement.
• Contractors and primary suppliers will be debarred for 2 years if they fail to comply with GBV/SEAH
obligations.
ESS5 Land Acquisition, Yes • The resettlement impacts of each sub-project are likely to be moderate due to the limited size and nature of
Restrictions on Land Use the individual physical works. It is notable that schools will be constructed in public land or land donated by the
and Involuntary community after an ascertainment that it is not contested and agreed to by representative of residents and
Resettlement users of the land and appropriate government departments
• The physical displacement will be minimized and duly compensated.
• The economic displacement will largely relate to encroachment on private or community lands or temporary
impact during the construction, which will be also minimized. More details are presented in the RPF.
ESS6 Biodiversity Yes • While a few locations in a few municipalities may contain some land with inherent environmental sensitivity
Conservation and relevant to ESS6, the subproject screening process in the ESMF will exclude such sensitive areas.
Sustainable Management of • The ESMF includes specific measures to avoid or minimize negative impact on critical or protected areas if the
Living Natural Resources sub-project screening process does not otherwise exclude these areas.
ESS7 Indigenous No ESS7 is not relevant to the project, as the people in the project area are not considered as Indigenous Peoples as
Peoples/Sub-Saharan defined under ESS7.
African Historically
Underserved Traditional
Local Communities
ESS8 Cultural Heritage Yes • There is the potential for chance find of cultural or archaeological significance during construction or
rehabilitation of schools and associated infrastructure, and the existence of some historic buildings in the
school neighbourhood that could potentially be impacted from the construction.
• The ESMF has been updated to comply with ESS8, and the subproject-specific ESMPs will address these issues
through the inclusion of chance find procedures.
• More details are available in Annex 5 of this ESMF.
ESS9 Financial No Not relevant to this project
Intermediaries

18
ESS10 Stakeholder Yes • Key stakeholders include beneficiaries, parents, teachers and school committees, including CECs, SAC, other
Engagement and project-affected communities, host communities, federal, state and municipal authorities responsible for
Information Disclosure education, religious and local leaders, civil society organizations (CSOs), and other development partners.
• As discussed in ESS1, the potential disadvantaged groups to be considered for stakeholder engagement include:
o IDPs, refugees and returnees;
o Poor households (such as female headed, widows, older persons, orphans, persons living with severe
illness);
o Persons with disabilities;
o Illiterate community members;
o Nomadic pastoralists; and
o Minority groups
• The project will take differentiated measures to include these groups into stakeholder engagement activities,
such as through focus group/individual meetings, mediation by community support groups, accessible
consultation venues, discrimination of written materials or graphics or provision of free municipal transport.
• More details on the consultation, information disclosure, inclusion plan and the GRM are presented in the SEP.

19
60. The project will comply with the ESSs, where potential risks and impacts are anticipated. Where
possible, the project will put premium on implementing alternative measures to avoid, minimize, mitigate,
manage or compensate adverse environmental impacts. Avoidance measures will be prioritized over
mitigatory or compensatory measures consistent with the mitigation hierarchy. Additionally, the project
will enhance positive impacts in project selection, location, planning, design, implementation and
management.
3.8 World Bank Group EHS Guidelines

61. WBG has guidelines for Environment, Health and Safety (EHS) that serve as useful references for
general issues as well as sector-specific activities. Projects financed by the WBG are expected to comply
with these guidelines as required by the policies and the standards. The EHSGs are mainly on OHS,
community health and safety as well as on construction and decommissioning. It contains guidelines
cross-cutting on environmental (waste management, ambient air quality, noise and water pollution), OHS
issues among others, applicable to all the industry sectors.
62. The applicability of the EHS Guidelines should be tailored to the hazards and risks established for
each project on the basis of the results of an environmental assessment, which should be carried out as
part of the ESMPs before civil works. The EHS Guidelines are available at the World Bank’s website.25
3.9 Gap Analysis

63. The activities in the Somalia education project need to comply with both existing Somali laws and
regulations and World Bank ESSs. This sub-section compares the national public sector environmental and
social management rules, regulations and standards to World Bank’s Standards. The main objective of this
assessment is to help implement this ESMF more effectively at the Federal and State levels in Somalia
through an understanding of existing gaps.
64. Table 3 summarizes a comparison focusing on the World Bank policies relevant to the project and
gaps identified in existing Somali laws and regulations.
25
See http://documents1.worldbank.org/curated/en/157871484635724258/pdf/112110-WP-Final-General-EHS-
Guidelines.pdf

20
Table 3: GAP analysis for Environmental and Social Standards – August 2020
Scope Bank Standard Government of Somalia policies, Gaps identified Gap-filling measures
regulations
ESS1 (“Assessment and Management of Environmental and Social Risks and Impacts”)
EIA instruments Range of instruments to satisfy Instruments for environmental EIAs not incorporated into Federal ESMF to guide the
the Bank include EIAs, regional assessment have not been delineated laws, and are weakly captured at borrower.
or sectoral EAs, EMPs, etc. adequately at the FGS level, and are State level in only Puntland (and
absent in the FMS. Somaliland)
Missing in all the other FMS.
Environmental Screening procedures There are no clear procedures for Screening procedures are absent in ESMF to guide the
impact screening developed for projects involving screening under the statutes of Somalia. all the FMS save for Puntland and to borrower.
sub-projects, as is likely to be some extent Somaliland.
the case in the Somalia
education project.
Social impact Screening procedures There are no clear procedures for Screening procedures are absent in ESMF to guide the
screening developed for projects involving screening under the statutes of Somalia. all the FMS. borrower.
sub-projects, as is likely to be
the case in the Somalia
education project.
Public The Bank requires the Borrower Procedures for public consultations not Procedures for public consultations The project SEP to
consultations to initiate consultations with explicitly stated. not explicitly stated. guide the borrower.
project-affected persons and
other interested parties
including CSOs.
Monitoring of Bank requires regular There are no procedures provided in There are no procedures provided in ESMF to guide the
environmental and monitoring of environmental regulations in the country on the conduct regulations in the country on the borrower.
social data and social safeguards data to of monitoring activities in the collection conduct of monitoring activities in
evaluate the success of of environmental and social data. the collection of environmental and
mitigation and to foster social data.
corrective measures at the
earliest possible juncture.

21
Institutional Requirement by the Bank for • MoECHE as the project implementing • MoECHE has capacity for Respective PMUs to
arrangements specific description of partner. technical implementation of work with the
institutional arrangement and • Directorate of the Environment and project interventions but will respective ministries
implementation schedule for Climate Change in the Office of the require Safeguards support. and agencies
monitoring and mitigation Prime Minister, to be responsible for • Directorate of the Environment responsible for
measures. oversight of environmental matters. in the Office of the Prime management of
Minister may be responsible for environmental and
coordinating institutional social matters for
responses under this ESMF, but development projects
the institutional information is as the focal points for
not available and its remit is administration of this
unknown, as is the technical ESMF.
capacities.
ESS2 (“Labour and Working Conditions”)
Management of The Bank puts emphasis on the Labour Code of Somalia (Law Number 65, The Labour Code is broadly ESMF and the Labour
different types of identification and adopted in 1972) is the specific labour law consistent with the ESS2, while there Management
project workers characterization of different governing all aspects of labour and is a significant gap in the Procedures (LMP) to
types of workers (project working conditions, which covers the enforcement aspect of the guide the borrower.
workers, direct workers, contract of employment, terms and legislation. More details are
contracted workers, community condition, remuneration, and OHS, trade presented in the LMP.
workers, primary supply unions and labour authorities. The
workers) to manage different provisions of the Labour Code apply to all
types of labour risks. employers and employees in all project
municipalities. The Labour Code is
applicable to all project workers of the
Somalia education project.
Labour standards Several provisions made under • Article 24(5) stipulates that all The new labour code, amending the The Project will not
ESS2 to safeguard the workers, workers, particularly women, have a code from 1972, has not been passed allow any forced and
promote safety at work and special right of protection from yet. child labour. It will hold
ensure that they have a viable sexual abuse, segregation and all contractors liable to
means of communicating discrimination in the work place. The implementation of the existing the implementation of
grievances and receiving • The Puntland Sexual Offences Act articles in practice may not be very the LMP.
redress. 2016 prohibits sexual harassment. strong.
• Article 14 prohibits Human The PIU will have
trafficking: A person may not be overall responsibility to
subjected to slavery, servitude, monitor the
trafficking or force labour offences.

22
• Every labour law shall comply with implementation of the

gender equality. LMP.
• Provisional Constitution of the
Federal Republic of Somalia Article The Project will fully
14 stipulates that a person may not comply with WB ESS 2.
be subjected to slavery, servitude, This is set out in the
trafficking, or forced labour for any LMP (see annex 1).
purpose.
• The Labour Code of 1972 stipulates
that all contracts of employment
must include: (a) the nature and
duration of the contract; (b) the
hours and place of work; (c) the
remuneration payable to the worker;
and (d) the procedure for suspension
or termination of contract.
Furthermore, all contracts must be
submitted to the competent labour
inspector for pre-approval.
ESS3 (“Resource Efficiency and Pollution Prevention and Management”)

Pollution This ESS requires the Borrower • There are no known national There are no supporting legislative ESMF to guide the
prevention and to undertake a health and construction standards for schools, frameworks for pollution prevention borrower on pollution
management safety risk assessment of any however the MoECHE intends to and management. prevention and
existing pollution which may apply the UNICEF Safe Schools management.
affect communities, workers Standards and commitments related
and the environment, especially to school EHS standards.
in the school environment • No known national statutes in
which will be the main arena for support of periodic environmental
project implementation. audits.
• No national pollution standards
known at the time of developing this
ESMF.
Management of The Bank requires the Borrower • No known national legislation or There are no approved hazardous ESMF to guide the
hazardous wastes to undertake specific measures policies on management of waste disposal sites in Somalia. borrower on the
to manage both hazardous and hazardous wastes. management of both
non-hazardous wastes.

23
Specific emphasis is given in this • Provisional Constitution of the hazardous and non-
ESS with respect to Federal Republic of Somalia - Article hazardous wastes.
transportation and disposal, 25 of the Constitution states that
obtain chain of custody every Somali has the right to an
documentation to the final environment that is not harmful to
destination. them, and to be protected from
Approved disposal sites are pollution and harmful materials.
required for this ESS. • Every Somali has a right to have
a share of the natural resources
of the country, whilst being
protected from excessive and
damaging exploitation of natural
resources.
• Article 45 states that the
Government shall give priority to the
protection, conservation, and
preservation of the environment
against anything that may cause
harm to natural biodiversity and the
ecosystem.
• All people have a duty to
safeguards and enhance the
environment and participate in
the development, execution,
management, conservation and
protection of the natural
resources and the environment.
ESS4 (“Community Health and Safety”)
Health of The ESS anticipates that the • The Somali Penal Code of 1962. The The Somali Penal Code of 1962 fails The LMP, SEP and the
community project will put measures in Code criminalizes rape and other to protect survivors and prosecute GBV Action Plan
members place to anticipate and avoid forms of sexual violence as well as perpetrators for GBV/SEAH/SEA developed for this
adverse impacts on the health forced prostitution. crimes. project will guide the
and safety of project-affected • Articles 398-9 provide that ‘carnal reduction of harm to
communities during the project intercourse’ and ‘acts of lust omitted The crimes under Articles 398-9 are communities affected
life-cycle from both routine and with violence’ are punishable with 5- too narrowly defined to satisfy by the project.
non-routine circumstances. 15 years and 1-5 years of international law standards of
Further, it provides for the imprisonment. Abduction for the protection from sexual and
avoidance or minimization of GBV/SEAH.

24
community exposure to project- purpose of lust or marriage is

related traffic and road safety prohibited under Art 401. Furthermore, in practice however it
risks, diseases and hazardous • Article 39(i) makes abuse of power in has been documented that women
materials. the commission of a crime an complaining about a rape may find
aggravating circumstance and Article themselves trapped by the Article
33 provides that when a superior 426 prohibition against adultery that
officer orders the commission of an makes no exception for the case of
offence both the perpetrator and his rape.
superior will be liable. In practice provisions under Art 39(i)
offer little more than theoretical
protection.
Security personnel ESS4 states that when the District police will likely provide security While the security protocols guiding The project to be
Borrower retains security services in the implementation of the the deployment and use of force are guided by the ESMF
personnel to safeguard workers Somalia education project. The civil broadly unknown, the project will and relevant provisions
and property, it will assess the servants in Somalia are governed by coordinate with the law enforcement of ESS4 on the
risks posed by these security Provisional Constitutions and Civil Service authorities in each municipality to deployment of security
arrangements to those within Law (Law Number 11). manage associated risks. personnel to
and outside the project sites. However, there are no security protocols construction sites in
guiding their deployment, and there is schools where security
The Borrower will not sanction possibility of violence meted out on risks are deemed
any use of force by direct or civilians or workers or even the possibility ‘high’.
contracted workers in providing of rent-seeking.
security except when used for The project will also
preventive and defensive develop and
purposes in proportion to the implement a Security
nature and extent of the threat. Management Plan.
ESS5 (“Land Acquisition, Restrictions on Land Use and Involuntary Resettlement”)
Physical and ESS5 covers the involuntary • Provisional Constitution of the There is a lack of detailed legislation RPF to guide the
economic taking of land, resulting in loss Federal Republic of Somalia, Article governing land use and ownership. borrower.
displacement of shelter or loss of assets: a 26 states that every person has the Evictions are reported to be
hierarchy has been provided right to own, use, enjoy, sell and commonplace in Somalia.
that seeks to minimize losses to transfer property
affected persons. It forbids • The Provisional Constitution defines There are no functional national or
forced evictions. land as public property. The state policies guiding involuntary
government has created means to resettlement of persons that may be
transfer some land into private affected by the project.
ownership by granting ownership for More details are provided in the RPF.

25
urban and agricultural land.26 Formal

legal frameworks now exist alongside
customary land management.
• The State may compulsorily acquire
property only if doing so is in the
public interest. Any person whose
property has been acquired in the
name of the public interest has the
right to just compensation from the
State as agreed by the parties or
decided by a court.
• Compensation is provided only for
occupants of temporary structures.
Affected persons are to be settled in
suitable land and their eviction and
settlement costs be paid for by the
local government.
• Provisional Constitution of Somalia
(Article 43) calls for consultation
between the Mayor and the Planning
Committee prior to the expropriation
of private land.
ESS6 (“Biodiversity Conservation and Sustainable Management of Living Natural Resources”)
Biodiversity In accordance with the • Somalia has developed National However, no draft management plan The project to be
restoration mitigation hierarchy Biodiversity Strategy and Action Plan is provided in Somalia’s NBSAP. guided by the ESMF
provided in ESS1 and with the (NBSAP), which calls for action to be and relevant provisions
requirements of taken to manage the 40+ identified of ESS6 on biodiversity
this ESS, Borrower is required biodiversity hotspots. restoration where the
to ensure that biodiversity project interfaces with
expertise is utilized to biodiversity and other
develop and implement a environmentally
Biodiversity sensitive areas
Management Plan.
ESS8 (“Cultural Heritage”)
26
IGAD, Somalia. Land Governance Country Profile, Assessment of Land Governance Framework, Training & Research Land Governance Institutions, accessed at:
https://land.igad.int/index.php/countries/39-countries/somalia/40-somalia-profile?showall=1

26
Management of This ESS requires the Borrower No information is available at hand on There are no explicit laws or ESMF to guide the
risks on tangible to manage risks on tangible and how the FGS intends to manage cultural regulations known to be delineating Borrower.
and intangible intangible cultural heritage, heritage. sites as places of cultural importance.
cultural heritage, including identification of the
including legal presence of all listed legally
protection to protected cultural heritage
cultural heritage areas affected by the project.
sites
ESS10 (“Stakeholder engagement and information disclosure”)
Meaningful The World Bank anticipates that Provisional Constitution of the Federal The law on the right of access to The Project will
engagement of the project will establish a Republic of Somalia: Article 32 stipulated information currently only exists as a implement stakeholder
stakeholders in the systematic approach to that every person has the right of access draft consultations
project activities stakeholder engagement that to information held by the State. The throughout the
from planning to will help Borrowers identify Federal Parliament shall enact a law to lifetime of the project,
implementation stakeholders and build and ensure the right of access to information. as per the SEP.
levels maintain a constructive
relationship with them, in The PIU will ensure
particular project-affected that a grievance
parties. Further, the project will mechanism for the
promote and provide means for project is in place, in
effective and inclusive accordance withESS10
engagement with project- as early as possible in
affected parties throughout the project development
project life-cycle on issues that to address concerns
could potentially affect them. from project affected
The project affected persons persons.
should be provided with
accessible and inclusive means
to raise issues and grievances,
and allow Borrowers to respond
to and manage such grievances.

27
4. PROJECT BIOPHYSICAL AND SOCIO-ECONOMIC SETTING
65. This section focuses on the existing biophysical and socio-economic environments in the proposed
states. Physio-geographically, Somalia is a country of limited contrasts, but for the purposes of the Somalia
education project, this ESMF will treat the project sub-regions as three relatively distinct continuities:
• Somaliland, Puntland and Galmudug (arid agroecology);
• Hirshabelle, Jubbaland and South-West State (semiarid agroecology); and
• Mogadishu (coastal marine agroecology).
66. Ecologically-sensitive sub-regions within the regions will be identified where possible.
4.1 Introduction
67. The proposed project will be implemented in a context of ecologically fragile environments, in
some places (such as Puntland) characterized by a high number of arid-adapted flora (including the
deciduous species of Acacia and Commiphora in addition to Euphorbia and Aloe variants forming
understory) and fauna (such as the Dorcas gazelle, Beisa oryx, gerenuk, the Somali wild ass - Equus
africanus somaliensis and the Somali warthog, Phacochoerus aethiopicus delamarei) species, many of
them endemic. Some of these species used to thrive in the country’s national parks and game reserves,
which were relatively well protected in the reign of former central government. Following the collapse of
the former regime, the parks have all but disappeared, and it was extremely difficult to gather any
information on their current state, actual boundaries, management, etc.
68. Many of the species aforementioned are categorized as Critically Endangered (CR), Endangered
(EN) or Vulnerable (VU) in international conventions and agreements, such as the World Conservation
Union’s Red List of Threatened Animals.27 Some of the endangered flora and fauna species, according to
the IUCN Red List, include Aloe eminens, Aloe hildebrandtii, Aloe grisea, Mirafra ashi, Mirafra sharpie,
Aloe ambigens, Aloe albovestita, Dirachma somalensis, Aloe scobinifolia, Aloe cremnophila, Aloe
gracilicaulis, Aloe gillettii, Aloe bella, Cleopatra rugosa, Aloe peckii, Ceratonia oreothauma subsp.
somalensis, Hildegardia gillettii, Elapsoidea chelazzii, Linaria johannis, and Vigna monantha. Somalia has
ratified the Convention on International Trade in Endangered Species of Wild Flora and Fauna (CITES), but
few if any practical measures are being taken to ensure its implementation. Like for the fisheries, the
wildlife is also subject to illegal, unreported and unregulated trapping and trafficking.
69. As a precaution, it will be critically important for the PMUs to engage with communities,
contractors, civil society and other government MDAs to ensure that the project does not affect existing
biodiversity.
4.2 Climate
70. All the proposed project states share similar characteristics, climate-wise. There is generally warm
and arid climate across most parts of Somalia, although precipitation and the wind can be highly variable
in places at certain times of the year (on account of proximity to the equator). Typically, the Somali climate
is hot and semi-arid to arid, with two annual rainy seasons Gu’ (which spans from April to June), and Deyr
(which takes place from October to November). There are variations in spatial distribution of rainfall, with
about 500 mm recorded annually in the northern highlands and between 300 and 500 mm in the southern
regions. The coastal plains register only between 50 and 150 mm.
27
See http://www.animalinfo.org/country/somalia.htm

1
71. Annual potential evapotranspiration (PET) is high, exceeding 2,000 mm in the northern basins and
can be as high as 3,000 mm in the Gulf of Aden. Over the dry period, the vegetation is sustained mainly
through the shallow aquifers found along the dry riverbeds (tog or wadis) across the country. Fertile flood
plains and continuous recharge from the Juba and Shabelle Rivers, both originating from Ethiopian
highlands, also provide sustained development growth along the riverine areas.
4.3 Ecosystems
72. Somalia’s environmental complement, especially the vegetation resources, offers contrasting
experiences, and this is due to the spatial and temporal precipitation distribution. There are four main
eco-regions in Somalia, whose distribution is determined by the spatial and temporal distribution of the
two annual rainfall seasons:
• The dominant xeric grasslands and shrub-lands (accounting for 74 percent of the country’s
landmass);
• Somali montane xeric woodlands (14 percent);
• East African mangroves (11 percent); and
• Coastal forest mosaic (11 percent).
73. Farms in the south-central region, urban centres and other settlements account for the remaining
1 percent of dry landmass.
4.4 Socio-economic Environment
4.4.1 Geography, Landmass and Population

74. Somalia, with a landmass of about 627,340 km2, has a population estimated to be 16,143,40628.
Estimates show that, out of the total population, 7,431,038 people were living in urban centres in 2020.
This accounts for a relatively highly urbanized society (standing at ~46.8 percent). The population density
is estimated at 25 persons per km2, one of the lowest in East Africa. The median age in Somalia is estimated
to be 16.7 years. The population’s livelihoods are connected to either livestock husbandry, smallholder
dryland agriculture, itinerant commerce or remittances from diaspora.
75. The United Nations Population Fund (formerly the United Nations Fund for Population Activities)
estimated that in 201429 the total population of Somalia was 12.3M which was broken down to 1,830,073
for Puntland, 508,180 for Somaliland and 6,462,580 for the rest of Somalia.
4.4.2 Poverty in Somalia

76. The United Nations classifies Somalia as a least developed country. The socio-economic situation
of the country is described as “very poor” in the National Development Plan (2017-2019)30, with
approximately 69 percent of Somalis reportedly living below the poverty line. Poverty cuts across sectors,
location, group and gender, and its forms and causes vary. An understanding of Somalia’s geography,
recent trends in its economy and consequences of civil strife is important to determining the nature and
extent of its poverty. There is more stability in the northern regions (Somaliland and Puntland), and
consequently less poverty. Poverty in Somalia is more pronounced in the IDP camps, where is it estimated
to be 88 percent, followed by rural areas with 75 percent and urban areas with 67 percent.
28
These estimates are based on information from http://www.worldometers.info/world-population/somalia-
population/
29
UNFPA Population Estimates Survey of Somalia 2014
30
See http://extwprlegs1.fao.org/docs/pdf/som169866.pdf for a copy of the Plan

2
77. Somalia’s economy is largely consumption-based and dominated by agriculture, while it is also
supported by remittances and large aid flows. Remittances and aid flows are estimated at USD 1.4 billion
a year, which represented 29 percent of Somalia’s GDP in 2018. Agriculture plays a key role by constituting
75 percent of GDP, and 93 percent of total exports. Other sectors driving growth are construction,
telecommunications and money transfer services.31 Approximately half of Somalia’s population depends
on pastoralist and agro-pastoralist activities. According to the recent Flood Impact Needs Assessment
conducted by the FGS and the World Bank, this means that people remain highly vulnerable to natural
disasters.32
4.4.3 Human Development

78. Somalia scores very low on UNDP’s HDI. Although it has not been ranked for a few years, different
indicators reveal low scores. For example, life expectancy at birth lies at 57.1 years with a global average
of 56 years33 in low human development countries34; and the mortality rate under the age of 5 is at 127
per 1000 life births35, while the global average is 3936.
4.4.4 Education
79. The school enrolment rates in Somalia are among the lowest in the world. In the education sector,
only 16 percent of the Somali population have completed primary school and only 7 percent have finished
secondary school.37 Three (3) million children between the age of 6 and 18 do not attend any school. At
the primary level, about 60 percent of children do not attend school. At the secondary level 92 percent of
children (mainly in the south central parts of the country) do not attend school. The recent flooding has
caused additional challenges on the education of children, as it has displaced people, made access more
difficult and has caused the exclusion of some.38
80. Literacy in Somalia is 40 percent among the adult population, with male literacy at 8 percentage
point higher than female. There are significant differences in the literacy rate between social groupings.
For example, urban populations have the highest literacy rate with 64 percent, while nomadic populations
have the lowest literacy rate with 12 percent. Among the FMS, Hirshabelle has the lowest literacy rate at
20 percent; South West State has 26 percent and Jubaland 29 percent.39
81. In particular in South Central Somalia, child recruitment, compulsory military training, segregation
of boys’ and girls’ classes and concerns over attacks on education institutions remain key challenges in
the provision of education for all children. Furthermore, there are inadequate water and sanitation
facilities, limited classrooms and supplies, as well as a shortage of teachers in overcrowded schools.
31
Government of the Federal Republic of Somalia and The World Bank, Somalia. 2019 Flood Impact and Needs
Assessment, February 2020, p. 18.
32
Government of the Federal Republic of Somalia and The World Bank 2020, p. 18.
33
UNDP, Human Development Reports. Somalia, accessed at: http://hdr.undp.org/en/countries/profiles/SOM
34
UNDP, Human Development Report 2019, p.38.
35
UNDP, Human Development Reports. Somalia, accessed at: http://hdr.undp.org/en/countries/profiles/SOM
36
WHO, Children. Reducing Mortality, factsheet, accessed at: https://www.who.int/news-room/fact-
sheets/detail/children-reducing-mortality
37
UNICEF and World Health Organization, Joint Monitoring Program, 2019, accessed at:
https://washdata.org/data#!/som>.
38
Government of the Federal Republic of Somalia and The World Bank, Somalia. 2019 Flood Impact and Needs
Assessment, February 2020, p. 58
39
FGS, Ministry of Education, Culture and Higher Education, Education Sector Strategic Plan 2018-2020, p.29

3
Additional enrolments of IDP children makes the situation even more dire. Absence of school feeding
programs in famine and drought prone zones disrupts school attendance as well and drops the nutrition
status of children.40 Access to education is particularly difficult for nomadic/pastoralist populations, with
only 16 percent of nomadic population age 6 and above being enrolled in school.41
4.4.5 Water and Sanitation Hygiene

82. Access to basic water supply is estimated at 83 percent in urban areas and 28 percent in rural
areas. About two-thirds (61 percent) of the population has access to basic sanitation facilities in urban
areas and 20 percent in rural areas. According to a UNICEF report, the key challenges are weak water
supply management models, high operational management costs and technical limitations. There is
further a lack of a harmonized legal and policy framework and policies in place and inconsistency with
implementation.42
83. Frequent droughts have had negative impacts on the water sector, while conflicts have weakened
the water supply and sanitation services. WASH facilities have been destroyed as a result of conflict, and
there is a lack of sufficient WASH facilities for the large number of IDPs. Furthermore, the population
pressure causes over pumping of ground water, and the wearing out of equipment.43 Even though various
aid programs have supported the development of latrines, UNICEF reports that there is little impact on
increased use of latrines or improved sanitation and hygiene more so in the rural areas. There is further a
lack of sustainability of latrines and little indication of behavioural change among the population.
Widespread displacement and recurrent emergencies contribute to this dire picture. Diseases like cholera
are therefore widespread in Somalia, with a total of 164,000 cases reported between 2006 and 2015.44
4.4.6 Agriculture, Livestock and Livelihoods

84. Only about 10 percent of Somalia’s land can be described as arable and suitable for crop
production. Somalia’s agricultural sector, which accounts for 65 percent of the GDP and employs 45
percent of the active workforce (Somalia Agriculture Report, 2018), relies on the state of health of the
country’s natural capital (vegetation and water resources). It is worth nothing that the livestock sub-sector
alone accounts for between 80 to 90 percent of agricultural GDP and contributes about US$2.4 billion (or
about 40 percent of total GDP) and more than 90 percent of export earnings (ibid), and grows 6 percent
annually.
85. According to the Somalia Agriculture Report (2018), total agricultural exports have climbed every
year since the late 2000s, to a peak in 2015 of $634 million, more than five times the value before the civil
war. The Somalia Supply and Market Outlook Assessment report by FEWSN (2017) identifies the country’s
four main staple foods as maize, sorghum, rice, and wheat. While maize and sorghum are grown locally,
rice and wheat are almost entirely imported.
86. The economy of Somalia mainly depends on livestock production, which has historically and
culturally been the mainstay of livelihood for the majority of the people. The livestock production system
in Somaliland is predominantly pastoral and agro-pastoral, with the industry providing 29.5 percent of
40
Ditto, p. 25-26
41
Ditto, p. 30
42
UNICEF Somalia Country Office, Water, Sanitation & Hygiene (WASH) Profile, February 2020, p.2, accessed at:
https://www.unicef.org/somalia/media/1251/file/Somalia-wash-profile-February-2020.pdf
43
Ditto, p. 2
44
Ditto, p. 3.

4
GDP in Somaliland and employing 27 percent and 20 percent of the female and male workforce,
respectively in Somaliland.
87. Livestock is the source of livelihood for pastoralists, contributes to the Government revenues, and
provides employment to a wide range of professionals and other service providers. Somaliland has a long
history of live animal export to the Arabian Gulf states through Berbera port on the Red Sea.
88. The movement of these pastoralists is often organized and follows a regular pattern in which clan-
based groupings have their traditional grazing areas and/or common watering points and temporary
camps. In some parts of the country, pastoralists co-habit with farmers to access crop residues for their
animals. In other places, the pastoralists take advantage of heavy rains and floods for agricultural
purposes, planting crops in areas cleared for the production of forage or grain.
89. Somalia is prone to flooding. Most of the flooding in 2019 occurred in Middle and Lower Juba,
Bay, Lower and Middle Shabelle, and Hiraan. Weeks of flooding have destroyed physical, productive, and
social service delivery infrastructure. Physical infrastructure, such as roads were turned into rivers, and
agricultural land was fully destroyed, and livestock lost.
90. According to FAO, since 2016, Somalia has faced climate shocks for eight agricultural seasons.
About 2.1 million people currently live in severe acute food insecurity; and 1 million children are acutely
malnourished.45
4.4.7 Labour and Employment

91. In the labour sector, 47 percent of the population in South Central Somalia is unemployed. The
rate is even higher among the youth at 54 percent.46The main employment is in the agricultural sector,
where 72 percent of employees worked in 2019; followed by 6 percent in the industrial sector, and 21
percent in the service industry.47 In addition, as ILO points out, the legal and judicial systems governing
employment are still weak; and there are few private or public insurance institutions; in addition, there
are no labour inspection systems. This indicates that workers can be exposed to hazardous work without
adequate protection, and child labour is a common practice in Somalia.48
92. In view of child labour and trafficking, in Somali culture, girls and boys are expected to take part
in household chores from around the age of five years, especially in rural areas. The distribution of such
tasks is highly gendered and the burden skewed towards girls. Boys are usually responsible for maintaining
income-earning and food-producing animals such as cattle and goats, while girls attend more to cooking,
cleaning and resource gathering responsibilities. In situations of extreme poverty, girls may work in
domestic roles or engage in survival sex. Poverty-driven child labour is not generally considered to be a
violation of children’s rights and children are forcibly recruited within Somalia and used as labour in
agriculture, livestock herding, construction, sexual servitude, domestic service and sexual exploitation.
45
UNFAO, Somalia Humanitarian Response Plan 2020, accessed at: http://www.fao.org/3/ca7825en/CA7825EN.pdf
46
Federal Republic of Somalia, Ministry of Education, Culture and Higher Education, Education Sector Strategic Plan
2018-2020, p.13
47
Statista, Somalia: Distribution of Employment in by economic sector from 2009 – 2019, accessed at:
https://www.statista.com/statistics/863133/employment-by-economic-sector-in-somalia/
48
ILO, Decent Work Programme, Somalia 2011-2015, p. 12.

5
4.4.8 Land Issues

93. Land conflicts in Somalia have risen to be one of the key factors of instability at the community
and inter-community level. This is partly due to a complex situation of land tenure. While the Agricultural
Land Law of 1975 abolished private ownership, the current situation is very unclear. Only few local people
registered their land at the time, and the civil war further impacted the situation negatively. Customary
land tenure has therefore taken the centre stage in ordering land ownership and usage. It is focused on
clan relations and on pastoral land use rather than norms of individual ownership. The Provisional
Constitution defines land as public property. The government has created means to transfer some land
into private ownership by granting ownership for urban and agricultural land.49 Formal legal frameworks
now exist alongside customary land management.
94. Land disputes and grievances have been identified in the existing literature as a major issue of
contestation. A study on land in Mogadishu by the Rift Valley Institute (RVI) even estimated that 80
percent of cases filed at the Supreme Court were connected to land grievances.50 Furthermore, ongoing
forced evictions are a key challenge for IDPs in Somalia. Due to insecure land tenure arrangements in IDP
settlements, it is often difficult for IDPs to secure their rights. According to ReDSS, an annual average of
155,000 individuals have been evicted across Somalia, mainly in Mogadishu and Baidoa. Evictions take
place from both public and private infrastructure. Key protection challenges are that IDPs settle on public
land or private plots with contested ownership. Women and girls are thereby most vulnerable, as they
encounter GBV/SEAH challenges in addition to loss of assets and livelihoods.51
4.4.9 Cultural Heritage

95. Somalia has rich cultural heritage due to its own cultural goods ‘dhaqan’, including the
fundaments of a segmented society and the resulting social fabric. Traditions often originate in the proto-
Somali cultural era or originate in the many interactions Somali populations have had with other cultures,
including those from the Arabian peninsula, India and sub-Saharan Africa. The protracted conflicts and
the civil war in Somalia, however, have had significant impacts on the loss of tangible and intangible
cultural heritage. Deliberate efforts have to be made to protect cultural heritage. Unfortunately, the
country’s legislation around these issues has not yet been developed and does not legally enforce the
protection and preservation of cultural artefacts, cultural heritage and distinct sub-national identities.
Infrastructure development projects should, therefore, support the protection of places of cultural and
religious significance, including graveyards, religious buildings, and historical sites.
4.4.10 Security and Conflict Environment

96. Somalia ranked second on the Fragile State Index of 2019 with a total score of 112.3, only topped
by Yemen with a score of 113.5.52 Somalia’s indicators on factionalized elites, and demographic pressures
score the highest.
49
IGAD, Somalia. Land Governance Country Profile, Assessment of Land Governance Framework, Training & Research
Land Governance Institutions, accessed at: https://land.igad.int/index.php/countries/39-countries/somalia/40-
somalia-profile?showall=1
50
RVI 2017, p. 67
51
ReDSS, Forced Evictions as an obstacle for durable solutions in Somalia, March 2018, accessed at:
http://regionaldss.org/wp-content/uploads/2018/03/Forced-evictions-as-an-obstacle-to-durable-solutions-
210318.pdf
52
Fragile State Index 2019, accessed at: https://fragilestatesindex.org/data/

6
97. Somalia has had a long history of civil war, which followed the Siad Barre regime that ended in
1991. Clan-based militias turned the country into chaos and prevented an effective central government
for a long time. A Transitional Federal Republic was formed in the early 2004 and lasted until the 2012
when the country adopted the provisional federal constitution, and a Federal Republic was established
with Hassan Sheik as the president. The FGS came into power following more than two decades of civil
war and transitional governance arrangements. With the new President, the federal state building process
commenced53 under the framework of the distinct peacebuilding and state building goals of the New
Deal/Compact, which was signed in September 2013. However, the last years have been dominated by
political infights and clan-related tensions, including in the establishment of the FMS. This has worsened
the security situation in the country.
98. There is significant conflict at different levels in Somalia. Some insecurity stems from clan
competition, which goes back into historical movements and power distribution. Often it is combined with
localized competition over resources, for example over land or water sources. Such insecurity and conflict
can be due to continued local tension between different communities, competition over sources of power,
such as governmental positions, as well as competition over aid resources brought down to the state or
district level.
99. The social impacts and potential aggravation of resource-related conflicts is well documented in
a range of pastoralist and agro-pastoralist assessments carried out in the Somali region.54 Access to water
and pasture is a fundamental source of both conflict and co-operation between clans and civil authorities
throughout the Somali region. In terms of conflict, extensive trans-boundary movements of livestock and
limited access to the combination of water and pasture is one of the primary drivers of conflict across the
Horn of Africa and within Somalia. Following decades of low investment in Somalia, water points with
adequate surrounding pasture are especially scarce, claimed by clans, fiercely guarded and intrinsically
linked to resource conflict.
100. The Islamist group Al-Shabaab still controls areas in South Central Somalia, providing harsh
treatment, forced recruitment vis-à-vis the local populations. It infiltrates other areas and conducts deadly
attacks on citizens. Most importantly, Al-Shabaab has introduced a harsh tax system in its areas of control
and beyond. It has also started to expand on other administrative functions, such as the provision of
justice.55 Given the weakness of the formal justice system in the country, people have been turning to Al-
Shabaab courts, where swift justice and the execution of judgments is guaranteed. Al-Shabaab remains a
key source of violence, attacking government facilities, personnel, security forces, and members of
international organizations. In 2019, Somali-led offensives in Lower Shabelle led to the ousting of Al-
Shabaab in the area. However, Al-Shabaab has shifted to different areas and has maintained attacks on
the newly recovered area.56
101. It is notable that different armed groups maintain checkpoints along key entry points of the
country to extract fees from travellers. People are thereby associated with their clans, and have difficulties
53
Under the FRS, the state level governments are Puntland State of Somalia, Jubaland State of Somalia, and two
interim administrations, i.e. Galmudug State and the Interim South West Administration. Somaliland is a self-
declared state. State formation is currently ongoing in the Hiraan and Middle Shabelle regions. The formation is
complete and all the interim administrations are now functioning Federal Member States.
54
Lewis 1961; Lewis 1998; DfID 2005; Gomes 2006 Access to water for pastoral resources management
55
Security Council, S/2019/858, p.3
56
Security Council, S/2019/884, p. 3/17

7
moving and working in areas in which their clans are not prominent. Even government checkpoints can
be little efficient, as they are subject to corruption.57
102. Somalia therefore remains trapped in continued fragility, which is protracted by insecurity,
endemic corruption, fledgling government capacity, predatory armed groups and spoiler networks. This
poses significant security risks for the population, but also for the planned project activities. These include
terrorist attacks, hijackings, abductions, and killings. The state security apparatus is however very weak,
and is underpinned by clan dimensions as well. There are sometimes blurred lines between the state
security apparatus, local militia or other armed factions.
4.5 Vulnerability and Social Exclusion

103. Internal Displacement: In April 2020, OCHA reported that there were 2.6 million IDPs in Somalia58
due to disaster and conflict, among other shocks. Conflict and violence triggered 578,000 new
displacements and disasters 547,000.59 During the drought in 2017, people dependent on livestock and
agriculture had to abandon their rural homes to find new opportunities, migrating predominantly to urban
areas. Drought conditions are contributing to already pronounced rates of acute and protracted
displacement. More than 278,000 people were displaced in March 2020 alone within Somalia due to the
drought, bringing the total number to approximately 585,630 since December 201660.
104. Camps are heavily congested and have also proportionally received the largest number of new
arrivals61. Displaced women and girls are among the most disadvantaged populations and face multiple
constraints including lack of access to adequate shelter, livelihoods and access to critical resources,
including land. The attendant separation of many women and girls from community and familial support
structures, as well as from traditional livelihoods activities, also contributes to an increased reliance
particularly of women on marginal, inconsistent and hazardous livelihood strategies, which often increase
exposure to violence.
105. IDPs commonly settle in informal urban settlements, where access to services and conditions is
poor, and where they often become victims of forced eviction, sexual harassment, exploitation and forced
labour. Conditions of displacement often compound existing conditions of vulnerability and poverty. They
are therefore part of the poorest strata in Somalia, and are often in dire need of access to food, water,
sanitation, health services, shelter and education.62 Generally, the socio-economic and human
development indicators for IDPs are worse than those of non-IDPs. While 7 in 10 Somalis are poor, over
three in four IDPs live under 1.90 $ per day.63
57
J. Sanya and I. Mwenda, Mogadishu. When Checkpoints don’t work, Horn International Institute for Strategic
Studies, accessed at: https://horninstitute.org/mogadishu-when-checkpoints-dont-work/
58
OCHA, Somalia Situation Report, 5 April 2020.
59
Internal Displacement Monitoring Center, The Ripple Effect. Economic Impacts of Internal Displacement. Case
Studies in Eswatini, Ethiopia, Kenya and Somalia, Thematic Series, January 2020, p. 30.
60
UNHCR, UN Habitat, IOM, JIRA and Local Ministries of Interior, IOM and The World Bank, 2017
61
JRIA 2016
62
Internal Displacement Monitoring Center 2020, p. 30.
63
The World Bank, Somali Poverty and Vulnerability Assessment, Findings from the Wave 2 of the Somali High
Frequency Survey, April 2019, p.73

8
106. Minority groups (ethnic minorities such as Bantu, Bajuni, Benadiri,64 RerXamar, Bravanese; or
occupational groups such as Midgan/Gaboye, Tumal, Yibir, Galgala) that are estimated to represent up to
one third of the population in Somalia, continue to be excluded from political participation, have limited
access to justice, are denied multiple rights and are disproportionately affected by natural hazards and
conflicts. Women from minorities and/or among IDPs are particularly affected by multiple violations of
their rights, both as women and as members of a minority group. The marginalization and social
segregation of disadvantaged groups is one of the key driving forces of the protracted massive
displacement of people and the difficulty to find durable solutions for them. Minorities in Somalia can be
considered to be those who fall outside the four main clans. There are three main groups of minorities
occupational groups, coastal communities and bantu groups:
i. Occupational groups – these communities, including Gabooye, Tumal and Yibir - traditionally
fulfilled a particular function that was considered taboo by the main Somali clans. This
included leatherworking, pottery, metalworking, hunting and some traditional health
practices (including carrying out FGM). These communities are found all over Somalia. They
experience extreme daily social discrimination. Inter-marriage between young people from
these communities and those from the four main clans is socially unacceptable – with at times
tragic consequences when reprisal actions are taken when occasionally such marriages have
taken place in spite of social disapproval and threats.
ii. Coastal communities – these communities including Ashraf, Benadiri, Bajuni, Bravanese–
often resulted from in migrants from the Arabian Peninsula (but also Italians), who settled
and inter-married with Somalis. Once living relatively privileged lives, often in larger coastal
urban centres, many of these communities were displaced by conflict (both internally and
internationally) and their communities were decimated.
iii. Bantu groups – more often found in South Central, these communities may have originally
migrated north from the Bantu lands of Central and Eastern Africa. These communities were
more likely to earn a living by growing crops – often in the fertile riverine areas of South
Central, they coexisted with the major Somali clans who lived more by pastoralism with
systems of patronage keeping the Bantu groups in a servile and sometime unpaid labourer
positions.
107. These groups are often discriminated against and/or excluded against in services and jobs and
typically do not participate effectively in government or other institutions, and therefore have their voices
less represented.
4.6 Gender
108. UNDP Somalia reports that the country has one of the highest gender inequalities in the world, at
0.776, which ranks fourth in the world. The country has an extremely high maternal mortality, rape,
FGM/C and child marriage rates, while violence and GBV/SEAH/SEA against women and girls is common.
The participation and roles of women in politics and decision-making is minimal, which perpetuates
limited female roles and inequality. While in Somaliland and Puntland women’s rights are ostensibly
protected in their respective constitutions, the implementation of these provisions is lagging behind.
109. Women make up 57 percent of the workforce in agriculture and pastoralism (both of which
constitute nearly 70 percent of the local economy). The number of women working in government
departments and agencies in Somalia is estimated at just 19 percent of the workforce. The situation is
64
This term is mostly used as a composite name for Rer Xamar and other minority groups residing in Mogadishu. It
is sometimes used interchangeably with Rer Xamar to mean the same thing.

9
also dire in the education sector, where only 36 percent of pupils in the upper primary education are girls.
Gender disparity is higher in upper grades due to economic constraints and early marriage.
110. Available economic opportunities, however, are still quite limited for both men and women and
female-headed households remain among the most disadvantaged populations. Unemployment rates
remain particularly high for women, and especially female IDPs who often remain reliant on charity
through social protection mechanisms and contributions from the diaspora in the form of remittances.
Women who are engaged in income generating activities are often engaged in the informal sector and
further bear the double domestic burden of earning an income and taking care of the home. The
consequences of this burden often fall to girls in the family, who are expected to contribute to the
maintenance of the home, often at the expense of the girls’ education and skills development65.
111. While there is lack of statistical data on the situation of women in Somalia, the available evidence
shows that Somali women are still far from enjoying equal rights and treatment. The Social Institutions &
Gender Index for 2014 places Somalia on the 6th lowest position in the world, with ‘very high’
discriminatory family codes, ‘very high’ levels of restricted physical integrity, and a ‘very high’ level of
restricted resources and assets.66 The continuation of practices, such as polygyny, early and forced
marriages, FGM, and wife inheritance, continues to undermine development towards increased gender
equality. Lack of access to services, such as education and health, or lack of access to agricultural
production or other livelihoods and employment opportunities has kept most of the female population of
Somalia disempowered.
112. Insecurity for women is still the number one issue that prevents gender equality and women’s
empowerment from being a feasible objective. Somalia has ranked prominently as one of ‘the worst
countries to be a woman’67 and one of the ‘worst countries to be a mother’68. Women continue to suffer
disproportionally from clan-fights and extremist interventions. Formal security forces have proven to be
weak in their willingness to protect women, and the justice system has failed survivors of conflict-related
GBV/SEAH69, as well as the many survivors of domestic violence and FGM. Protracted conflict and fragility
have increased fundamentalist religious interpretations, including the acceptance of pharaonic-type
FGM/C by the younger generation.70
113. The ongoing fragility, conflict and natural disaster like floods are responsible for an increasing
number of IDPs within Somalia, including a high proportion of women. They are often subject to poor
security arrangements, which leave women and girls particularly vulnerable. In this context, as well as
outside IDP camps, GBV/SEAH (particularly rape) is widespread, including as a tool between social units
in conflict.71 The UN has consistently reported that between 75-85% of GBV/SEAH incidents collected
65
Interagency Working Group on Disaster Preparedness for East and Central Africa.
66
OECD Development Center, Social Institutions and Gender Index, 2014, accessed at:
http://genderindex.org/ranking?order=field_sigi_value14_value&sort=asc
67
See: http://www.theguardian.com/world/interactive/2011/jun/15/gender-afghanistan
68
Save the Children, ‘The Urban Disadvantage. State of the World’s Mothers 2015’, Fairfield 2015, p.9.
69
Implementation of the Beijing Platform for Action. Beijing +20 Review. Somalia Country Report 2014, p. 14
70
See, for example, NAFIS Network/MOLSA, Assessment of the Prevalence, Perception and Attitude of Female
Genital Mutilation in Somaliland, 2014.
71
See, for example, UNICEF ‘Sexual Violence as a Weapon of War, accessed at:
http://www.unicef.org/sowc96pk/sexviol.htm

10
through the Gender-Based Violence Information Management System (GBV/SEAHIMS) are perpetrated
against IDPs.72
114. Available information indicates that SGBV/SEAH in the country is very high. In particular, sexual
violence against women has been used as a tool of war, including leheyste-galmo, a form of sexual
hostage-taking as well as child marriage, FGM/C (98% of female population in Somalia), rape and intimate
domestic violence (IPV) which already existed but were normalized after conflict.73
115. Rape is increasing in prevalence, becoming more violent and taking on a more normalized form.
There are reports of an increase of gang rape and “date rape” as a youth phenomenon driven by
frustrations associated with lack of opportunity and access to marriage.74 Rape case reports indicate that
it primarily affects younger women between the ages of 11–25 years as well as children, both girls and
boys. In South-Central Somalia and IDP areas, perpetrators are often ‘uniformed’.75
116. The UNHCR Protection Return Monitoring Network (PRMN) estimates that floods have displaced
20,308 people in Middle Shabelle; 7,643 in Bay; 3,227 in Middle Juba; 2,923 in Banadir; and, 678 in Bakool
region. An initial assessment conducted by UNFPA and its implementing partners in the affected regions
identified damages and access challenges to the health facilities and GBV/SEAH one-stop centers which
support vulnerable women and girls including pregnant women and survivors of GBV/SEAH. Hence, the
need for SRH and GBV/SEAH services to the affected populations. At least 20,340 women and girls are
estimated to be at risk of GBV/SEAH as the displacement weakens traditional family and community
protection mechanisms. Recurrent floods, drought, protracted conflict and armed attacks in Somalia have
resulted in insecurity, major protection challenges, food insecurity and also extremely weakened basic
socio-economic services.76
117. There are significant barriers with access to justice. Fear of reprisals or punishment deters
survivors of GBV/SEAH from reporting incidents. Survivors are often reluctant to pursue cases against the
perpetrator due to the social stigma associated with rape and other forms of GBV/SEAH. In south and
central Somalia, survivors, lawyers, witnesses, journalists, and family members have been threatened,
harassed, and arrested for reporting GBV/SEAH offences. Legal aid providers regularly receive death
threats towards their staff. Fear of reprisals to staff, survivors, witnesses, and medical personnel is a
particular problem if perpetrators are from the security forces.
118. Most domestic and sexual violence cases are dealt with through the customary and Sharia legal
systems. Anecdotal evidence indicates that some customary practices result in double victimization of
72
Somalia Humanitarian Country Team, 2019, Humanitarian Needs Overview, accessed at:
https://reliefweb.int/sites/reliefweb.int/files/resources/Somalia_2019_HNO.PDF; UNFPA, September 2016,
Somalia Gender Based Violence Sub-Cluster Bulletin, accessible at
https://somalia.unfpa.org/en/publications/somalia-gender-based-violence-sub-cluster-bulletin; UNFPA, December
2016, Somalia: Gender Based Violence Sub-cluster Bulletin, accessed at
https://somalia.unfpa.org/sites/default/files/pub-pdf/Dec_GBV/SEAH%20Bulletin%20%283%29.pdf; UNFPA,
August 2015, Somalia: Gender Based Violence Sub-cluster Bulletin, accessible at
https://reliefweb.int/report/somalia/somalia-GBV/SEAH-sub-cluster-bulletin-1-january-august-2015
73
Expanding Access to Justice Program, Gender Assessment, 2019.
74
Ditto.
75
For example, security and law enforcement officials, AMISOM, gang-members and/or freelance militia
76
UNFPA Flood Response Situation Report, November 2019.

11
women and girls, denial of justice for many survivors, and impunity for perpetrators. The customary justice
system is focused on clans. Justice is delivered for the clan rather than for the survivor of the sexual
violence. Traditional approaches to dealing with rape seek resolution or compensation through
negotiation between clan members. Restitution is paid to the clan and not to the survivor. Once restitution
is paid, the perpetrator of the sexual violence is free from further punishment and the case is considered
finalized. In some cases, the woman or girl is forced to marry the perpetrator of the violence as a form of
“restitution” ordered by customary courts. The customary system is widespread, and many families and
clans choose it over formal justice systems.77
119. In view of inheritance and access to resources, women are exposed to housing, land and property
violations, especially land-grabbing and denials of inheritance. The fact that, after marriage,11 women will
likely enter a different family limits women´s inheritance. Investing in women is perceived as a misuse of
scarce resources in times of poverty and conflict. Therefore, women rarely inherit valuable assets such as
land and income-producing animals. Also, women are not considered principals; they are not diya-paying
members and thus do not usually share in diya receipts, even if they relate to a violation against them.
This creates important vulnerabilities for women, while a woman must be protected by her clan members
by convention, as a non-diya paying member and one who cannot contribute to clan security in times of
conflict, women will always be less valuable and more dispensable.78
120. On the other side of gender, since the war in 1991, the majority of men lack the resources to fulfil
their gender specific expectations and responsibilities. Men have become vulnerable and are at risk of
revenge killing a war-related phenomenon that affects male mobility and work opportunities which puts
pressure on women to act as breadwinners. Men have been forced to leave outside of their clan territory,
which makes them leave in constant fear without the protection of the clan.79 Interventions for women
and children should consider the well-being of the family as a whole. A positive engagement with the
issues confronting Somali men should be part of any attempt to address the needs of women and children.
121. The rate of FGM/C in Somalia is estimated at 98 percent. This harmful practice carries serious
health consequences and it increases the likelihood of dying during childbirth. Nearly 50 percent of the
girls are forced to marry before they turn 18. Being married robs them of their childhood and increases
the likelihood of early pregnancy and school dropout. Existing protection services are inadequate,
especially in remote and in warring communities: there is widespread failure to promote and protect the
rights of children80.
77
UNDP 2018
78
Expanding Access to Justice in Somalia Program 2019.
79
J. Garder and J. El-Bushra, The impact of war on Somali men and its effects on the family, women and children.
80
UNICEF, Child Protection, 2020, accessed at: https://www.unicef.org/somalia/child-protection

12
5. CONSULTATIONS AND PUBLIC DISCLOSURE
5.1 Introduction
122. The World Bank ESS10 “Stakeholder Engagement and Information Disclosure” recognizes the
importance of open and transparent engagement between the Borrower and project stakeholders as an
essential element of good international practice. Effective stakeholder engagement can improve the
environmental and social sustainability of projects, enhance project acceptance, and make a significant
contribution to successful project design and implementation. This Standard requires public consultation
with relevant stakeholders (potential project beneficiaries, affected groups and local NGOs) about the
project environmental and social impacts, and take their views into account when developing the project.
123. The analytical underpinnings of the Somalia Education Human Development Project (SEHDP) are
based largely on the National Development Plan (2020-2024), which has a chapter dedicated to the
required improvements in the relevance and efficiency of the human capital development through
education in Somalia. The design and priorities of the SEHDP were discussed at the WBG office in Nairobi,
Kenya in January 2020 and involved important stakeholders including representatives of the Ministries of
Education of the Federal Republic and Member States, line ministries and local education groups.
Engagements and consultation on the project design and the planned activities and implementation
arrangements have been done with key institutional stakeholders including the relevant Government and
implementing agencies as summarized in Table 4.
Table 4: Stakeholder planning meeting

Agenda discussed Participants Key points discussed
Ministry of Finance (MoF) DG Funding formula for the project, efficient use of the resources
and accountability
Ministry of Labour and Social DG Policy direction and guidance on all labour administration
Affairs
Ministry of Energy and Water DG Safety and health of potential workers
Sources
Ministry of Public Works and DG How the Ministry can support the project in the area of
Reconstruction construction standards, land acquisition policies and
restrictions on land use
Ministry of Posts, Telecom and DG ICT in education, infrastructure building, etc.
Technology
National office for Environment Director How the Office would provide necessary advice on the area of
regulation, forest protection, minimization of air pollution,
preservation of bio-diversity etc.
5.2 Brief Summary of Previous Stakeholder Engagement Activities

124. A virtual stakeholder consultation on the SEP was held on 3 December 2020 was attended by 40
participants representing the Federal and State Governments, civil society organizations (CSOs),
development partners and the World Bank (about 6 of the participants were women). A stakeholder
consultation on the ESMF and RPF was held on February 2021, attended by 55 participants representing
the Federal and State Governments, civil society organizations (CSOs), development partners and the
World Bank. Tables 7&8 presents a summary of the key issues raised and how they have been
incorporated in the instruments. The list of participants is presented in Annex 6.

13
Table 5: Summary of key issues raised during SEP consultations on 3rd December 2020
# Concern Responses
1. Transparent criteria for The national poverty index will be used to select the districts and beneficiary schools. The
selection of schools to be focus will be on the poorest parts of the country with low education enrolment. The
supported by the project criterion is described in Section 1.4 of this ESMF.
2. Inclusion of the poor and The selection of the districts and the areas to be supported by the project is aimed at
disadvantaged including supporting communities that are poor and disadvantaged. The Inclusion Plan, presented
learners with disability in section 5 of this ESMF, outlines how the various disadvantaged groups will be involved
in all stages of the project. The grievance redress mechanism (GRM), described in section
6 sets out ways through which the communities will be able to channel their complaints
and get redress.
3. Recruitment and retention The community education committees will be enlisted to take part in the recruitment
of female school teachers in process. The selection of female teachers, that are resident in the communities will be key
schools to ensuring that they are kept in the education system. There will also be incentives to
attract and retain female teachers
4. Trusted grievance redress The project will establish a GRM as outlined in the SEP. Measures will be put in place to
mechanism make sure it is trusted and accessible.
5. Gender based violence The risk of GBV/SEAH is articulated in Section 6.5 of this ESMF. A standalone GBV Action
(GBV/SEAH) and other Plan will be developed before disbursement, to manage GBV/SEAH and sexual
crimes exploitation and abuse (SEA).
6. Coordination and There will be a PMU and PIUs will have responsibility to coordinate with other projects,
management of the project arms of government and non-state actors.
7. Sustainability of the The FGS will absorb the costs of managing the investments from the project beyond the
interventions beyond project funding. This is indicated in Section 1.4 of this ESMF.
project funding
Table 6: Summary of key issues raised during consultations on ESMF and RPF held on 9th February, 9am -12pm
Issues Raised Mitigation measures
1. Min of Environment asked how this Environmental and social The project will be implemented in line with the EIA
guideline will be in line with currently drafted Government regulations as per the ESMF
guidelines which is ESIA regulations.
2. Are there specially trained investigators of SEA. If not, the Ministry This will be considered in the GBV Action Plan
should consider as some of the cases may need special attention.
4 The need for confidentiality in reporting GBV/SEAH issues and There will be multiple reporting lines including toll
protection of victim identity and avoiding stigma lines, messaging and focal persons trained in these
issues. And ensure confidentiality in the process.
5 There is a teacher recruitment processes in the Teacher Policy. The To be referred to in the LMP
onus is on FMS and MoECHE to implement the policy proposals.
6 The society knowledge gap on issues of GBV/SEAH Awareness of the society on the GBV issues.
7 Land ownership and acquisition To sensitize the community about the project to
have community buy inn and to have land
agreement drawn from other project experience
like the one used in other projects ( Byole), to use
government land where possible. And use existing
schools in urban centers where land is expensive.
8 Security for the teachers and students on issues of GBV Developing a comprehensive approach and
sensitize the community on the issue.
Ministry of Labour mentioned that there is a new labour law ready These gaps will be considered in the LMP
for submission to the cabinet for approval, and there a number of
HR policies that might need to be updated including issues of child
labour and OHS. Annual stakeholder consultation meetings will be
held at FGS and FMS level.

14
Suggestion that there should be SOPs that should be followed

strictly by all stakeholders. Secondly a simple
community/stakeholder feedback mechanism to be developed to
allow all project staffs and stakeholders to provide
feedbacks/complains to the management.
Land disputes are a significant risk for school construction. There is These issues have been considered in the RPF
need for thorough investigation. It is important that the land should
be Government land to avoid collusion and land being taken away
from the public. The participants also mentioned the importance of
land donation or acquisition being documented in a proper way,
and hardly will that cause an issue especially in rural areas if the
community is well informed and issues explained to them. The
process differs from one region to the other, like in Puntland the
interior ministry declares what is to be public properties and the
mayors are also involved. The donation document must be
notarized and witnessed by several parties. The participants also
mentioned that it is useful to draw from past and current
experiences including the Biyole project in matters of land
acquisition. The community engagement is important and also all
the neighboring parties should be involved, which would reduce or
eliminate cases of land contestation. It was mentioned if there is a
clear process guiding resettlement.
Concern over accessibility for students with physical impairment The schools will be accessible to those with physical
and if the project intends to support students with special needs, disabilities and will follow the guidelines approved
particularly when doing construction. by the ministry on the construction standards that
include all public utilities to be accessible.
Concerns that the school ownership would be taken over by private Schools will be owned by the MOECHE and only in
entities cases where land acquisition or donation is not
possible like the Banadir region and the GER is low,
the government might engage the private schools
to accept poor students.
125. MoECHE teams will continue engaging in extensive consultations with all relevant stakeholders
including the Federal Member States (FMS), local administrators in the selected project areas, community
leaders, education officers and business entrepreneurs. Information gathered through these
consultations will be used to update the SEP as necessary.
5.3 The Project SEP

126. The SEP identifies the key stakeholders to be consulted and the means of communication. It also
identifies the frequency of engagement. The social specialists assigned to the SEHCDP will be responsible
for the implementation of the SEP and the monitoring elements, with assistance from the communication
and M&E officers. Key stakeholders identified include learners, parents, school committees, including
CECs, Social Accountability Committees other project-affected communities, host communities, federal,
state and municipal authorities responsible for education, religious and local leaders, civil society
organizations (CSOs), and other development partners. The Project will take differentiated measures to
include such groups into stakeholder engagement activities, such as through focus group/individual
meetings, mediation by community support groups, accessible consultation venues, simple written
materials or use of graphics or provision of free municipal transport.
5.3.1 Inclusion plan

15
127. An Inclusion Plan is also included in the SEP, aimed at ensuring that all people are involved in
project decision making and benefit from the investments. The following disadvantaged groups have been
identified by the project:
i. Minority casts and groups;81
ii. Internally displaced persons;
iii. Those who live in remote rural areas or areas characterized by violence that are bereft of
social services and amenities;
iv. Nomadic pastoralists, adults and children living with mental and/or physical disabilities;
v. Widows;
vi. Single heads of households;
vii. The elderly;
viii. Persons with chronic illnesses; and
ix. Orphans.
128. Social accountability committees will have representation of these groups and promote inclusion.
Teachers and communities will be trained on inclusion of minority groups, people with mental and
physical disabilities etc.
5.3.2 Grievance Redress Mechanism

129. Transparency and accountability will be core elements of the SEHDP. The goal of the GRM is to
strengthen accountability to beneficiaries and to provide channels for project stakeholders to provide
feedback and/or express grievances related to project supported activities. By increasing transparency
and accountability, the GRM aims to reduce the risk of the project inadvertently affecting
citizens/beneficiaries and serves as an important feedback and learning mechanism that can help improve
the project impacts.
130. Under the new World Bank ESSs, Bank-supported projects are required to facilitate mechanisms
that address concerns and grievances that arise in connection with a project.82 One of the key objectives
of ESS 10 (Stakeholder Engagement and Information Disclosure) is ‘to provide project-affected parties
with accessible and inclusive means to raise issues and grievances, and allow borrowers to respond and
manage such grievances’.83 This GRM should facilitate the SEHDP to respond to concerns and grievances
of the project-affected parties related to the environmental and social performance of the project. The
SEHDP will provide mechanisms to receive and facilitate resolutions to such concerns.
131. Types of grievances: Complaints may be raised by staff, partners, consultants, contractors,
members of the community where the program is operating or members of the general public regarding
any aspect of program implementation. Potential complaints include:
i. Fairness of contracting;
ii. Fraud or corruption issues;
81
This shall include all groups falling outside the big four clans and not genealogically associated with them in a
specific district or geographical area including the ethnic, occupational groups.
82
Under ESS2 (Labour and Working Conditions), a grievance mechanism for all direct or contracted workers is
prescribed, which will be laid out in a separate Labour Management Plans (LMPs). The World Bank’s Good Practice
Note on ‘Addressing Gender Based Violence in Investment Project Financing involving Major Civil Works’ spells out
requirements for a GBV grievance redress mechanisms, which will be defined in a separate GBV/SEA and GBV Action
Plan.
83
World Bank, Environmental and Social Framework, 2018, p. 131.

16
iii. Inclusion;
iv. Social and environmental impacts;
v. Payment related complaints;
vi. Quality of service issues;
vii. Poor use of funds;
viii. Workers' rights;
ix. Gender-Based Violence (GBV) and Sexual Exploitation and Abuse (SEA) and sexual harassment;
x. Forced labour, including human trafficking and use of prison labour;
xi. Child labour; and
xii. Threats to personal or communal safety.
132. As per World Bank standards, the GRM will be operated in addition to GBV/SEA and GBV Action
Plan, which includes reporting and referral guidelines (there will be a stand-alone GBV Action Plan
developed for this project). The GRM will also operate in addition to specific workers’ GRMs, which are
laid out in the LMP.
133. The GRM is designed to ensure that grievances and perceived injustices are handled by the
project, and that the project aides mitigating general conflict stresses by channeling grievances that occur
between people, groups, communities, government actors, beneficiaries, project staff, NGOs, CSOs,
contractors or primary suppliers. Aggrieved parties need to be able to refer to institutions, instruments,
methods and processes by which a resolution to a grievance is sought and provided. The GRM therefore
provides an effective avenue for expressing concerns, providing redress, and allowing for general
feedback from community members.
134. The GRM aims to address project-related concerns in a timely and transparent manner and
effectively. Information on the GRM will be readily available to all project-affected parties. The GRM is
designed in a culturally appropriate way and is able to respond to all needs and concerns of project-
affected parties. The availability of these GRM does not prevent recourse to judicial and administrative
resolution mechanisms.
135. MoECHE will have the responsibility of overseeing the resolution of all issues related to the project
activities in accordance with the laws of FGS and the World Bank Environmental and Social Standards
through a clearly defined GM that outlines its process and is available and accessible to all stakeholders.
The entry point for all grievances will be with the Social specialists at the FGS and FMS level who will
receive grievances by phone, text or email to publicized toll free mobile phone lines and email addresses
at both FMS and FGS level. The social specialists will acknowledge, log, forward, follow up grievance
resolution and inform the complainant of the outcome. The complainant has the right to remain
anonymous, thus their name and contacts will not be logged and whistleblower protection for complaints
raised in good faith will be ensured. The FGS social specialist will carry out training of all PMT staff and
Ministry of Education staff involved with the project, and contractors on receiving complaints and referral
and complaints handling and reporting and will oversee awareness raising on the GRM at national level.
136. A grievance redress committee (GRC) will be established at FMS and FGS levels chaired by the
project manager, and the relevant staff will be included as necessary depending on the complaint
(procurement, finance, monitoring and evaluation (M&E), GBV advisor and communication). The social
specialist will compile minutes for the meetings and follow up the grievance resolution process. The GRC
will meet monthly to review minor complaints, progress on complaints resolution, review the
development and effectiveness of the grievance mechanism, and ensure that all staff and communities

17
are aware of the system and the project. Immediate meetings will be held in case of significant complaints
to be addressed at the MOE/PIU level. Significant complaints will be outlined in the GM manual. For
serious or severe complaints involving harm to people or the environment or those which may pose a risk
to the project reputation, the FMS social specialist should immediately inform the FGS social specialist or
head of the PMU, who will inform the World Bank within 48 hours as per the Environmental and Social
Incident Reporting (ESIRT) requirements.
137. Due to limited capacity in the Government system, the States may enlist the support of CBOs
working in the project areas to support the GRM activities or NGOs/an independent call center to receive
and help process complaints on an as-needed basis. All contractors and suppliers will be expected to
sensitize their workers on the Project GRM and have a focal person to receive complaints regarding the
construction and their workers and put in place complaints structures specific to the workers (as detailed
in the LMP).
138. At community level social accountability committees with strong representation of disadvantaged
groups will receive complaints directly from the community, contractors or school and forward to the FMS
social specialist to support resolution and follow up. Figure 1 presents the structure to be adopted by the
project in managing grievances.
Figure 2: Grievance structure for the project

18
(i) Receive and register complaints

139. The beneficiaries will have multiple ways of channelling complaints on any aspect of the project.
This will be through email, mobile phones, community meetings, and websites. There will also be
opportunities for in-person reports at the community level through contractors or project staff, CECs,
SACs or community leaders. All complaints will be channelled to the relevant social specialist, who will log
them into the Complaints Register (see a template in Annex 2).
(ii) Acknowledge, assess and assign

140. An acknowledgement of receipt will be sent to the complainant within 7 days of receipt of the
complaint. The social specialist will assess the complaint in conjunction with the PM and forward it to the
relevant level of implementation (e.g. MoE at the State level). If the grievance cannot be easily resolved,
the social specialist in conjunction with the project manager will call a meeting of the Grievance Redress
Committee (made up of relevant members of the project team) will develop a course of action. The GRC
will meet every 2 months to review the functioning of the GRM and the Grievance log. All cases will be
treated with utmost confidentiality.
141. Incident reporting. Severe incidents, those that caused an incident that caused significant adverse
effect on the environment, the affected communities, the public or workers, e.g., fatality, GBV, forced or
child labor, will be reported by the IP to the PMU and the WBG within 24 hours (details on this process
are described in the Labour Management Procedures).
142. Where grievances are of sexual nature and can be categorized as GBV/SEA or GBV Action Plan,
the IP will handle the case appropriately, and refer the case to the GBV reporting protocols and referral
system, defined in the GBV/SEA and GBV Action Plan. Dedicated training on how to respond to and
manage complaints related to GBV/SEA will be required for all GRM operators and relevant project staff.
143. For all other grievances, the respective PIU will determine whether the grievance can be solved
locally, with local authorities, implementers, NGOs, CSOs or contractors, and whether an investigation is
required. The first port of call will have in-depth knowledge of communal socio-political structures, hence
will be able to address the appropriate individuals, if the case can be solved at the local level.
144. At all times, the PIUs will provide feedback promptly to the aggrieved party, for example through
the phone or through the community structures established for addressing GRM. Feedback will also be
communicated through stakeholder meetings and beneficiary meetings during Project activities. For
sensitive issues, feedback will be given to the concerned persons bilaterally.
145. Records of all feedback and grievances reported will be established by the PIU. All feedback will
be documented and categorized for reporting and/or follow-up if necessary. For all mechanisms, data will
be captured in an excel spreadsheet. The information collected, where possible and for only for non-GBV
related complaints, will include the name of the person reporting, district, State, cooperating partner
where applicable, project activity, and the nature of the complaint or grievance.
(iii) Propose a response

146. The GRM focal point will propose the mechanism to be followed to resolve the grievance within
21 days and share findings with relevant stakeholders. Where an incident is reported, the IP will, in
addition, follow the incident management protocol to resolve the issue. Verification and management of
GBV/SEAH related grievances will follow specific, differentiated processes outlined in the GBV Action Plan.

19
(iv) Agreement of a response between the Complainant and the GRM Team
147. Where a negotiated grievance solution is required, the GRC will invite the aggrieved party (or a
representative) and decide on a solution, which is acceptable to both parties and allows for the case to
be closed – based on the agreement of both parties.
148. After deciding a case, the GRC will provide an appeals mechanism to the aggrieved party, which
is constituted through the PMU. This is important in cases in which the aggrieved party is dissatisfied with
the solution provided by the GRC. In these instances, the PMU will step in and provide an appeals
mechanism. The appeal should be sent to the PMU directly (a phone number will be provided), where it
will be reviewed by the PMU GRM Team and will be decided on jointly with the PIU Coordinator. Where
aggrieved parties are dissatisfied with the response of the PMU, they can report cases directly to the
World Bank or use the available national grievance resolution mechanisms (see below).
(v) Implement the response

149. The GRM focal point will follow up on the recommended response mechanisms and ensure the
resolution of the complaints. In case the resolution is successful, the case will be closed out but in cases
where the complainant is dissatisfied with the response, the GRM focal point will guide the individual or
group to seek alternative grievance resolution mechanisms including mediation, arbitration and judicial
processes.
(vi) Review the Grievances

150. The GRM team will conduct a review of the cases reported on a monthly basis and agree on the
next steps on cases that have not been closed out. The GRM focal point will record the actions
recommended by the GRM team and file a monthly report to the PIU. Most importantly, all cases filed will
need to be logged and monitored by the contractors and primary suppliers. Figure 2 presents the process
to be adopted by the project in managing grievances.

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Figure 3: Grievance process for the project
Monitoring and Reporting of GRM

151. The PMU, specifically the Social Specialist, will be responsible for monitoring the access to and
implementation of the GRM by all project teams at the national, state levels. The Specialist will include
the GRM in his/her supervision and monitoring missions to the field and conduct spot checks on its
implementation, or, where access is difficult recruit local teams to do so.
152. The contractors and primary suppliers will provide analytical synthesis reports on a quarterly basis
to the PMU, which will include the number, nature and status of grievances. These reports will form the
basis of all regular reports from the PMU to the World Bank.
153. The PMU will further provide an excel sheet summary of the feedback and grievances reported,
which will be linked to the Project’s Management Information System (MIS) and to the M&E Results
Framework. The summary will also include a breakdown of different categories complaints such as those
related to GBV/SEA. The viability of having a separate GBV/SEA/H GRM will also be considered. The project
team will further maintain a documented record of stakeholder engagements, including a description of
the stakeholders consulted, a summary of the feedback/grievances received during community
consultations. The PMU will extract lessons from the GRM and conduct an analysis on the overall
grievances, and share the results with all contractors and key project team members.

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GBV and SEA

154. Cases of GBV/SEA can be reported through the general Project GRM. However, additional
channels for reporting GBV/SEA complaints will be identified and integrated into the GRM (details are
provided in the GBV Action Plan). The GBV survivor has the freedom and right to report an incident to
anyone: community member; project staff; GBV case manager; or service provider. Given to the sensitive
nature of GBV complaints, the GRM will provide different ways to submit grievances such as phone, text
message and email. All relevant staff of the PMU will receive training on handling GBV complaints and
referral systems, ideally during the project initiation phase and as part of the staff welcome package. The
GRM Operators will be trained on key protocols including referral, reporting and informed consent
protocols to receive those cases in an appropriate manner and immediately forward them to the GBV/SEA
referral system. The GRM Operator will ensure appropriate response by: (i) providing a safe caring
environment and respect the confidentiality and wishes of the survivor; (ii) if survivor agrees, obtain
informed consent and make referrals; and (iii) provide reliable and comprehensive information on the
available services and support to GBV survivors.
155. The GRM proposes the following key features on preventing GBV/SEA: (i) establish quotas for
women in community level grievance management to facilitate safe reporting; (ii) provide multiple
channels to receive complaints (channels to be determined after community consultation); (iii) resolve
complaints at the point of service delivery to reduce information and transaction costs and gender
sensitive independent channels for redress; and (iv) communicate GRM services at the community level
to create GBV/SEA awareness and enable project‐affected persons to file complaints.
156. Beneficiaries and communities will generally be encouraged to report all GBV/SEA cases through
the dedicated GBV/SEA referral system and complaints resolution mechanism. This will be made explicit
in all community awareness sessions, as well as be part of the publicly disclosed information. The GBV/SEA
referral system will guarantee that survivors have access to necessary services they may need, including
medical, legal, counselling, and that cases are reported to the police should the survivor choose to do so.
Formal processes for disclosing, reporting, and responding to cases of GBV/SEA will be articulated within
the GBV/SEA and GBV Action Plan.
157. If a GBV/SEA case is reported through the Project GRM, the GRM Operator will report the case
within 24 hours to the PMU, and the PMU is obliged to report this case to the WB within 24 hours.
Furthermore, cases of SH will be reported through the workers’ GRM, if it concerns a direct worker or a
worker from a sub-contractor, NGO partner or even a community worker following a survivor-centered
approach. The PIUs will be in charge of holding sensitization sessions for contractors and primary suppliers
regarding the Code of Conduct obligations and awareness raising activities in communities. All reporting
on GBV/SEA will limit information in accordance with the survivor’s wishes regarding confidentiality and
in case the survivor agrees on further reporting, information will be shared only on a need-to-know-basis,
avoiding all information which may lead to the identification of the survivor and any potential risk of
retribution.
GRM Appeals and Escalation Mechanisms

158. Where agreement on grievance resolution has not been reached, the project team will offer the
complainant with appeal options and processes available in the country. The approaches will include an
Independent Panel; internal or external offices or individuals with appreciable degree of independence,
and third-party fact-finding, facilitation, and mediation missions as applicable. Depending on the
grievance, the appeal may entail offering the aggrieved person the option to seek redress through
statutory referral institutions operational in the country.

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WBG’s Grievance Redress Service (GRS)

159. World Bank Somalia Office: Communities and individuals who believe that they are adversely
affected by a World Bank supported project may submit complaints to existing project-level grievance
redress mechanisms or the World Bank Somalis office at: [email protected].
160. World Bank Grievance Redress Service (GRS): If no response has been received from the World
Bank Somalia office the grievance can be raised with the World Bank Grievance Redress Service email:
[email protected]. 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. For information on how to submit complaints to
the World Bank’s corporate Grievance Redress Service (GRS), please visit
http://www.worldbank.org/en/projects-operations/products-and-services/grievance-redress-service.
For information on how to submit complaints to the World Bank Inspection Panel, please visit
www.inspectionpanel.org.

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6. POTENTIAL ENVIRONMENTAL AND SOCIAL RISKS, IMPACTS AND MITIGATION
6.1 Introduction
161. This section highlights the environmental and social risks and impacts along with associated
mitigation measures for the expected negative environmental and social risks and impacts linked to the
proposed, albeit small-scale civil works, especially during the construction and rehabilitation of
classrooms, schools, ablution facilities, staff rooms, storage facilities and another schooling infrastructure.
The risks and impacts during the operational phase of the supported schools are also covered. The schools
to be supported in the project, including any new constructions, will be modelled along the Safe Schools
standards as promoted by UNICEF and its partners, ensuring that the schools are designed and
constructed to secure the children while at the same time having minimal adverse environmental risks
and impacts. The Safe Schools Standards focus on school designs for the protection of children and their
educational prospects in areas prone to armed conflicts. The schools to be supported in the project,
including any new constructions, will be modelled along the Safe Schools standards as promoted by
UNICEF. These UNICEF standards focus on the EHS standards and the school environment, ensuring that
the schools are designed and constructed to secure the children while at the same time having minimal
adverse environmental risks and impacts. These Standards focus on school designs for the protection of
children and their educational prospects and are relevant for areas prone to armed conflicts. By following
these Standards, the Somali government will ensure that it will provide access to water and sanitation in
school facilities, ensure that the indoor air quality (IAQ) is in compliance with WHO guidelines, eliminate
smoking in schools and ensure that children can safely walk to schools.
162. Based on stakeholder consultations and on account of the fact that the project length is relatively
limited, it is envisaged that the project will have minor deleterious environmental impacts. The potential
positive socio-economic benefits that may be registered as a result of this project are also described.
163. An Environmental and Social Commitment Plan (ESCP) has been prepared for the project. The
ESCP requires compliance with all provisions of the following environmental and social instruments, which
have been prepared and/or are under preparation for this project:
• This ESMF, which has been prepared in accordance with the procedures set in place by the World
Bank;
• The Resettlement Policy Framework (RPF), which has been prepared in accordance with ESS5 of
the ESF. The Framework will ensure that appropriate measures are in place to address any issues
that might arise from potential land acquisition and/or economic displacement under the project;
• The Stakeholder Engagement Plan (SEP) has been developed. The SEP includes stakeholder
identification and analysis summary, plans for engagement (e.g., type, regularity, etc.),
communication activities and grievance redress mechanisms. The SEP outlines both the initial and
ongoing process by which stakeholders will be engaged to ensure the design of the project aligns
with stakeholders current and ongoing needs. Consultations have been done on the SEP with a
variety of actors in the education sector in Somalia, and a number of comments received and
addressed;
• The Labour Management Procedures (LMP) will be developed and cleared prior to disbursement
of funds for Component II of the project. The LMP will outline requirements for construction
companies and primary suppliers including a mechanism to prevent child and forced labour and
reporting requirements on serious incidents;
• GBV/SEAH Action Plan will be developed to address risks related to sexual exploitation abuse and
harassment; and

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• Security Management Plan will be developed and cleared before disbursement of components 2
and 3.
164. The ESCP also requires compliance with ESIAs and ESMPs, Resettlement and Livelihood Plans (RPs
and LPs), sub project specific SEPs and contractor LMPs, which will be prepared for subprojects under the
project.

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6.2 The ESMF Procedures

165. Step 1: Environmental and Social Screening. Screening is the process of identifying whether a
closer, more comprehensive and formal assessment of environmental and social impacts is necessary or
not. The procedure is used to determine whether a proposed sub-project activity within the larger
Education project is likely to have significant effects on the environment and social systems. The
subproject screening process will also exclude sensitive areas, including biodiversity hotspots and
seasonal water streams, to ensure that ecological processes are not interfered with.
166. An environmental and social screening checklist is hereby provided for the benefit of the project
implementing teams in the seven project districts. The project teams, and especially the environmental
and social safeguards, are required to closely go through the screening tool to determine the next steps,
including the environmental and social instruments that need to be prepared. Please see Table 6.
Table 6: Environmental and social screening tool for the Somalia Education Project
Impact occurrence Yes84 No85 Details
Will sub-project logging of natural stands of
activities entail the … forests?
consumptive use of wetlands?
use of marine resources?
consumptive use of natural
grasslands?
poaching, removal, alteration or
disturbance of any animal
species?
Will project activities, modification of physical features
after their of the terrain, leading to
implementation, result alteration of site hydrology?
in the … flow of leachate into the soil?
spilling of oil and other
petroleum products and the
contamination of surface and
subsurface soil biota
generation of hazardous wastes
(solid and liquid)?
groundwater contamination or
deterioration of water quality?
soil erosion?
siltation of waterways?
flash floods?
increased levels of air pollution,
including dust, particulate
matter, and emissions of noxious
fumes?
84
Tick if “yes”
85
Tick if “no”

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Project procurement Will the project procure, or does

the project intend to procure,
products that are in the World
Health Organization (WHO)
Classes IA and IB, or formulations
of products in Class II or
pesticides or other chemicals
specified as
“persistent organic pollutants”
under the Stockholm Convention
or that are banned in Somalia?
Please check the WHO website
for more information
(http://www.who.int)
Environmental Will sub-project activities
conventions and contravene major international
treaties and regional conventions on
environmental issues? Please
consult the project’s ESMF listing
on page X for a list of these
conventions.
Unexpected Will there be other unexpected
environmental impacts environmental impacts that may
occur as a result of
implementation of the proposed
sub-projects?
Environmental-related Is the project likely to receive any
grievances environmental and/or social
related grievances as a result of
the sub-projects?
Social screening checklist
Land availability and Is land available for school
ownership construction?
Are the community members
willing and ready to hand it over
for school construction?
Presence of a CEC at the Does the area have a functional
school level CEC or the readiness to form
one?
Involvement of Are there structures in place to
disadvantaged groups engage people considered
in discussions and disadvantaged in decision making
decision making (e.g. women, youth, persons with
disabilities, IDPs, etc.?
167. Step 2: Development of E&S instruments. Based on the findings of the environmental and social
screening, the team will proceed to the next step of development of environmental and social instruments

27
in the event that significant environmental and social impacts are anticipated. The team will therefore
prepare the following environmental and social documents:
a. Site-specific Resettlement Plans (RPs); and
b. Environmental and Social Management Plans (ESMPs).
168. Step 3: Review and approval. The draft environmental and social instruments prepared will be
submitted to the project TTLs, who will review and in turn forward these draft documents to the World
Bank ESF team supporting this project. The Bank will internally review the submitted instruments carefully
and will likely have suggestions for quality improvement, including enhancing the proposed.
environmental and social mitigation measures. After Bank clearance, the project team can go ahead and
implement the sub-projects, including allowing contractors to move on and commence civil works.
169. Step 4: Implementation, monitoring and reporting. In this instance, the project teams in the
various FMS’s will ensure that specific requirements on contractor management, including incorporating
ESHS requirements, are incorporated into bidding document and contracts. Contractors are duty bound
to ensure that they report as accurately as possible on incidents and accident in the course of the
construction and operation of the schools supported by the project. The contractor and primary suppliers
will be required to ensure that they follow the national guidelines and World Bank requirements, including
maintaining an accurate labour registry of all contracted workers, with age verification conducted.
Minimum working age under the project is 18 years.
170. Also, under Section 6.1, several E&S instrument, including ESMF, RPF, SEP, LMP, GBV Action Plan
and SMP are said have been or being in the process of being prepared. It needs to clearly state the specific
timeline for each instrument.
6.3 Environmental and Social Screening

171. Screening is the first step in the ESMP preparation process. All proposed subprojects, that is, new
school construction activities grouped into district cohorts, will be subjected to the screening process to
determine and assign them an environmental and social risk rating category and further identify potential
environmental and social impacts. The process will also identify critical issues that might be triggered
and/or exacerbated by the subprojects and would need further detailed investigations during
environmental and social assessments. This process will also help in advising what safeguards tools
(ESMPs, RPs, LPs etc.) will be required for the various subprojects. Most importantly, it will help in re-
aligning, re-designing and where not possible dropping out subprojects that have high risks and the
potential to negatively impact on the environment, natural habitat and physical and cultural resources,
forests, and the health and wellbeing of the communities.
172. The environmental and social screening will involve:

• reconnaissance of the subproject areas (including the siting of the schools) and their surroundings;
• the absence or existence of any VDC/CEC in the village/district, their capacity, effectiveness as per the
CEC policy and the existing gaps;
• identification of the major subproject activities to be implemented;
• preliminary assessment of the impacts of these activities on the ecological, physicochemical and
socio-economic environment of the subproject surrounding areas; and
• potential impacts on the individuals, households and communities living in the project area; and
• an understanding of the community including disadvantaged groups as well as the land ownership
and management system and community structures including the existence of CECs and VDCs and
representativeness.

28
173. A template form for environmental and social screening for sub-project activities is presented in
Annex 2. This will be reviewed and updated as needed during the implementation process. Key
environmental and social risks identified as crosscutting for the project include labour and OHS. The
project investments will be considered in the environmental and social assessments. Specific
environmental and social risks for each project component are mainly linked to processes and capacity of
key stakeholders for environmental and social risk management.
6.4 Environmental and Social Risks Rating

174. Assessment of risks for subprojects will be determined according to their environmental and
social risk levels. The risk level is to be estimated based on the intrinsic environmental and social risks
associated with:
• the type of interventions to be carried out (e.g., during the construction of schools); and
• the specific type of infrastructure proposed.
175. The physical components of the project are civil works related to the construction of schools and
upgrading offices to be used for project activities. The impact of the civil works is expected to be small-
scale, localized and reversible. There are, therefore, no significant or irreversible adverse environmental
issues anticipated from the activities to be financed under the project.
176. The engineering capacity of the client is nascent and growing with regards to construction of
small-scale civil works. However, the client's ability to apply World Bank ESS is limited due to lack of
appropriate technical capacity for safeguards at the MoECHE. In addition, the country risks are extensive
due to political and security considerations; the ability for the World Bank to supervise environmental and
social risk management is limited. Construction specifications for the new classrooms and schools will
conform to the government’s school prototypes, align with agreed standards (safe, inclusive, resilient,
and climate-smart), and incorporate a modular approach as appropriate to suit local needs so as to ensure
optimal coverage and minimal distances for children to travel. The project will also adhere to the recently
published national construction standards by the Ministry of Public Works and Reconstruction which
establishes standards for construction or renovation projects funded by, or on behalf of, the government
of Somalia. The ministry’s building standards put emphasis on ensuring that such buildings are accessible
to persons with disabilities (PWDs), i.e., PWD-friendly, through “universal design,” which ensures usability
by all people, to the greatest extent possible, without the need for adaptation or specialized designs.
177. The overall environmental and social risk rating is “High” under World Bank’s Environmental and
Social Risk Classification system (ESRC).
6.5 Environmental Risks and Impacts Envisaged

178. There are environmental risks and impacts associated with the implementation of the project
activities for the proposed initiative. The environmental risk rating is “Moderate” at this time due to the
potential environmental risks from school construction and IT support. The rating may be amended as
more details become available. The new schools will be modelled along the Safe Schools Standards as
promoted by UNICEF and its partners, meaning that the schools will be designed and constructed to
secure the children while at the same time having minimal adverse environmental risks and impacts. The
Safe Schools Standards focus on school designs for the protection of children and their educational
prospects in areas prone to armed conflicts. The schools to be supported in the project, including any new
constructions, will be modelled along the Safe Schools standards as promoted by UNICEF. The Standards
include commitments related to the EHS standards and the school environment, ensuring that the schools
are designed and constructed to secure the children while at the same time having minimal adverse

29
environmental risks and impacts, and which are in agreement with the World Bank’s EHS Guidelines.
These Standards focus on school designs for the protection of children and their educational prospects
and are relevant for areas prone to armed conflicts. By following these Standards, the Somali government
will ensure that it will provide access to water and sanitation in school facilities, ensure that the indoor air
quality (IAQ) is in compliance with WHO guidelines, eliminate smoking in schools and ensure that children
can safely walk to schools.
179.
180. The envisaged environmental risks and impacts during the construction phase are likely to
include:
a. land clearing and loss of vegetation;
b. soil erosion and sedimentation;
c. risks from vehicular traffic;
d. change of land use;
e. generation of liquid waste, and hazardous wastes (e.g., use oil, empty paint cans, etc.);
f. risks associated with source of primary supply materials (materials for school
construction, etc.);
g. worker occupational health and safety;
h. construction risks during COVID-19 pandemic;
i. solid waste generation and disposal;
j. air and noise pollution; and
k. open pits following extraction of construction materials for school construction.
181. The envisaged environmental risks and impacts during the operational phase are likely to include:
a. potable water supply;
b. wastewater disposal;
c. solid water collection and disposal;
d. indoor air quality;
e. transportation (including traffic);
f. outbreak of pests and vermin;
g. spread of communicable and infectious diseases among children noise pollution;
h. e-waste (especially since the project will support digital delivery of educational materials);
and
i. other potential hazards beside fire (including droughts, etc.).
182. Although there are no significant or irreversible adverse environmental issues anticipated from
the investments, the project will explore the use of safety audits for the education sector, as is currently
done among humanitarian and development partners in Somalia, to ensure project activities take into
consideration key structural safety considerations in design and implementation.
6.6 Social Risks and Impacts Envisaged

183. The social risk rating is adjudged as ‘High’. While the scale and nature of the civil works are limited,
some social risks and impacts may be significant. The project is designed to have positive social impacts
by purposely targeting disadvantaged populations including IDPs, rural, and pastoralist/nomadic
communities. A preliminary assessment of potential social risks and impacts establishes that there are
direct risks from project activities related to civil works from construction of schools, which could lead to
land acquisition, restrictions on land use, resettlement and labour influx. In addition, the use of local

30
labour and the reliance on community partnerships and management could lead to cases of child labour
and forced labour.
184. The risks of GBV/SEAH/SEA and sexual harassment, are currently assessed as “High” based on the
existing high rates of GBV/SEAH in the country, extending from conflict and shocks such as droughts,
floods and other climate-related challenges, and social norms that entrench gender inequalities in
Somalia. In addition, because the project’s scope and focus will be on predominantly rural sites, the scope
of works, and the absence of appropriate institutional structures to manage risks and weak mitigation
systems and lower absorption capacity ramps up the risk rating.
185. The project will be implemented in areas of fragility due to endemic poverty, acute drought, floods
and protracted conflict and insecurity which may make direct access to beneficiaries challenging and
amplify risks related to lack of effective stakeholder engagement, community participation, grievance
redress and application of other risk mitigation protocols. Other cumulative risks include systemic
weaknesses related to MoECHE’s capacity and the capacity of the FMS MoEs’ for preventing adverse social
impacts on the project and mitigating and offsetting impacts of social harm whenever they occur.
186. In order to address the aforementioned potentially adverse environmental and social risks and
impacts, an environmental and social screening process has been proposed under this ESMF. This will be
applied in such a way as to ensure that potential negative risks and impacts of the project are identified,
prevented or mitigated appropriately while enhancing the positive impacts. As an additional mitigation
measure, schools will be designed according to the Safe School Standards. Promoted by UNICEF and its
partners, Safe School Standards ensure that the schools are designed and constructed to secure the
children while at the same time having minimal adverse environmental risks and impacts. The Safe Schools
Standards focus on school designs for the protection of children and their educational prospects in areas
prone to armed conflicts. The Standards put emphasis on school crisis and emergency preparedness
training for both students and teachers, which encompass environmental crisis prevention/mitigation,
early intervention (which is part of ongoing school safety), immediate response/intervention, and long-
term recovery. The Standards include commitments related to the EHS standards and the school
environment, ensuring that the schools are designed and constructed to secure the children while at the
same time having minimal adverse environmental risks and impacts. Taken together, adhering to the
Standards and the EHS commitments will help the Somali government ensure that it will provide access
to water and sanitation in school facilities, ensure that the indoor air quality (IAQ) is in compliance with
WHO guidelines, eliminate smoking in schools and ensure that children can safely walk to schools. This is
in tandem with the guiding principles of the World Bank’s ESF.
187. To mitigate these risks during project implementation, key ESF instruments will be prepared and
activated in the life of the project. These are as follows:
• The LMP will guide how project related labour will be sourced and managed in a manner that
reduces harm on all categories of workers;
• The SEP will set out effective and transparent management of consultation and information
disclosure processes. The SEP will include a Grievance Redress Mechanism (GRM) and Inclusion
Plan as key components;
• A GBV/SEAH Action Plan, which will articulate the key risks and mitigation measures to address
GBV/SEAH/SEA risks, identification of GBV/SEAH Service Providers and reporting and referral
protocol in the event cases emerge, and communication and training requirements for
communities and all project related staff, including project workers, teachers, and school

31
administrators. It will also elaborate the adoption of mitigation measures including an

Accountability and Response Framework which will define the use of Code of Conduct (CoC) for
project workers, collaboration with local communities and GBV/SEAH-related service providers;
• Security Management Plan which will highlighting measures to minimize security risks such as
protection of project construction workers, if any;
• An ESCP, which will summarize the Borrower’s commitments and obligations to adopt and
implement these measures during project implementation; and
• A Resettlement Planning Framework (RPF), which will contain the protocols for voluntary land
donations and will be a key guide in terms of the processes and procedures for land acquisition
and resettlement, should this be necessary.
6.7 Environmental and Social Benefits

188. The implementation of subprojects under the overall Somalia education project as proposed will
have a number of social and environmental benefits. The social benefits include:
• inclusion of out-of-school children in schooling and improvements in learning will lead to a
larger number of students completing lower primary education;
• availability of larger number of cohorts of students transitioning into secondary schooling;
• improving girls’ participation in schooling by introducing incentives for increasing and
maintaining their enrolment in school will improve the gender situation in Somalia;
• encouraging recruitment of female teachers and prioritizing support for female teachers and
schools will ensure more women participation in the education sector in Somalia, with
positive downstream outcomes;
• inclusion of training modules in promoting girls’ education and creating safe, inclusive school
environments with specific attention to identifying and addressing violence, including gender-
based violence in schools, will ensure safer environments for children at school;
• employment opportunities for the community through construction, rehabilitation and
maintenance of the school infrastructure; and
• overall, the project will contribute towards the development of social cohesion and national
stability in the longer-term.
189. The project will have the following key environmental benefits:
• provision of improved, quality school infrastructure which will lead to less exposure of
school-going children to communicable diseases; and
• the formalized schooling environment will provide a basis for incorporating environmental
education and stewardship into the school curriculum, resulting in higher levels of
environmental stewardship.

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7. ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES
7.1 Environment and Social Risks Mitigation

190. Table 5 presents the mitigation measures proposed for negative environmental and social risks
and impacts anticipated for the Somalia education project.
191. Before the implementation of activities on the ground, the government of Somalia will oversee
the development of two Environmental and Social Management Standards per district. A standard (base)
ESMP will be developed with environmental and social mitigation activities for school construction, while
a different standard ESMP will be developed to take care of possible environmental and social risks
occurring during school operation and maintenance activities. Both ESMPs should be developed at the
initiation of the project. Sample TORs for an ESMP are provided in Annex 4.
192. The standard construction ESMP then will then modified/enhanced based upon the subproject
screening (and any other additional activity) and be used as a requirement for construction contractors
(including a base for their C-ESMP). Similarly, the standard operation phase ESMP will also be
modified/enhanced based upon the actual conditions (design, location, services, etc.) of an individual
school prior to the end of construction. These standard ESMPs will be presented to the World Bank for
review and clearance and will help ensure consistency and adequacy (completeness, details) among
individual schools/subprojects.
Table 7: Environmental and social risks and impacts mitigation

Potential Proposed mitigation measures
negative
environmental
and social risks
and impacts
CONSTRUCTION PHASE
Possible loss of terrestrial • Avoid environmentally sensitive areas when scouting for gravel extraction and backfill
biodiversity during land materials for school infrastructure works
clearing for construction • Contracts with contractors and suppliers will incorporate EHS requirements
or rehabilitation of • Contractors and PMUs to seek advice and clearance from appropriate government
classrooms, especially in agencies on the location of these sensitive environments
the southern regions of • Minimize removal of existing vegetation within the project site, else restore/rehabilitate
the country, including areas temporarily cleared of its vegetation
loss of natural vegetation • Use of appropriate indigenous species (tree/shrub/grass/cover crop) for rehabilitating
(both flora and fauna), temporarily disturbed/cleared/denuded areas
soil erosion and • Minimization of cleared area to only the land needed for the construction of the facilities
sedimentation, change of • Minimize clearance/cutting of indigenous and rare tree species
land use • Careful site selection avoiding sensitive and/or breeding areas
• Vegetative regeneration should be included as a condition in contracts for physical works
Air quality problems, • Ensure that project and contractor vehicles and other equipment undergo scheduled
including: preventive maintenance for proper exhaust emission
(a) increased levels of air • Construction truck drivers to observe established speed limits when working in the
pollution caused by the school set-up
operations of • Avoid burning of biomass as much as possible and use fire only in situations where this is
construction vehicles and least environmental damaging
heavy equipment in
schools and

33
(b) increased greenhouse

gases emission due to the
operations of
construction vehicle and
equipment
(c) Air quality impacts
also during school
operations due to poor
indoor air quality
Noise, dust and vibration • Dampening school construction sites at least once a day to reduce dust levels
from construction and • Use of modern, well maintained equipment fitted with noise enclosures
maintenance equipment • Strict controls of timing of activities (e.g., prohibition on night-time working)
• Observance of seasonal sensitivity (breeding and animal migration seasons)
Hazards from vehicular • Signage
traffic, especially from • Traffic calming measures where possible
construction traffic • Deploying signalmen when constructing for traffic coordination
Poor management of • Conform to international standards regulations governing civil works and other
occupational health and infrastructure development86
safety could lead to • Rest and recreational facilities and time should be provided for workers
accidents, injuries and • Adherences to comprehensive health and safety and risk management plans and
diseases, especially reporting system
among causal labourers • Availability of First Aid kits at the working sites and camps (including temporary camps)
hired from the • Training of construction workers in First Aid, fire prevention and PPE use
community in the area • Strict regulation of incidents register
(see also OHS measures • Arrange with nearby suitable hospitals or health clinics to treat project staff and workers
proposed in the LMP) that are sick or have been victims of accidents in the civil works sites or camps
• Contractors to develop an Emergency Response Plan for each school supported in the
project
• Orient ambulance drivers and emergency response teams on alternative routes, and
instruct traffic aides to assist the medical and emergency response teams when
necessary
• Establish a CoC to be followed by all construction supervisors and workers that will
include disciplinary action in case of gross violation of the guidelines
Land acquisition and • Comply with the RPF, including the following:
resettlement issues • Prepare and implement the land agreements, RPs and LPs subject to WB approval, for
(including physical and each of the sub-projects..
economic displacement) • Ensure all resettlement issues are resolved prior to the start of construction
•
Possible loss of cultural • PMUs to ensure that contractors carefully follow the protocols and procedures to protect
heritage during tangible and intangible cultural heritage (e.g., protection of community graves or no-
construction works disruption to cultural/religious events, and development of cultural heritage mitigation
plans as per ESS8)
Possible social tensions • Comply with the RPF
and conflicts as a result of • Prepare and implement a RP for each of the districts
activities such as • Ensure all resettlement issues are resolved prior to the start of construction
displacement, • Ensure continual community consultation, and ensure that disadvantaged groups are
marginalization of represented
community groups (see • All public consultation meetings are to be well documented
86
See ISO standards for civil works, which are codified here:
https://www.iso.org/files/live/sites/isoorg/files/store/en/PUB100317.pdf

34
also the LMP on • Ensure establishment of functioning GRM to promptly address community and worker
management of labour- grievances (see Annex 7 on sample GRM)
related risks) • Proper selection of construction workers, with priority given to hiring of qualified
members of project affected households, local residents and IDPs
• Holding of orientation to all construction workers on local customs and traditions
Negative social • Contractor to prepare and enforce a No Sexual Harassment Policy in accordance with
implications attributable national law where applicable
to labour influx • All workers and nearby communities and stakeholders will be educated on preventing
and responding to sexual harassment and GBV/SEAH ahead of any project related works
• The community within the vicinity of the school where construction will take place will
also be educated on GBV/SEAH and sexual offenses such as sexual harassment, rape and
defilement in the context of labour influx and the prevention and response measures
• Strategies such as male involvement will be employed in preventing and responding to
GBV/SEAH/SEA
• Partnerships will be established with relevant government agencies and NGOs to ensure
survivors of GBV/SEAH and sexual offenses access survivor centred services such as
medical care, psychosocial support, legal redress, safety, etc. as and when necessary
• Provision of gender disaggregated data, separate bathing, changing, sanitation facilities
for men and women
• Impose zero tolerance on sexual harassment, all forms of GBV/SEAH and discrimination
at all phases of the project
• Grievance redress mechanisms including non-retaliation should be set up for the workers
Discrimination against • Implement the Inclusion Plan included in the SEP
disadvantaged groups • Generate a comprehensive list of disadvantaged people and groups in the respective
Several disadvantaged community, and ensure this list is regularly updated
groups have been • Ensure a continued update disadvantaged groups
identified including • Monitor the implementation of the Inclusion Plan and make changes on need-basis
minority groups, IDPs, • Ensure that social accountability committee is established and its role known to all
nomadic pastoralists, project stakeholders
persons with disabilities, • Educate the community and the general public on the presence and function of the GRM
female headed
households and orphans
or children from single
headed households that
may not be actively
engaged in the project
activities and may not
benefit equally from the
interventions
GBV/SEAH/SEA • Comply with the provisions of the GBV/SEAH Action Plan (see Annex 8)
There are already high • Sensitize the school community – learners, teachers, management administrative staff
levels of GBV/SEAH that and workers on GBV/SEAH/SEA
might increase during • Provide training to all Project workers – direct, contract, supplies and community on
project implementation GBV/SEAH/SEA
since the project seeks to • Include GBV/SEAH/SEA provisions in the CoCs to be read, understood and signed by each
increase the number of project worker
female teachers and • Sensitize the communities living around the schools on GBV/SEAH/SEA
increase female students • Monitor and refine GBV/SEAH/SEA activities throughout the project implementation
to about 50% of the period
school population

35
There is risk of
GBV/SEAH/SEA during
the construction phase
Lack of or inadequate • Ensure that measures are put in place to identify and reach the disadvantaged groups and
public participation rural populations with project information in a timely manner
This will mainly arise due • Use communication channels that are accessible including the use of community radios
to the country’s fragility • Translate and disseminate information in local languages
and high levels of • Hold meetings with the beneficiary communities to update on the project and respond to
insecurity any communal concerns
• Identify and equip local leaders with information on the project more generally and the
GRM for further dissemination in their communities
Security threats • Refer to the Security Management Plan
The project will be • Coordinate with Ministry for Internal Affairs, which is responsible for security
implemented in rural and • Monitor the security of project workers and take actions based on the threats
remote areas that are
prone to security threats
from known and
unknown militia
OPERATION PHASE
Issues with potable water • Ensure that school construction designs include the installation of appropriate potable
supply water supply facilities
• School operation costs to take into account expenses related to provision of safe and
potable water for school children, teachers, and other stakeholders
Poor management of • Establish and maintain continuous liaison with the host communities including
OHS, as well as risks to sensitization on safety and health issues on construction sites
community health and • Install and maintain appropriate safety and warning signage in schools where
safety constructions works are in progress
• Use of local language and images for signage shall be encouraged
• Ensure that all potentially dangerous work areas have controlled access limited to
authorized persons only
• Ensure proper and adequate provision of sanitation and waste management facilities at
all construction sites
• Maintain a system of receiving and responding to any safety concerns by the
communities
• School CECs to be trained on EHS monitoring during school operations
Inefficient solid, • Preparation of waste management plan for each waste stream and implementation of
hazardous and liquid the waste hierarchy, as part of the Operation Phase ESMP
waste and e-waste • Prepare and implement a simple waste management plan subject to the concurrence of
collection and the respective PMUs in the FMS
management during • School CECs to provide garbage receptacles in strategic places within the school
operation and compound area, and regularly collect and properly deposit of these wastes in the
maintenance phases, designated disposal areas
leading to waste disposal • As much as practicable, reuse spoils that meets material specifications
problems, and resulting • When practicable, compost organic and degradable waste in suitable container, and
in polluting soils, surface provide this to interested farmers for their crop production
and shallow
groundwater, especially
during the rainy seasons
Outbreaks of diseases • Ensure that school designs adopted provide adequate learning environment free of pests
and poor indoor air and vermin, with ample ventilation provided
quality • Periodic fumigation activities, to be prescribed in the Operation Phase ESMP

36
• Ensure proper and adequate provision of sanitation and waste management facilities at
all schools
• Maintain a system of receiving and responding to any safety concerns by the
communities
GBV/SEAH/SEA • Comply with the provisions of the GBV/SEAH Action Plan (see Annex 8)
As the project seeks to • Sensitize the school community – learners, teachers, management administrative staff
increase the number of and workers on GBV/SEAH/SEA
female teachers and • Provide training to all Project workers – direct, contract, supplies and community on
increase female students GBV/SEAH/SEA
to about 50% of the • Include GBV/SEAH/SEA provisions in the CoCs to be read, understood and signed by each
school population, project worker
GBV/SEAH/SEA risks • Sensitize the communities living around the schools on GBV/SEAH/SEA
during operation of the
schools
LMP, SEP, SMP and RPF • The need to ensure that the project is complying with the provisions in these instruments
• Continue sensitizing the communities on the key provisions
• Ensure that the documents are updated based on the monitoring reports and project
amendments
7.2 Gender Mainstreaming and GBV/SEAH Action Plan
7.2.1 Gender Mainstreaming

193. The rights of women are protected in the Constitution of Somalia. Women have the right to
education, they are allowed to work, own property, hold public office, and receive inheritance. However,
there are risks that disparities between men and women may possibly occur during project
implementation, in areas such as exclusion from stakeholder engagement activities, priority in
recruitment of workers, differentiated pay rates for similar work done, safe working environment, health
and sanitary facilities in the work place, and exposure to GBV/SEAH/SEA.
194. To address such risks, the project will take a number of differentiated measures to include female
members in stakeholder engagement processes (including consultation events and grievance redress
committees); inclusion in the CECs and the social accountability committees, provision of job
opportunities in subprojects’ civil works; and fair working conditions (including provision of maternity
leave and nursing breaks where relevant, and sufficient and suitable toilet and washing facilities, separate
from men and women workers). These measures are also included in the LMP and SEP. Gender
mainstreaming can be incorporated into the project with lessons from the Africa Region Gender Action
Plan (GAP).87 This plan lays out the World Bank Africa Region’s strategy for addressing gender inequality.
The plan’s objective is to advance development for both men and women through operations grounded
in robust evidence and informed country dialogue.
7.2.2 Management of GBV/SEAH/SEA Risks

195. Given that GBV/SEAH in Somalia is a significant contextual challenge, a preliminary assessment of
project-related GBV/SEAH/SEA has been conducted during project preparation (based on the risk
assessment tool). Consequently, the project will adopt a robust approach to address potential
GBV/SEAH/SEA risks. Relevant mitigation measures to address these risks will be included in the ESMP as
follows:
87
See http://siteresources.worldbank.org/INTAFRICA/Resources/AFR-Gender-Action-Plan-FY13-17.pdf for more
details

37
• The CoC for all categories of project workers will have GBV/SEAH/SEA-related protections;
• Plan for sensitization/awareness raising for the community and intended training activities
for workers on CoC and GBV/SEAH/SEA provisions;
• Sensitize the school communities on GBV/SEAH/SEA – learners, teachers, management and
administration;
• Mapping and collaboration with GBV/SEAH service providers;
• A Reporting matrix that outlines key requirements for reporting cases if they arise and
measures to enable safe, ethical, survivor-centred response;
• An Accountability Response Framework that outlines how the PMUs/contractors/suppliers
will handle allegations, including related to investigation (in alignment with national
processes) and sanctions for potential perpetrators;
• Establishment of special channel/procedures for safe, confidential reporting of GBV/SEAH
incidents that connect to the project GRM and enable training of GRM operators on how to
respond to cases that come forward;
• GBV/SEAH requirements to be clarified in bidding documents (including requirements for
CoCs, training of workers, and how GBV/SEAH related costs will be covered in the contracts);
bid evaluation to include consideration for GBV/SEAH response proposals; and
• Make additional funds available to implement measures to address GBV/SEAH/SEA risks and
impacts that may arise during project implementation.
196. The project will also include provisions of capacity building and training of relevant stakeholders,
including contractors and project workers, in addition to capacity building for government partners.
GBV/SEAH/SEA risks should be monitored throughout project implementation through regular re-
assessment with the risk screening tool, particularly as new project locations are determined, and through
regular monitoring engagement. Contractors and primary suppliers who do not observe the GBV/SEAH
requirements will be debarred for a period of two years. This section is also presented in Annex 8 of this
ESMF and relevant provisions have been incorporated into the ESMP of each subproject.
7.3 Resettlement Policy Framework for the Somalia Education Project

197. Resettlement is broadly defined as the process by which those adversely affected are assisted in
their efforts to improve, or at least to restore their incomes and living standards. In general, resettlement
associated with Somalia education project is likely to be mainly associated with the acquisition of land for
the construction of schools. This would likely lead to the following impacts:
i. Loss of land-based livelihoods;
ii. Loss of access to communal resources and associated loss of livelihood;
iii. Loss of economic immoveable assets;
iv. Decreased income earning ability;
v. Food insecurity; and
vi. Unemployment.
198. Resettlement can also lead to the loss of access to communal resources:
i. Loss of land for grazing;
ii. Loss of access to water;
iii. Loss of medicinal plants; and
iv. Loss of trees for charcoal production and firewood.

38
199. These impacts can result in further indirect impacts, including the marginalization of the
population concerned, degradation of health standards, loss of access to resources for disadvantaged
communities such as pastoralists and minority groups, disturbance to the way of life of affected
populations, conflicts with host communities, and potential food shortages. Given the type of
investments, however it is not likely that resettlement as a result of the project will be extensive. The
requirements of the RPF will, however, still apply, as this does not depend on the scale or complexity of
the resettlement required.
200. Whenever and where the implementation of the Somalia education project results in physical and
economic displacement of persons and entities, a RP will be prepared and implemented after approval by
the PIU and the Word Bank.
7.4 Security Management Plan

201. A SMP will be developed to describe the procedures and protocols related to the security for the
project, and ensure that the security arrangements of the project are in line with the World Bank ESF. The
Plan will also describe the pre-requisite security arrangements (policies, resources and equipment) which
will be necessary before the implementation of the project, including those of the contractors and primary
suppliers before they are awarded service-delivery contracts. In addition, the Plan will further outline the
roles and responsibilities of each project partners - FGS MoCHE, FMS MoEs and other partners - in
managing and maintaining the security of the project beneficiaries, materials and equipment throughout
the implementation period.
202. Prior to the development of the SMP, wide consultations will be conducted under the leadership
of the MoECHE with security teams in the FGS and FMS and World Bank experts with experience in
developing SMPs. The SMP will be a stand-alone instrument.
7.5 Environmental and Social Monitoring of Contractors

203. The PIU and supervision consultants, with the support of municipal and district officers, will
monitor the contractors’ compliance on the following environmental and social issues for their
subprojects.88
• Safety: hours worked, recordable incidents and corresponding Root Cause Analysis (lost time incidents,
medical treatment cases), first aid cases, high potential near misses, and remedial and preventive
activities required (for example, revised job safety analysis, new or different equipment, skills training,
etc.).
• Environmental incidents and near misses: environmental incidents and high potential near misses and
how they have been addressed, what is outstanding, and lessons learned.
• Major works: those undertaken and completed, progress against project schedule, and key work fronts
(work areas).
• Environmental and social requirements: non-compliance incidents with permits and national law (legal
noncompliance), project commitments, or other environmental and social requirements including the C-
ESMP.
• Environmental and social inspections and audits: by contractors, engineers, or others, including
authorities - to include date, inspector or auditor’s name, sites visited and records reviewed, major
findings, and actions taken.
• Workers: number of workers, indication of origin (expatriate, local, non-local nationals, IDPs), gender, age
with evidence that no child labour or forced labour is involved, and skill level (unskilled, skilled,
supervisory, professional, management).
88
The following list should be used in a manner proportional to the size, risk and impacts of each sub-projects.

39
• Training on environmental and social issues: including dates, number of trainees, and topics.
• Footprint management: details of any work outside boundaries or major off-site impacts caused by
ongoing construction—to include date, location, impacts, and actions taken.
• Details of any security risks: details of risks the contractor/supplier may be exposed to while performing
the work - threats may come from third parties external to the project.
• Worker grievances (based on the workers’ grievance management system): details including occurrence
date, grievance, and date submitted; actions taken and dates; resolution (if any) and date; and follow-up
yet to be taken—grievances listed should include those received since the preceding report and those
that were unresolved at the time of that report and time taken to resolve grievances.
• External stakeholder grievances: grievance and date submitted, action(s) taken and date(s), resolution (if
any) and date, and follow-up yet to be taken—grievances listed should include those received since the
preceding report and those that were unresolved at the time of that report. Grievance data should be
gender-disaggregated.
• Major changes to contractor’s environmental and social practices.
• Deficiency and performance management: actions taken in response to previous notices of deficiency or
observations regarding E&S performance and/or plans for actions to be taken—these should continue to
be reported until municipalities/PMU determines the issue is resolved satisfactorily.
• Incidences of GBV/SEAH/SEA reported and handled through the referral systems, number of perpetrators
prosecuted.
7.6 Environmental and Social Liabilities of Contractors

204. Contractors and primary suppliers will be legally and financially accountable for any
environmental or social damage or prejudice caused by their staff, and thus are expected to put in place
controls and procedures to manage their environmental and social performance. A breakdown for the
cost of noncompliance for each mitigation measure will be enclosed in bidding documents (see Annex 9
on environmental stewardship for contractors). These will include:
• Mitigation measures to be included in the contract will be specified in the subproject ESMP;
• Deductions for environmental non-compliance will be added as a clause in the Bill of Quantities
(BOQ) section;
• Environmental penalties shall be calculated and deducted in each submitted invoice;
• Any impact that is not properly mitigated will be the object of an environmental/social notice by
Somali authorities;
• For minor infringements and social complaints, an incident which causes temporary but reversible
damage, the contractor/supplier will be given a notice to remedy the problem and restore the
environment;
• If the contractor/supplier fails to remedy the environmental impact during the allotted time, the
PIU will stop the work and give the contractor/supplier a notification indicating a financial penalty
according to the non-complied mitigation measure that was specified in the bidding document;
• All workers signed CoC;
• All worker’s grievances recorded and resolved;
• Through stakeholders’ engagement plans ensure that the process of hiring local labour is agreed
with all the stakeholders and clearly understood; and
• Human rights are observed for all the workers.

40
8. ROLES AND RESPONSIBILITIES OF THE IMPLEMENTING ENTITIES
8.1 Introduction
205. The successful implementation of the ESMF for the project depends on the commitment of the
different arms of government in Somalia, the education sector and related institutions, and the capacity
within the institutions to apply or use the ESMF provisions effectively, and the appropriate and functional
institutional arrangements, among others. This section describes the detailed roles and responsibilities of
the key institutions involved in the implementation of the ESMF by project components.
8.2 Overall Project Management

206. Overall project implementation and coordination will be led by the FGS MoECHE. The MoECHE
will collaborate with all State MoEs to implement the different components of the project.
207. The project will set up a single Project Steering Committee (PSC). The PSC, headed by the FGS
MoECHE with representatives from the FMS Ministries of Education including FMS MoE Ministers, one
representative from the Education Sectoral Committee (ESC) coordination body and one donor
representative. The PSC will provide strategic direction and guidance on high-level risk management and
monitoring. It will also facilitate effective relationships across the project. The PSC will meet annually. The
FGS MoECHE will have the latitude to make changes in the membership of the PSC and/or its terms of
reference (TOR) in consultation with State MoEs.
208. A Program Management Committee (PMC) will be established. The PMC will be headed by the
Director General, Federal MoECHE; or his/her designate. The PMC will include FMS Director Generals of
Education, Heads of relevant MoECHE departments and the PIU coordinator. Key responsibilities of the
PMC will include: (a) establish a platform for collaboration, management and decision making of the
project; (b) provide collaborative management of project activities, decision-making around co-design and
co-management of activities including the annual work plan and budget; (c) co-monitor project activities;
(d) conduct quarterly progress reviews; (e) make joint decisions on issues pertaining to implementation,
and (f) ensure open communication and maximum accountability. The PMC will meet once a quarter, but
it can be convened by the FGS DG as and when required.
209. A dedicated PMU will be formed at FGS level. The PMU will be headed by a Project coordinator
and include a small team of experts: (a) financial management specialist (FMS); (b) procurement specialist;
separate environmental and social specialists and a GBV/SEAH specialist (c) M&E specialist; and (d)
communication specialist. The project coordinator will coordinate the implementation of day-to-day
administration of the project activities and will conduct quarterly reviews and a total of five in-country
reviews to ensure the effective and timely implementation of project components and activities. The PMU
team will be responsible for developing, updating, validating and disseminating the standardized
construction phase and operation phase ESMPs. The PIU coordinator will also work closely with the RCRF
Project III PIU team to ensure coordination of the education activities. The management structure is
illustrated in Figure 2.
210. The PIU’s at FMS level will include a project manager and a full time social/GBV/SEAH specialists
and a part time environmental specialist. These staff will be supported by officers at the district level. The
will be a social specialist based in the districts where construction is taking place in order to closely work
with the contractors and communities in addressing social issues. A communications officer will also be
placed at the FMS level to be responsible for all communication activities in close coordination with the
officer at the Republic level. The PIUs will be responsible for day-to-day project management activities,

41
including monitoring and reporting on project progress to all the relevant stakeholders (please see the
table on Information Disclosure). For this purpose, the PIU will organize, at regular intervals, workshops
involving representatives of all stakeholders to present project progress and seek stakeholder input. The
costs for all these activities are budgeted under the Component 4 and may be adjusted on need basis.
211. The implementation of this project will be vested with the MoECHE at the Federal level, the MoE
at the State level and the communities at the local level. It is notable due to capacity gaps inherent at all
implementation levels and the need to synergize with ongoing activities, the PIU will coordinate its
activities with other partners such as development partners, NGOs and CBOs in the delivery of some of
the interventions. Table 5 presents a synopsis of the responsibilities and partners per component.

42
Table 8: Leadership of various sub-components and activities

Component Sub-component Implementer Potential partners /collaborators
1. System building: The focus 1.1: Strengthening MoECHE -FMS MoE
will be on establishing and government’s stewardship -Development partners
strengthening systems at the role and policy formulation -NGOs/CBOs
FGS and the FMS level to 1.2: Implementation of MoECHE -FMS MoE
successfully implement the national sample-based -Development partners
government’s ESSP and student learning assessment -NGOs/CBOs
enhance sustainability of systems
investments in the sector 1.3: Strengthening monitoring MoECHE -FMS MoE
and evaluation -Development partners
-NGOs/CBOs
2. Expansion of access to 2.1: Constructing and Federal State -MOECHE
quality schooling for the furnishing new schools MoE -CECs
disadvantaged: The focus will -Development partners
be to provide out-of-school -NGOs/CBOs
children from disadvantaged -Ministry of Public works,
backgrounds with access to Infrastructure and Reconstruction
good quality schools -National office for Environment
2.2 Recruiting and paying the Federal State -MOECHE
salaries of teachers MoE -CECs
-Development partners
-NGOs/CBOs
-Ministry of Public works,
Infrastructure and Reconstruction
-Ministry of Energy and Water Services
-National Treasury
2.3 School grants to the newly Federal State -MoECHE
established schools to meet MoE -CECs
recurrent expenditures -Development partners
-NGOs/CBOs
-National Treasury
2.4 Incentivizing non-State Federal State -MOECHE
schools to expand access to MoE -CECs
the most disadvantaged -Development partners
children -NGOs/CBOs
-Ministry of Labour and Social Affairs
3. Enhanced instruction Development of a 2-year MoECHE -Ministry of Posts, Telecom and
quality: This component will Teachers Professional Technology
leverage the high levels of Development Program (TPDP) -FMS MoE
connectivity in Somalia to - blended teacher training -Development partners
enhance the quality of
education services
4. Project Management The project will build capacity MoECHE -FMS
at all levels of implementation -Development partners
FGS, States and community
levels

43
8.3 Responsibility for the ESMF

212. The PMU will provide overall responsibility for safeguards’ due diligence, and compliance
monitoring of the project. With regards to safeguards, the PMU will:
• Employ separate and qualified full-time environmental and social specialists and a
GBV/SEAH specialist;
• Ensure compliance with World Bank ESS and other relevant country laws as contained in this
ESMF;
• Ensure that E&S requirements are included in all documents and guidelines;
• Ensure that E&S requirements are included in the bidding documents and due diligence and
monitoring is carried out with contractors by the safeguards staff at FMS level;
• Undertake effective preparation, review, approval and implementation of GBV/SEAH action
plan, security management plan, labour management procedures, sub-project ESMPs, based
on the provisions in this ESMF.
• Be responsible for the preparation, updating, validation, and dissemination of standardised
ESMPs for the construction and operational phases of schools in the project.
FGS Safeguards Officers

213. The Safeguards officers at the PMU will specifically:
• Provide capacity building and technical oversight for all social specialists at FMS level.
• Provide guidance and templates for all E&S processes, monitoring and reporting;
• Review all ESMPs, reports and documents prepared by PIU specialists to ensure compliance
to the World Bank ESS;
• Screen all subprojects for E&S risks and approve checklists and statutory forms for
environmental and social screening;
• Ensure that the project design, specifications and budget adequately reflect the
recommendations of the ESIAs/ESMPs;
• Co-ordinate application, follow up processing and obtain requisite clearances and approvals
from the World Bank for the Contractor ESMPs submitted by the individual subprojects;
• Prepare regular monthly/quarterly/semi-annual and annual progress reports on their
responsibilities;
• Develop, organize and deliver appropriate E&S safeguards related training courses for the
PMU staff, contractors, local government/community representatives and others involved in
the project implementation;
• Review and approve the contractors’ ESMPs (C-ESMPs) using this ESMF as a guide;
• Liaise with the contractors, the supervision consultants, third party monitors, primary
suppliers and the PI/PMUs/MDAs on implementation of the ESMPs;
• Liaise with various Government agencies on environmental, resettlement and other
regulatory matters;
• Continuously interact with relevant NGOs/CBOs and community groups;
• Establish dialogue with the affected communities and ensure that the environmental and
social concerns and suggestions are incorporated and implemented in the project;
• Ensure the implementation of all plans developed for the project including the LMP, SEP
(that contains the Inclusion Plan and the GRM), ESMPs, GBV/SEAH Action Plan, and SMP;
• Review the performance of the project in terms of the progress in E&S safeguards, through
an assessment of the periodic internal monthly and quarterly environmental and social
monitoring reports; provide summaries of the same and initiate necessary follow-up actions;
and

44
• Provide support and assistance to the Government MDAs and the World Bank during Project
Review Missions.
214. The FMS PIU’s will oversee safeguards’ due diligence, and compliance monitoring of the project
at FMS level. With regards to Safeguards, the PIU will:
• Employ one social specialists/GBV officer and one part time environmental officer at FMS
level;
• Screen all subprojects for E&S risks and approve checklists and statutory forms for
environmental and social screening;
• Prepare regular monthly/quarterly/semi-annual and annual progress reports on their
responsibilities;
• Review and approve the contractors’ ESMPs (C-ESMPs) using this ESMF as a guide;
• Liaise with the contractors, the supervision consultants, third party monitors, primary
suppliers and the PI/PMUs/MDAs on implementation of the ESMPs;
regulatory matters;
• Ensure the implementation of all plans developed for the project including the LMP, SEP
(that contains the Inclusion Plan and the GRM), ESMPs, GBV/SEAH Action Plan, and SMP;
and
Review Missions.
• Provide monthly reports on E&S compliance to the PMU safeguards specialists.
FMS Safeguards Officers

215. The Safeguards officers at the PIU will specifically:
• Screen all subprojects for E&S risks;
• Review all ESMPs, reports and documents prepared by environmental and social consultants
to ensure compliance to the World Bank ESS;
• Prepare regular monthly/quarterly/semi-annual and annual progress reports with statutory
requirements;

45
• Review and approve the Contractors’ ESMPs using thus ESMF as a guide;
• Liaise with the Contractors, primary suppliers and the PI/PMUs/MDAs on implementation of
the ESMPs;
regulatory matters;
• Ensure the implementation of all plans developed for the project including the LMP, SEP (that
contains the Inclusion Plan and the GRM), ESMPs, GBV/SEAH Action Plan, and SMP;
and
Review Missions.

46
8.4 Roles and Responsibilities of the MOECHE

216. The MoECHE is the lead implementing agency of the project. Its roles and responsibilities are as
enumerated below:
• Take the lead in reviewing of draft ESMPs for the government, receiving comments from
stakeholders during public hearing of the project,
• Provide overall leadership during public consultations with critical education sector
stakeholders, in order to gain their support/cooperation/consensus in established policy
direction; and
• Ensure that the Somalia education project implementers comply with all relevant environmental
laws and policies.
8.5 World Bank Roles and Responsibilities

217. The World Bank will:
• Provide guidance on the compliance to Bank’s ESS;
• Perform compliance monitoring of the project to ensure that the ESS are complied with and
conduct regular project review missions;
• Maintain an oversight role, review and approve the project’s ESMF, and environmental and
social assessment instruments such as any ESIA or ESMPs of sub-projects, if any;
• Conduct regular supervision missions to check on the performance of the project and assess its
compliance to agreed grant covenants;
• Recommend measures for improving the performance of the project PMUs; and
• Recommend the holding of appropriate training activities intended to improve the capacity of
PCU and PIU as necessary.
8.6 Updating the ESMF

218. This ESMF will be used for screening of sub-projects and as a guide for the preparation, review
and approval of environmental assessment instruments (ESIA and ESMP). It will also be a reference in the
implementation of the subprojects and their respective ESMPs. Since there may be new developments,
guidelines or national legislations issued after its (ESMF) approval and posting on the World Bank website,
the ESMF may need to undergo updating from time to time.
8.7 Disclosure of Safeguards Instruments

219. This ESMF has been prepared in consultation with the relevant stakeholders in Somalia. Copies of
this ESMF and other safeguard instruments developed later (including GBV/SEAH Action Plan, RPF and
ESMPs), prepared for the subprojects to be financed under the project, should be consulted upon
disclosed in compliance with relevant country regulations and the World Bank ESSs. A summary of the
safeguards instruments will be translated into Somali language and disclosed in all project sites. It will also
be disclosed in two daily newspapers for 21 days, or as required by country laws, while the World Bank
will post the approved document on its InfoShop.

47
9. SAFEGUARDS CAPACITY NEEDS ASSESSMENT AND TRAINING PLAN
220. Once the FGS and FMS safeguards specialists are on board, a capacity assessment and
implementing plan will be developed, possibly by an independent consultant. Given there are very few
experienced safeguards specialists in Somalia particularly at FMS level, it is likely that capacity will have
to be developed from scratch.
221. The training and capacity building plan (summarized in Table 9) will include general ESF training
and project implementation facilitated by World Bank consultants and the RCRF senior social specialist
and other government specialists and consultants. Specialist training and capacity building support may
also need to be carried out by independent capacity building specialists and agencies including for
contractors and social accountability committees and GRM.
Table 9: Planned capacity building activities

Session Timeframe For whom
E&S requirements for Once Potential implementing partners.
contractors requests for
proposals are
issued
E&S requirements for MoE Once FGS and PCIU and FMS PMT staff including social and
and action planning FMS staff are environmental specialists, GBV/SEAH specialist, M&E
in place. specialist, communication specialists
GRM Month 1 All direct workers including social and environmental
specialists, GBV/SEAH specialist, M&E specialist,
communication specialists
GBV/SEAH Month 2 All direct workers including social and environmental
LMP and code of conduct Month 3 All direct workers including social and environmental
OHS requirements Month 4 All direct workers including social and environmental
Inclusion plan Month 5 All direct workers including social and environmental
E&S reporting Month 6 Social and environmental specialists
Monitoring of E&S Month 7 Social and environmental specialists, M&E specialists
requirements
Virtual tools for E&S Month 8 Social and environmental specialists, M&E specialists
monitoring
Other sessions as required

48
10. MONITORING PLAN
10.1 Regular monitoring and inspection
222. The goals of monitoring are to measure the success rate of the activities, determine whether
activities have managed negative impacts, and whether further interventions are required or if monitoring
is to be extended in some areas. The goal of inspection activities is to ensure that subproject activities
comply with the plans and procedures laid out in the ESMF and in activity-specific instruments.
223. Both the PMU and PIUs will have responsibilities for project-related environmental and social
monitoring and implementation as laid out in this ESMF, as well as the SEP, LMP, RPF, GBV/SEAH Action
Plan and SMP. The Project Coordinator of the PMU will bear the overall responsibility for the
implementation of the environmental and social mitigation measures, as well as for monitoring and
inspections for compliance. The Environmental and the Social Specialists in the PMU will address the day-
to-day tasks in regard to the implementation of the ESMF and associated instruments. The PIU managers
and PIU safeguards staff have responsibility for day to day monitoring and capacity building of contractors
E&S requirements. The supervision consultant will be responsible for monitoring the contractors ESMP
implementation. GIS tagged tools e.g. kobotoolbox will be used to monitor construction and E&S
measures on a day to day basis so that pictures of the sites, construction and log books can be sent to the
FMS and FGS at regular intervals. Independent Verification Agents (IVA) will also include environmental
and social risk mitigation measures in their project monitoring activities.
224. The ESMF is the overall document that guides the development of site specific ESMPs. All
implementers will be responsible for their own site/activity specific screening, impact assessments,
development of site/activity-specific ESMPs, monitoring of impacts, and administration of mitigation
measures in regards to their respective sub-component activities. They further commit to integrate
stakeholder inputs into their regular monitoring and reporting activities. All implementers are committed
to report all screening results (see reporting format in 2), results of ESIAs, site/activity-specific ESMPs, to
the PIU.
225. The PMU Environmental and Social Specialists will assess the compliance of all implementers’
activities against the ESMF and their subsequent ESMPs, and will report possible non-compliance to the
Project Coordinator of the PMU. Indicators are identified in both documents, and used as a baseline for
assessing progress on implementation. The PIU will also independently conduct its own monitoring,
verification and inspection of the activities of all implementers to ensure they are in compliance with this
ESMF. Monitoring indicators will depend on specific activity contexts. Performance will be integrated into
quarterly reports to the WBG (see Annex 10).
226. The World Bank will supervise and assess the environmental and social performance through
review of the biannual monitoring reports and through site visits where possible.89 A summary of the key
E&S aspects to be covered during project reporting is provided in Annex 10.
227. The GRM will further help track complaints and effectiveness of interventions, including those
with environmental and social impacts. Furthermore, Independent Verification Agents (IVAs) will be
deployed to monitor overall project implementation, including the implementation of environmental and
89
Frequency will be determined by the need but expected to be more frequent at early stages of project
implementation

49
social risk mitigation measures. The IVAs will report non-compliance to the PMU and directly to the World
Bank.
228. Upon completion of the Project, the PMU shall undertake an assessment of the success of the
ESMF and include relevant information in the Implementation Completion Report (ICR). This ICR will be
followed by the Bank’s own ICR. If either of these assessments reveals that any key objectives of the ESMF
were not achieved, follow-up measures shall be developed to remedy the situation. This is also applicable
for site-specific ESMPs.
229. Implementation (work plan) progress shall be reported by the contractors to the FMS PIU, and
verified by the PIU through regular project site visits. The PIU in turn will keep the PMU and the WB
properly updated on implementation progress. It is also expected that there will be a supervision
consultant to supervise activities in the implementation of E&S instruments.
10.2 Incident and Accident Reporting

230. Incident reporting will follow the process indicated in Figure 3.
Figure 4: Incident reporting process
231. Incidents should be categorized into ‘indicative’, ‘serious’ and ‘severe’. Indicative incidents are
minor, small or localized that negatively impact a small geographical area or a small number of people
and do not result in irreparable harm to people or the environment. A ‘significant’ incident is one that
causes significant harm to the environment, workers, communities, or natural resources and is complex
or costly to reverse (see Annex 11 for World Bank incident classification guide). A ‘severe’ incident causes
great harm to individuals, or the environment, or presents significant reputational risks to the World Bank.
232. Severe incidents (an incident that caused significant adverse effect on the environment which
affected communities, the public or workers, e.g. fatality, GBV/SEAH, forced or child labour) will be
reported within 24 hours to the PIU and the World Bank. Further guidance on reporting of serious and
indicative incidents is provided in Annex 11.
233. Where grievances are of sexual nature and can be categorized as GBV/SEAH or child protection
risk, the implementer has to handle the case appropriately, and refer the case to the GBV/SEAH referral
system, defined in the GBV/SEAH Action Plan. Contractors and primary suppliers who do not adhere to
the GBV/SEAH provisions will be debarred for 2 years.

50
11. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN AND BUDGET
234. This section describes the specific E&S due diligence provisions necessary to avoid, minimize, or
mitigate project activities with potential risks, and monitor their outcomes. This process also includes
identification of institutional responsibilities (implementation, supervision, monitoring and evaluation,
and reporting) along the lifetime of the interventions, timing of actions, how these provisions will be
monitored and reported on, and identification of budget requirements. The objectives of the ESMP are:
i. To identify measures and plans to prevent, reduce, mitigate and/or compensate adverse impacts
and enhance positive impacts; including the environmental, health and safety aspects of the
project’s interventions/activities, risks and negative impacts of the project;
ii. To provide an estimation of the budgetary costs for implementing the mitigation measures
alongside the implementing agencies responsible for addressing project impacts;
iii. Develop environmental and social monitoring plan, corresponding to measures proposed in the
mitigation plan, for project activities/sub-projects and the implementation of mitigation
measures with estimated cost. The monitoring plan has included the parameters to be monitored,
methods to be used, frequency of measurements, responsibility and budget;
iv. To identify the responsibilities and capacity assessment for each of the participating
implementing agencies responsible for addressing project impacts; description of institutional
arrangements and reporting procedures; and
v. To prepare clear ESMP in such a manner that environmental and social requirements e.g.
mitigation measures and monitoring plan related to project activities (sub-projects) could be
incorporated in the bidding/contract documents.
235. This section describes the specific E&S risk management due diligence provisions necessary to
avoid, minimize, or mitigate project activities with potential risks, and monitor their outcomes. This
process also includes identification of institutional responsibilities (implementation, supervision,
monitoring and evaluation, and reporting) along the lifetime of the interventions, timing of actions, how
these provisions will be monitored and reported on, and identification of budget requirements. The
objectives of the ESMP are:
i. To identify measures and plans to prevent, reduce, mitigate and/or compensate adverse
impacts and enhance positive impacts; including the environmental, health and safety aspects
of the project’s interventions/activities, risks and negative impacts of the project;
ii. To provide an estimation of the budgetary costs for implementing the mitigation measures
alongside the implementing agencies responsible for addressing project impacts;
iii. Develop environmental and social monitoring plan, corresponding to measures proposed in
the mitigation plan, for project activities/sub-projects and the implementation of mitigation
measures with estimated cost. The monitoring plan has included the parameters to be
monitored, methods to be used, frequency of measurements, responsibility and budget;
iv. To identify the responsibilities and capacity assessment for each of the participating
implementing agencies responsible for addressing project impacts; description of institutional
arrangements and reporting procedures; and
v. To prepare clear ESMP in such a manner that environmental and social requirements e.g.
mitigation measures and monitoring plan related to project activities (sub-projects) could be
incorporated in the bidding/contract documents.

51
Table 10: ESMP and Indicative Budget – Somalia Education Project
# Key Activities Potential E&S Proposed Mitigation Measures Indicators for Means for Frequency Responsibi Cost (USD)
Risks and Impacts monitoring Monitoring of lity
Monitorin
g
Project Planning, construction and equipping of schools
Construction of Inadequate • Identify disadvantage groups in each of the # of #Meeting Continuou Social USD 180,000
schools consultations participating districts. disadvantaged reports s specialist
with local • Establish and maintain continuous liaison with the groups per -Site visits
communities and communities including disadvantaged groups to districts
other sensitize them on the project objectives and design. # of meetings
stakeholders • Use innovative communication means to reach the held
communities with information on the project. # of participants
• Establish GRM structures in the communities that structured
would sensitize the communities on the project along
GRM. vulnerability
• Maintain a system of receiving and responding to
any project concerns by the communities
Construction of Land and Comply with the RPF, including the following: -Land -Site visits Monthly Social USD
schools resettlement • Ascertaining land ownership and claims before donation/endo -Project specialist 100,000
issues commitments to construct a school wment documents
• Get agreement from residents and users of the agreements
land and relevant departments on the use of -RPs for each
land for the new schools. subproject
-List of people
• Preparation and implementation of RPs subject
displaced and
to WB approval, for each of the sub-projects
resettled
with resettlement requirements
# of land related
• Ensure all resettlement issues are resolved prior complaints
to the start of construction captured
• Require contractors to give preferential hiring to through the
qualified members of project affected households GRM
Construction of Localized noise • Selecting equipment with lower sound power levels Recorded cases -Site visits Monthly Environm This will be
schools and vibration e.g. the use of hand drilling machines of complaints -Document ent Expert part of the
by the project review

52
Monitorin
g
• Installing suitable mufflers on engine exhausts and workers and contracts for
compressor components in cases where the service community construction
provider uses generators members
• Post safety signage including “men/women at work”
signs, prominently displayed
• Provide fit to work PPEs (ear plug/earmuffs) for all
workers involved in the areas with elevated noise
levels
• Coordinate with the office users/staff as to
determining timing and more importantly what
specific noise controls and mitigations may be
needed at the site
• Installing acoustic enclosures (sound nets) for
equipment casing radiating noise i.e. generator
• The contractor should use equipment that is/are in
good working condition and are periodically serviced
• Dampening the soil where possible to reduce dust
vortexes and soil erosion
Construction of Fire hazards • Provide fire hazard training to construction workers - # of fire - Site visits Continuou Environm Part of
schools • Install fire hydrants extinguishers - PIU reports s during ent Expert contracts
installed - Third-party constructi for
• Provide fire extinguishers
- # of fire monitor on constructio
• Designate areas as “assembly points” hydrants reports n – costs
• Establish, where possible, live fire breaks in form of installed will be
appropriate vegetation - # of assembly included in
points the
designated contracts

53
Monitorin
g
Construction of Dust Emission • Suppress dust during construction by water spraying # of complaints -Site visits Monthly Environm Part of
schools and dampening where necessary on dust -Document ent Expert contracts
• Practice good general housekeeping at the work site; emissions review for
sweep off the drilled-out materials - constructio
Photography n – costs
• Post safety signage including “men/women at work”
will be
(or “work in progress”) signs
included in
• Provide fit to work PPEs for all workers involved in the
the renovation and installation activities contracts
Construction of Open pits • Ensure that all quarries are registered -Quarry -Site visits Monthly Environm Part of
schools following • Contractors should commit to backfilling the open certificates -Document ental contracts
extraction of pits before handing over the sites -Agreements review Expert for
construction with contractors - constructio
materials for # of complaints Photography n – costs
school on open will be
construction can quarries included in
result in injuries, the
especially for contracts
children
The pits can also
become breeding
grounds for
mosquitoes and
other vermin
Construction of Outbreak of • Spacing out school-going children # no of - Site visits Twice a MoECHE Fumigation
schools pests and vermin • Periodic fumigation of school infrastructure fumigation - Inspection year will be
events conducts reports included in
- Third-party school
monitor activities
reports supported
by school
grants

54
Monitorin
g
Construction of Generation of • The contractor shall ensure provision of waste bin at # of waste bin Site Visit Monthly Environm Part of
schools solid waste the site to handle waste generated at the site Project ent Expert contracts for
• Efficient use of materials to as much as possible progress construction
avoid and minimize waste production reports – costs will
review be included
• Ensure waste are recycled/reused before opting to
in the
dispose
contracts
• Use of durable, long-lasting materials that shall not
need to be replaced often
• Ensure waste is collected and disposed in
accordance to Somali Government Regulations
Construction of Occupational • The contractor shall provide the workers with the -Accident logs -Site visit Monthly Environm Part of
schools health and safety: required PPE and enforce on use at all times while at -First Aid Kits -Document ent & contracts
slip/fall, elevated the work sites -Fire reviews Social for
noise, dust and • The equipment used in the works should be extinguishers - Expert constructio
electrocution routinely serviced to ensure proper and safe photography n – costs
equipment functionality will be
included in
• Carry out Job Risk Assessment (analysis of hazards
the
likely to occur and precautions need to be
contracts
undertaken) before executing the construction
• Use of safety signage “MEN/WOMEN AT WORK” to
warn contractor workers and visitors to worksites
• Provision of adequate signage and communication
of risk to workers and communities
• Training and use of temporary fall prevention
devices, such as rails, full body harnesses and energy
absorbing lanyards
• Electrical works should be performed by trained and
qualified experts
• Ensure that electrical equipment is properly
connected before switching on sockets

55
Monitorin
g
• In case on any spillage at working areas, this should
be cleaned off immediately, anti-slip hazard warning
when mopping floors should be provided to reduce
on chances on slip and falls
Spread of • Train all staff on the signs and symptoms of COVID- # of reported Site Visits Monthly Social In
infectious 19, how it spreads, how to protect themselves and cases at site Document specialist, component
diseases - in the need to be tested if they have symptoms # availability of review CPHO 4 budget
particular COVID- • Use existing grievance procedures to encourage IPC strategies Grievance/ and SEP –
19 reporting of co-workers if they show outward for hand and incident log USD
symptoms, such as ongoing and severe coughing water hygiene, 100,000
with fever, and do not voluntarily submit to testing use of PPE
-Training
• All workers and visitors accessing work sites every
reports
day or attending meetings shall be subjected to
rapid Covid-19 screening which may include
temperature check and/or other vital signs
• Mandatory provision and use of appropriate PPE
such as masks shall be required for all project
personnel including workers and visitors
• Provide hand wash facilities, water and soap,
alcohol-based hand sanitizer and mandate their use
on entry and exit of the project site and during
breaks
• Avoid congregation of more than 15 workers at one
location. Where more than one persons are
gathered, maintain social distancing of at least 2
meters
• Restriction of the number of people accessing the
work areas
• Fumigation of offices and work areas
• Train all workers in respiratory hygiene, cough
etiquette and hand hygiene

56
Monitorin
g
• Train cleaning staff in effective use of PPE, cleaning
arrangement and procedures and disposal of waste
generated from the MoE offices
Spread of • Sensitize workers and communities on HIV/AIDS # of sites with Site Visit s Monthly Environm Comp 4 –
infectious prevention and management communication Document ent & USD 50,000
diseases - in • Place signage at the work sites/schools on HIV/AIDS posters/ review Social
particular prevention information on Expert
HIV/AIDS HIV/AIDS
• For site camps: provide signage for workers on
# of
HIV/AIDS at all the camps
communities
• Provide HIV testing facilities at worksites those with reached with
many workers information on
HIV/AIDS
# of people who
know about
where to get
HIV/AIDS
services
Labour disputes • Fair terms and conditions shall be applied for # of reported -Site visits Monthly Social Comp 4 –
workers (guided by relevant laws and WB ESS2) cases of -Workers’ Reports Expert social
• The project shall facilitate the development and disputes by GRM specialists
operationalization of GRMs for project workers workers -Document
(direct workers and contracted workers) to promptly review
address their workplace grievance (as provided for in
the LMP)
• The project shall respect the workers’ rights of
labour unions and freedom of association
Insecurity – • All work sites and camps shall be protected by # of reported Site visits Quarterly E&S Comp 4 –
construction sites security personnel insecurity SMP reports Expert, E&S
• All visitors to construction and camp sites (as incidents, Project Security specialists
appropriate) will be required to fill a visitors’ form # of training documents personnel
providing all personal details and purpose of the visit offered project involved
workers in the

57
Monitorin
g
• A data file with information regarding the visitor will # of workers project
be recorded and kept by the MoECHE trained activities
• Security induction must be done to all project
workers
• The SMP, developed for this project, will be
implemented by all parties involved in the project
implementation
Traffic Hazards • Use of competent drivers with defensive driving # of accidents -Field visits Quarterly -E&S Comp 2
techniques recorded, -Document Experts and 4
• MoECHE and MoEs’ at the district level shall #Vehicle review -SMPC
regularly inspect vehicle safety and maintenance inspection -
reports Contracto
• All fleet handling deliveries shall observe speeds
-Trip rs
limits to a maximum of 80km/h out of major towns
Management -Drivers
but 30kms in towns
Plans
• All drivers and loaders should sign the CoC
• Drivers (especially going to high insecurity areas)
should follow guidance on safe emergency driving
Operational Phase of the Project
School operation Security threats • The security personal shall be oriented on good # of reported -Field visits Quarterly E&S Comp 4 –
and maintenance conduct and required to sign a code of conduct as cases at site, -Document Experts, E&S
per the SMP -Types of work review Security specialists
• All students and workers shall be oriented on site and camp - Personnel
security matters protocols photography
Trainings
• The SMP shall be shared with the key project teams
offered to staff
(school managers and MoE officers) on a need-to-
know basis
• All visitors to school be required to fill a visitor form
providing all personal details and purpose of the visit
• Every school administrator shall keep a record of all
his employees and workers and their personal
details including phone numbers and address.

58
Monitorin
g
• Regular security induction and drills must be done
for all staff and students
• A search of personal luggage shall be performed by
the guards at the access control point to ensure no
access of all the prohibited items into the project
site
Potable water • Ensure that school construction designs % of school Field visit Quarterly Env. Comp 2 –
supply problems include the installation of appropriate potable children with TPM reports Specialist part of
water supply facilities access to safe Safeguards constructio
• School operation costs to take into account potable water monitoring n contracts
expenses related to provision of safe and reports and
potable water for school children, teachers, maintenan
and other stakeholders ce will be
covered by
school
grants
Poor management • Establish and maintain continuous liaison with # of ESHS Field reports Half yearly CECs Comp 2
of ESHS risks, as the host communities including sensitization on incidents and 4 –
well as risks to ESHS risks and mitigation measures occurring USD
community health • Use of local language and images for ESHS 180,000
and safety signage shall be encouraged
• Ensure proper and adequate provision of
sanitation and waste management facilities at
all schools
• Maintain a system of receiving and responding
to any safety concerns in the schools by the
communities
• School CECs to be trained on EHS monitoring
during school operations
Inefficient solid, • Preparation of waste management plan for each # of waste Field reports Half yearly PMU Comp 2 –
hazardous and waste stream and implementation of the waste management TPM reports
liquid waste and e- hierarchy, as part of the Operation Phase ESMP plans

59
Monitorin
g
waste collection • Prepare and implement a simple waste Part of
and management management plan subject to the concurrence of Volume of total constructio
during operation the respective PMUs in the FMS waste n contracts
and maintenance • School CECs to provide garbage receptacles in generated
phases, leading to strategic places within the school compound
waste disposal area, and regularly collect and properly deposit % of waste
problems, and of these wastes in the designated disposal areas collected
resulting in
• As much as practicable, reuse spoils that meets
polluting soils,
material specifications
surface and
shallow • When practicable, compost organic and
groundwater, degradable waste in suitable container, and
especially during provide this to interested farmers for their
the rainy seasons crop production
Outbreaks of • Ensure that school designs adopted provide # fumigation Safeguard Half yearly MoECHE Comp 2
diseases and poor adequate learning environment free of pests events reports PMU
indoor air quality and vermin, with ample ventilation provided conducted School
• Periodic fumigation activities, to be prescribed progress
in the Operation Phase ESMP reports
• Ensure proper and adequate provision of
sanitation and waste management facilities at
all schools
• Maintain a system of receiving and responding
to any safety concerns by the communities
Project Discrimination • The project will implement the inclusion plan #Procedure of Field visits Quarterly Social Comp 4 -
beneficiaries – and exclusion of contained in the SEP project Document Expert E&S
pupils disadvantaged • The employment of project workers will be based on targeting review specialists
groups the principle of equal opportunity and fair
treatment, and there will be no discrimination with
respect to any aspects of the employment
relationship

60
Monitorin
g
• Hold sensitization meetings on resources planning
and conflict resolution mechanisms
• Institutionalization of inclusion of all categories in
processes and decision making
• There will also be enough and suitable toilet and
washing facilities, separate from men and women
workers, boy youths and girl youths as the
community cultures demand
• The contracts with third parties will include non-
exclusion requirements which will also be part of the
monitoring system
• All stakeholders will be informed and sensitized on
the GRM and available channel for redress.
Project Sexual • Sensitization of project workers and the MoE staff # of reported Field Visit Quarterly Social Comp 4 -
beneficiaries Exploitation and and benefiting communities; cases Document Expert E&S
Abuse (SEA) • Instituting separate Grievance Redress Committee to # of cases review specialists
handle cases among others sexual abuses, handled to
conclusion
• Involving local authorities and police where
Existence of SEA
appropriate in handling sexual abuses; and
Plan
• All project staff should be trained against SEA
awareness programs for workers and the beneficiary
community.
Spread of • Carry out periodic HIV/AIDS awareness for workers # HIV/ AIDS Field visits Quarterly Social Comp 4 -
HIV/AIDS and STIs and staff, campaign done Document Expert, E&S
• Carry out voluntary HIV/AIDS testing for workers; #Training record review CBO specialists
and available
• Workers should sign the CoC and abide by its
provisions for HIV/AIDS awareness and prevention.
Selection of Compromised • Generate criteria for selection of female teachers to -Template for Field visits Quarterly Social Comp 4 -
female teachers selection process be engaged by the project selecting the Project Expert E&S
to be recruited, female teachers reports specialists
trained and

61
Monitorin
g
deployed to • Disclose up to the community level the selection -GRM template
schools criteria distribution
• Disseminate the GRM process to the lowest level to -Site visits
ensure that community members know where to -Project
channel to and how to channel their grievances documents
#Grievances on
teacher
selection
Forced • Provide a form for recruited female teachers to #Completed Field visits Quarterly Social Comp 4-
recruitment of indicate their consent consent forms Project Expert E&S
female teachers • Disseminate the GRM process to the lowest level to #Grievances reports specialists
ensure that community members know where to related to the GRM reports
channel to and how to channel their grievances recruitment
process
• Monitor the process and identify any challenges
-Teachers’
among the female teachers
performance
Training of 6000 Compromised • Ensure the development of a criteria for selection of -Selection Training Quarterly E&S Comp 4-
teachers (blended selection process teachers to benefit from the training criteria procedures Experts, E&S
training) • Disclose, at the county level, information on those -No. of teachers specialists
selected for training trained
GBV/SEAH/SEA/S • Monitor and report on the behaviour of project # of reported Field Visit Quarterly Social Comp 4-
H workers at all levels; cases Document Expert E&S
• Ensure the people engaged in project activities # of cases review specialists
understand the GBV/SEAH referral pathway; handled to
conclusion
• Ensure all learners and community members have
# Existence of
access to the GRM contacts; and
GBV/SEAH/SEA
• All workers should sign the CoC (see the LMP). Plan
Selection of Lack of or • Ensure that measures are put in place to identify and -Record of -Field visits Quarterly Social Comp 4-
project inadequate public reach the HUTLCs and rural populations with project Public -Document Expert E&S
beneficiaries participation and information; participation review specialists
consultation -Meetings
minutes

62
Monitorin
g
• Use communication channels that are accessible to # of complains
marginal populations including use of community recorded
radios, translating information in local languages;
and
• Identify and equip local leaders with information on
the project more generally and the GRM for further
dissemination in their communities.
Project Inadequate • Undertake a training needs assessment for the -Training needs -Field visits Quarterly Project USD 50,000
implementation capacity MoECHE, MoE and implementing partners assessment -Review of Coordinat
- Environment • Identify suitable and tailor-made courses for the report project or
- Social technical teams -Training reports
- GBV/SEAH protocols
• Facilitate capacity building efforts for the team
- Communicati -List of staff
on • Monitor the performance and provide continuous trained
- Monitoring technical support to the PIU
and
evaluation
Project Inadequate • Standardization of inventory management tools and Clear procedure Field Visit Quarterly Project Comp 4-
Implementation and/or inefficient mechanisms for opening bid, Document Coordinat E&S
management of • Checking needs for support in all schools more so Adherence to review or specialists
logistics those in remote areas the
Implementation Social
• Empowering implementing partners to take over the
manual specialist
supply of inputs for the activities for which they are
responsible
• Independent responsibility of each partner for its
activities (logistical support: accommodation, means
of communication and IT, transport, etc.)
• Strengthening the package of shared logistics
services for efficient response
Spread of • Train all school staff and school-going children on # of reported Field Visit Quarterly Environm Comp 4-
Infectious Disease the signs and symptoms of COVID-19, how it cases at site, ent E&S
– COVID-19 specialists

63
Monitorin
g
spreads, how to protect themselves and the need to # availability of Document and Social
be tested if they have symptoms IPC strategies review, and Expert,
• Ensure that the schooling infrastructure (including for hand and photography CPHO
chairs and desks) are well spaced apart, and are water hygiene,
frequently sanitised use of PPE
• Use existing grievance procedures to encourage
reporting of co-workers if they show outward
symptoms, such as ongoing and severe coughing
with fever, and do not voluntarily submit to testing;
• Mandatory provision and use of appropriate
Personal Protective Equipment (PPE) such as masks
shall be required for all project personnel including
suppliers, workers and visitors;
• Provide hand wash facilities, water and soap,
alcohol-based hand sanitizer and mandate their use
on entry and exit of the schools and during breaks;
• Avoid concentration of more than 15 persons at
• Fumigation of offices, work areas, store and project
vehicles delivering food to the schools;
• Train all workers in respiratory hygiene, cough
etiquette and hand hygiene; and
• Train cleaning staff in effective use of PPE, cleaning
arrangement and procedures and disposal of waste
generated from the MoE offices /schools.
Operation & Generation of E- • Procure electronic devices from credible -Clearly labelled Field Visit Annually Project USD 80,000
Management of Waste with manufactures to avoid purchasing second hand, E-waste bins / Document Coordinat
ICT Equipment associated toxic refurbished or obsolete devices with a short shelf receptacles review, or
chemicals leading life or already categorized as E-Waste; -Warrant for the Photography
to Air Pollution, • Recycle all E-waste through the licensed e-waste ICT Equipment Environm
pollution of recycling companies; -Temporary E- ent expert
ground water waste collecting at PIU
• Return Obsolete devices to the supplier depending
facility at
on warranty period/agreement;

64
Monitorin
g
• Establish an E-Waste Temporal Collection Centre at MoECHE and
MoE; including collection bins/receptacles; other offices
• Contract the services of NEMA Licensed E-Waste -Training
Firm to collect E-wastes from MoE and dispose of in records for E-
an environmentally sound manner Waste handling,
-E-Waste
• Conduct awareness and sensitization targeting the
disposal
users of the electronic devices to ensure that they
Certificates
engage in best practice for E-waste management;
-Waste License
and
for contracted
• The contractor for the installation of the ICT Firm
equipment shall adhere to the provisions in the E-
Waste Management Plan (Annex I).
TOTAL COST USD
740,000

65
ANNEXES
ANNEX 1: WORLD BANK ENVIRONMENTAL AND SOCIAL STANDARDS
ESS1: Assessment and Management of Environmental and Social Risks and Impacts*90
This Standard sets out the Borrower’s responsibilities for assessing, managing and monitoring environmental
and social risks and impacts associated with each stage of a project supported by the Bank through
Investment Project Financing (IPF), in order to achieve environmental and social outcomes consistent with
the Environmental and Social Standards (ESSs).
ESS2: Labour and Working Conditions*

This Standard recognizes the importance of employment creation and income generation in the pursuit of
poverty reduction and inclusive economic growth. Borrowers can promote sound worker-management
relationships and enhance the development benefits of a project by treating workers in the project fairly
and providing safe and healthy working conditions.
ESS3: Resource Efficiency and Pollution Prevention and Management*

This Standard recognizes that economic activity and urbanization often generate pollution to air, water, and
land, and consume finite resources that may threaten people, ecosystem services and the environment at
the local, regional, and global levels. This ESS sets out the requirements to address resource efficiency and
pollution prevention and management throughout the project life-cycle.
ESS4: Community Health and Safety*

This Standard addresses the health, safety, and security risks and impacts on project-affected communities
and the corresponding responsibility of Borrowers to avoid or minimize such risks and impacts, with
particular attention to people who, because of their particular circumstances, may be vulnerable.
ESS5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement*

Involuntary resettlement should be avoided. Where involuntary resettlement is unavoidable, it will be
minimized and appropriate measures to mitigate adverse impacts on displaced persons (and on host
communities receiving displaced persons) will be carefully planned and implemented.
ESS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources*

This Standard recognizes that protecting and conserving biodiversity and sustainably managing living natural
resources are fundamental to sustainable development and it recognizes the importance of maintaining core
ecological functions of habitats, including forests, and the biodiversity they support. ESS6 also addresses
sustainable management of primary production and harvesting of
living natural resources, and recognizes the need to consider the livelihood of project-affected parties,
including Indigenous Peoples, whose access to, or use of, biodiversity or living natural resources may be
affected by a project.
ESS7: Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities

This Standard ensures that the development process fosters full respect for the human rights, dignity,
aspirations, identity, culture, and natural resource-based livelihoods of Indigenous Peoples/Sub-Saharan
African Historically Underserved Traditional Local Communities. ESS7 is also meant to avoid adverse impacts
90
The asterisk sign (*) denotes that this Standard is applicable in the Somalia education project

66
of projects on Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local

Communities, or when avoidance is not possible, to minimize, mitigate and/or compensate for such impacts.
ESS8: Cultural Heritage*

This Standard recognizes that cultural heritage provides continuity in tangible and intangible forms between
the past, present and future. ESS8 sets out measures designed to protect cultural heritage throughout the
project life-cycle.
ESS9: Financial Intermediaries (FIs)

This Standard recognizes that strong domestic capital and financial markets and access to finance are
important for economic development, growth and poverty reduction. FIs are required to monitor and
manage the environmental and social risks and impacts of their portfolio and FI subprojects, and monitor
portfolio risk, as appropriate to the nature of intermediated financing. The way in which the FI will manage
its portfolio will take various forms, depending on a number of considerations, including the capacity of the
FI and the nature and scope of the funding to be provided by the FI.
ESS10: Stakeholder Engagement and Information Disclosure*

This Standard recognizes the importance of open and transparent engagement between the Borrower and
project stakeholders as an essential element of good international practice. Effective stakeholder
engagement can improve the environmental and social sustainability of projects, enhance project
acceptance, and make a significant contribution to successful project design and implementation.
More information on these Standards is available at

http://pubdocs.worldbank.org/en/837721522762050108/Environmental-and-Social-
Framework.pdf#page=53&zoom=80

67
ANNEX 2: INDICATIVE SCREENING CHECKLIST

No ITEM DETAILS
INTRODUCTION
1 Project Name Somalia Education for Human Capital Development Project
2 Project Location
3 Project Description (brief) including
risk classification and
recommendations about additional ES
studies/assessments
4 Does the Project require any: Yes no If yes, extent in ha.
Reclamation of land, wetlands
Clearing of grazing lands
Felling of trees
5 Minimum land area required for the
proposed development (ha)
6 Available total land area within the
identified location (ha)
7 Expected construction period
8 Responsible contact person, contact
Information
9 Present land ownership State: Private: Other:
10 Are there Multiple land claims or
conflict over land
11 Lack of community support YES No
12 Is there a Village Development Yes No

Committee or Community Education
Committee or other representative
community structure?
13 How effective and representative is
the CEC/VDC etc?
14 How are they selected and/or
appointed?
15 Are there minority clans in the area?
16 Are there IDPs in the area? If

Yes, how do you describe the how the
host community treat them?
17 What survivor centric health,

psychosocial, and legal services exist in
the area?
18 Are there any cases of forced or child

labour for constructions?
ENVIRONMENTAL IMPACT AND MITIGATION/ENHANCEMENT DURING CONSTRUCTION PERIOD

68
Impacts H91 M92 L93 N/A Mitigation/Enhancement

19 Soil erosion, soil subsidence, and
sedimentation
20 Water pollution
21 Potable water supply issues
22 Noise pollution
23 Solid waste generation
24 Liquid or e-waste waste generation
25 Traffic hazards
26 Loss of vegetation cover
27 Habitat loss or fragmentation
28 General disturbance to animal behaviour
29 Interference with normal movement of
animals
30 Irreversible/irreparable environmental
change
31 Air pollution
32 Existing environmental liabilities (e.g.,
waste materials disposed on site, soil
contamination)
ENVIRONMENTAL IMPACT AND MITIGATION/ENHANCEMENT DURING OPERATIONAL PERIOD
33 Potable water supply issues
34 Waste disposal issues
35 Indoor air quality
36 Traffic hazards (transportation)
37 Outbreaks of pests and diseases
38 Outbreaks of communicable diseases
39 Other potential hazards (including fire,
droughts, etc.)
40 Consider adjoining land uses and activities
(i.e., what is immediately next to the
school site, and whether there are any
sensitive receptors (homes, health clinics,
religious facility) nearby
COMMUNITY ENGAGEMENT
41 Number and nature of Number of Nature of Participants

public consultation Type of Meeting
Meetings Participants Male Female
meetings conducted so
far
91
High
92
Medium
93
Low

69
CONTACT DETAILS OF OFFICIALS AND RECOMMENDATIONS

Name of the person completing form
Designation and contact information
List of team members
Signature and date
Name of officer who checked this form

Designation and contact information
Remarks
Signature and Date

70
ANNEX 3: GENERIC CONTENTS FOR SITE-SPECIFIC SUB-PROJECT ESMP
INTRODUCTION
Purpose of the ESMP
There is need to carry out an environmental and social impact assessment which will have to comply with
the environmental procedures of ……………….and with the environmental guidelines of the financing
institutions, World Bank. The main objective of this study is to develop an Environmental and Social
Management Plan (ESMP) for planned project activities within the that will provide the decision makers in
the Ministry of Education, Federal Republic of Somalia, with sufficient information to justify acceptance,
modification or rejection of the proposed sub-projects (“schools”) for financing and implementation.
The purpose of the Environmental and Social Management Plan (ESMP) is to define and reach an
agreement with the World Bank concerning mitigation/enhancement, monitoring, consultative and
institutional strengthening measures to be undertaken during sub-project implementation and
operations. The ESMP format shall be flexible to ensure the integration of project specific mitigating,
enhancing and monitoring requirements. For instance, the ESMP shall integrate or at least refer to any
initiatives, such as resettlement plans, that contribute to enhance the project environmental or social
performance.
In addition, the ESMP format shall permit adjustments and revisions to reflect new developments and
findings along project implementation and operations. The ESMP's scope and level of details shall be
proportional to the number and complexity of the measures required to ensure the project's
environmental and social sustainability. The following components constitute the minimal contents of an
ESMP.
General Information
Estimated Starting date of implementation
Project completion date
Date of operation
Period covered by the plan
Objectives of the ESMP

This section shall specify that the ESMP aims to bring the project into compliance with applicable Somalia
national environmental and social legal requirements and the World Bank’s Environmental and Social
Framework. Other objective of the ESMP is to outline the mitigating/enhancing, monitoring, consultative
and institutional measures required to prevent, minimize, mitigate or compensate for adverse
environmental and social impacts, or to enhance the sub-project beneficial impacts. It shall also address
capacity building requirements to strengthen environmental and social capacities if necessary.
Project context
The ESMP shall briefly describe project activities and major environmental and social components that will
likely be affected positively or negatively by the project. The information provided shall be concise as the
project’s ESMF covers in detail this topic. In fact, for this section, cross-references to the ESMF are
recommended. Moreover, the context section shall outline existing interrelations between ecological and
social processes. These interrelations among components shall be mentioned to be taken into account in
the impact assessment and the development of mitigation/enhancement measures.
Beneficial and Adverse Impacts

71
This section shall focus on beneficial impacts that can be enhanced to improve the project’s environmental
and social performance as well as on adverse impacts that require mitigation measures to be minimized
or compensated. The impact description in the ESMP shall be brief and refer to the project’s ESMF for
further details.
Enhancement and Mitigation Program

This section shall propose feasible and cost-effective measures to address the impacts previously defined,
in order to accrue project benefits (enhancement measures) or to reduce potentially adverse
environmental and social impacts to acceptable levels (mitigation measures). Each measure shall be
described in detail, providing all technical information required for its implementation (design, equipment
description and operating procedures, as appropriate).
Monitoring Program
A monitoring program aims to ensure that mitigation and enhancement measures are implemented, that
they generate intended results and that they are modified, ceased or replaced when inappropriate.
Moreover, it allows to assess compliance with national environmental and social policies and standards as
well as with the international policies and guidelines. A monitoring program shall include two parts:
surveillance and monitoring activities.
Surveillance activities: The surveillance aims to ensure that the proposed mitigation and enhancement
measures are effectively implemented during the construction and operational phases.
Monitoring activities: These activities consist in measuring and evaluating the project impacts on some
environmental and social components of concern and to implement remedial measures, if necessary. The
program shall define as clearly as possible the indicators to be used to monitor the mitigation and
enhancement measures that need to be assessed during project implementation and/or operation. The
monitoring program shall also provide technical details on monitoring activities such as methods to be
used, sampling of schools, frequency of measurements, detection limits, and definition of thresholds that
will signal the need for corrective actions.
Where it is required, monitoring should address both emission and ambient levels of pollutants and solid
waste generated by the support schools, where these may be detrimental to human health. World Bank
guidelines presents general ambient quality standards, the figures presented are ambient guidelines only.
As Somalia has no national ambient air quality standards, the Bank’s standards can be used to substitute
for the country’s non-existent quality standards.
Consultations
The implementation and monitoring of some mitigation or enhancement measures may require that
consultative mechanisms be used. In such cases, the ESMP shall first identify for which measures
consultations will be undertaken as well as the goals and expected outcomes of these consultations. Then
the ESMP shall specify the target groups, appropriate consultative processes, consultation frequency,
reporting methods and result disclosure procedures.
Complementary initiatives
The ESMP shall integrate or at least refer to all initiatives that are proposed to improve the project
environmental or social performance. As the project’s ESMF includes such initiatives, these shall be briefly
presented in this section. Moreover, these complementary initiatives shall be taken into account in
determining the responsibilities, institutional arrangements, cost estimates and implementation schedule.

72
Responsibilities and Institutional Arrangements

The implementation of enhancement and mitigation measures as well as the completion of the monitoring
program require to clearly establish responsibilities among the project implementation team at FGS and
FMS levels. Ultimately the Ministry of Education at the FGS level is responsible for monitoring and
reporting on achieved results, but it may need to be assisted in the implementation of the ESMP by the
FMS project team and external consultants. Consequently, the ESMP shall identify the responsibilities of
the World Bank, the implementing ministry and other stakeholders in applying the ESMP, particularly the
monitoring program. In addition, the ESMP shall propose support to the implementing unit if it has
insufficient capacities to fulfil its obligations. This support could be provided through various means
including technical assistance, training and/or procurement.
Estimated Cost
This section estimates the capital and recurrent cost associated with the various proposed measures
(enhancement and mitigation), the monitoring program, consultations, complementary initiatives and
institutional arrangements. The financing for implementing the ESMP shall be part of project financing.
Implementation Schedule and Reporting
The ESMP shall include an implementation schedule taking into account all activities related to the
proposed measures (enhancement and mitigation), the monitoring program, consultations,
complementary initiatives and institutional arrangements. Moreover, the implementation schedule shall
be developed by phases and in co-ordination with the overall project implementation plan. To ensure early
detection of critical environmental and social conditions and to provide information on the mitigation
progress and results, reporting deadlines shall be specified in the implementation schedule and reporting
procedures shall be presented in this section.

73
ANNEX 4: PROTECTION OF CULTURAL PROPERTY

Cultural property includes monuments, structures, works of art, or sites of significance points of view,
and are defined as sites and structures having archaeological, historical, architectural, or religious
significance, and natural sites with cultural values. This includes cemeteries, graveyards and graves.
Under ESS 8, there will be aspects of important, intangible cultural heritage, which need consideration,
especially in the ancient city of Mogadishu. Under Somalia education project, for example, the
construction should not disturb events or ceremonials in nearby mosques or Islamic schools.
The initial phase of the proposed Somalia education project interventions pose limited risks of damaging
cultural property since projects will largely consist of small investments in school infrastructure and
other relatively minor public works. Nevertheless, the following procedures for identification, protection
from theft, and treatment of discovered artefacts should be followed and included in standard bidding
documents.
Chance Find Procedures

Chance find procedures will be used as follows:
• Stop the construction activities in the area of the chance find;
• Delineate the discovered site or area;
• Secure the site to prevent any damage or loss of removable objects. In cases of removable
antiquities or sensitive remains, a night guard shall be present until the responsible local
authorities and the Ministry in charge of Department of Archaeology and Museums take over;
and
• Notify the supervisory Engineer who in turn will notify the responsible local authorities and the
Ministry of Culture immediately (within 24 hours or less);
Responsible local authorities and the Ministry in charge of Department of Archaeology and Museums
would be in charge of protecting and preserving the site before deciding on subsequent appropriate
procedures. This would require a preliminary evaluation of the findings to be performed by the
archaeologists of the Department of Archaeology and Museums (within 72 hours). The significance and
importance of the findings should be assessed according to the various criteria relevant to cultural
heritage; those include the aesthetic, historic, scientific or research, social and economic values.
Decisions on how to handle the finding shall be taken by the responsible authorities and the Ministry in
charge of Department of Archaeology and Museums. This could include changes in the layout (such as
when finding an irremovable remain of cultural or archaeological importance) conservation,
preservation, restoration and salvage.
Implementation for the authority decision concerning the management of the finding shall be
communicated in writing by the Ministry in charge of Department of Archaeology and Museums.
Construction work could resume only after permission is given from the responsible local authorities and
the Ministry in charge of Department of Archaeology and Museums concerning safeguard of the heritage
These procedures must be referred to as standard provisions in construction contracts, when applicable.
During project supervision, the Site Engineer shall monitor the above regulations relating to the
treatment of any chance find encountered are observed.
Relevant findings will be recorded in World Bank Project Supervision Reports and Implementation
Completion Reports will assess the overall effectiveness of the project’s cultural property mitigation,
management, and activities, as appropriate.

74
ANNEX 5: SUGGESTED TEMPLATE FOR SCHOOL CONSTRUCTION ESMP (IN ADDITION TO CONTRACTOR C-ESMP)
Please annex CESMP, voluntary land donation/agreement documentation, screening form, community meeting minutes
1. Proposed sub-project: ______________________________ Village/district/state: __________________________________
2. Overview of the school site location and key features within 200m of works (to understand impacts)_________________________________________
_________________________________________________________________________________________________________________________
3. Population resident on or regularly using the land/sub-project or claimants of the land:

Village/ (facility users can be by No of individuals resident or regularly using No. of direct users of the sub-project Number of people from that
people resident more than one the project area for their livelihood area (individuals) village/consulted on the sub-project (design,
location) siting, social and environmental impacts)
4. Has there been any conflict over this land? If so please describe, what measures the project will take to ensure that it does not exacerbate conflict.
________________________________________________________________________________________________________________________________________
____________________________________________________________________________________________________________________
5. Consultations with the community on the site selection (to ensure broad agreement, ownership and risk identification and mitigation)
Date Village Total No. of No. of No. of minority group or IDP Main concerns Challenges in
number of women youth representatives (please raised and how they consulting with
people specify group/s) will be addressed people e.g.
involved migration,
conflicting event,
insecurity
Initial
discussions
Safeguards
screening
meeting

75
Other –
meetings
(specify)
6. Environmental and social impacts and mitigation measures identified by the community (only put those not captured in the ESMP)
Social and environmental impacts of sub- Mitigation measures Costing Time frame Responsible agency
project
7. Has a safeguards field visit been undertaken to the site? Y/N Date of visit: ________________________Title of visiting officer:______________________
8. Is the contract signed by the contract explicitly binds the contractor to incorporate the CESMP in his operations?
9. Has the ESMP been incorporated into the collective and individual contract for the works; and is a safeguards compliance report required before payment?
_____________________________________________________________________________________________________________________________________
10. Type of land required for sub-investment and documentation:

a. Government land Title deed/confirmation document attached? YES/NO/EXPLANATION
b. Community land Voluntary land donation form and community minutes attached? YES/NO/EXPLANATION
c. Private land Voluntary land donation form and conversion document attached? YES/NO/EXPLANATION
11. Voluntary land donation:

a) How many people either live on or regularly use the land where the project will be implemented (including those who might use it as a drought fall back
area) by location and how many and who agreed to the voluntary donation of this land for this public facility? ____________________________

76
b) Explain how the requirements for voluntary land donation have been met (and attach minutes, VLD form and signed participants list):
Requirements for voluntary land donation Explanation and evidence
1. The land required to meet technical project criteria must be identified in
conjunction with the affected community?
2. What are the likely impacts of proposed activities on donated land and how were
these explained to the community?
3. Area of land compared to area owned (no more than 10 percent of the area of any
holding can be donated). %
4. How will the users and occupiers of the land benefit from this sub-project?
5. What are the conditions of benefiting from this sub-project – connection fees,
service charges etc.
6. How was the community made aware that refusal was an option and confirmed in
writing that they are willing to proceed with the donation? (e.g. at the consultation
and in the voluntary land donation document)
7. What evidence is there that the act of donation was undertaken without coercion,
manipulation, or any form of pressure on the part of public or traditional authorities
(e.g. photos/videos of community consultation etc.)?
8. Do all the users and occupants of this land understand that by donating this land it
may be gazetted as public land
9. How was it explained that they have a right to compensation for land and the
available compensation options (in-kind compensation, land for land compensation
or cash compensation, and the implications of cash compensation?
10. Were monetary or non-monetary benefits or incentives requested as a condition for
the donation and were these provided?
11. How do you know that the land being donated will not reduce the remaining land
area to a level below that required to maintain the donor’s livelihood at current
levels and will not required the relocation of any household?
12. Will any structures be moved or any access to land be limited as a result of the sub-
project (describe structures and locations)?
13. If so, how will they be compensated/facilitated and/or their livelihoods restored?
14. How was consent provided by all individuals occupying or regularly using the land?
15. Was there anyone who did not give agreement and why?
16. How was it established that the land to be donated was free of encumbrances or
encroachment and was it registered in an official land registry?

77
17. All users and occupants of the land have genuinely understood (in local language
with sufficient time) and agreed that all conditions for voluntary land donations
have been met (refer to consultations above and attach minutes)
12. GRM: Has the GRM process and contact information for focal points been disseminated to the community? If so, how and to whom (numbers and groups). If Not,
when will this be done?
13. Have the SAC members been introduced to the community and their functions explained to the locals?
___________________________________________________________________
________________________________________________________________________________________________________________________________________
14. GBV/SEAH: Has awareness been carried out on GBV/SEAH, service providers and confidential survivor centric GBV/SEAH complaints mechanism? If so, how and to
whom (numbers and groups). If not, when will this be
done?_________________________________________________________________________________________________
__________________________________________________________________________________________________________________________________
15. Describe the involvement and inclusion of women and minority groups or nomadic pastoralist representative in management?____________________________
_______________________________________________________________________________________________________________________________________

78
ANNEX 6: CONSULTATION MEETINGS HELD WITH KEY STAKEHOLDERS
CONSULTATION MEETING ON SEP: Date 3/12/2020 Time: 10 am – 12 pm

List of participants for the IDA project stakeholder meeting Meeting Mode: Zoom
No Name Institution
1. Shweta Sandilya UNICEF
2. Mengistu Koricha Save the Children
3. R. Drake Warrick Creative Associates
4. William Babumba DRC
5. Suleiman Ahmed DRC
6. Ahmed Dirshe Concern WW
7. Dr. Mohamed Hassan Nur Mogadishu University
8. Dahir Hassan SIMAD University
9. Dr. Salad Jazeera University
10. Abdirashid Mohamed SCC
11. Dahir Shire DAN
12. Abdikadir Isse Farah FENPS
13. Abdifitah Aden Abdi WARDI
14. Abdisahal Mohamed Himilo Foundation
15. Aweis Haji Hassan Ayuub NGO
16. Beryl Auma World Vision
17. Adan Mohamed EFASOM
18. Mohamed Idle AET
19. Mohamud Ahmed Rage MOECHE
20. Abdi Gashan Egal MOECHE
21. Suaad Abdulle MOECHE
22. Abdinur Jama MOECHE
23. Abdifitah Mohamed ESC Coordinator
24. Shueyb Youb ARC
25. Mohamed Abdulkadir Nur MOECHE
26. Abdirizak Mohamed MOECHE
27. Ousman Abdullahi World Bank
28. Abdirahman Zeila World Bank
29. Huma Ali Waheed World Bank
30. Farhiya Farah World Bank
31. Mahdi Mohamud Abdi EFASOM
32. Ahmed Hassan Mohamed Himilo Foundation
33. Ismail Mohamed Ali GPE Coordinator
34. Ahmed Hassan Yusuf DG-MOECHE
35. Raymond S. Kirwa World Bank
36. Mary Amuyunzu-Nyamongo World Bank
37. Ahmed Kormeere MOECHE
38. Ismail Abdi MOECHE

79
CONSULTATION MEETING ON ESMF AND RPF: Date 9th February 2021, 9am -12pm
List of participants for the IDA project stakeholder meeting Meeting Mode: Zoom
No. Name Title & Institution

1. Salad Abdulle MoLSA – Director of Planning
2. Mohamud Rageh MOECHE- Director of Planning
3. Abdifitah Abdi Mohamed Education Sector Coordinator
4. Vanessa Tilstone Social specialist, World Bank
5. Shweta Sandilya UNICEF
6. Haile Gashaw UNICEF – WASH
7. Huma Waheed World Bank -TTL
8. Khalif Hassan Dalmar Director of Environment & Climate Change – OPM
9. Jose M. Bendito Chief of Social Policy, UNICEF Somalia.
10. Mohamed Dhugad Alight (formerly ARC) Area Rep
11. Ahmed Yusuf Director General of Environment, Office of the Prime Minister.
12. Dahir Shire Head of operations and Programs- DAN
13. Fouzia Warsame DCOP of USAID Bar Ama Baro
14. Peter Quamo UNICEF Education
15. Musa.I Dugow SOS Children's Village Somalia
16. Mohamud Sheikh Abdi INISKOY Program Manager Baidoa Base
17. Abdihakin Abdullahi Jama FENPS
18. Joy Khangáti CARE
19. Mahad KAARSHE WFP
20. Farhia Mohamud Somali Public Agenda
21. Oscar Boije UNICEF
22. Ismail Abdi MoECHE- TA Teacher Development
23. Lugard Ogaro Mercy Corps, Director of Programs
24. Mohamed Dahir Moalim Social Safeguard Specialist, RCRF, South West State
25. Mohamed Moge Mohamed Social Specialist, RCRF, Jubaland
26. Mandeq Abukar Concern Worldwide
27. Abdinasir Abdullahi DG. Ministry of Energy and Water Resources, Galmudug
28. Hussein Hassan RCRF Project Manager SWSS
29. Christophe Hodder UN Environmental Advisor
30. Mohamed-Abdullahi MARDO
31. Mohamed Hared Juba Foundation
32. Dr. Abdiwali Ahmed DG Galmudug MoH
33. Yarow Mohamed Abdi Juba Foundation
34. Siyad Abdirahman Rural education and agriculture development organization READO
35. Christophe Hodder IO/UNEP, Environment Advisor
36. Naima Nor Abdi FENPS
37. All Aweys Ayuub NGO
38. Shair Luli GBV consultant World Bank Somalia
39. Paul Owora World Vision Somalia
40. Adam Mohamed National Coordinator of EFASOM
41. Mahdi Mohamud MoECHE
42. Abdishakur Isse Hashi Social specialist RCRF Galmudug State
43. Ahmed Hussein Iman Project Coordinator, SOMALI NON-STATE ACTORS (SONSA)
44. Mohamed Abulkadir Nur MOECHE
45. Abdirahman Zeila Environment Specialist, World Bank
46. Jaafar Muhammed Social Specialist, World Bank
47. Mohamed Mohamud Directorate of Environment and Climate Change, Office of the PM
48. Peggy Ayako Kwendo World Bank
49. Abdinur Ahmed Jama MOECHE
50. Amin Mukhar Ahmed DG- Hirshabelle Ministry of Education

80
51. Ahmed Nur DG- Galmudug Ministry of Education

52. Abdi Ibrahim TIDES NGO – Executive Director, Garowe, Puntland
53. Abdiaziz Nur Mohamed MOECHE – TVET & Non-formal Director
54. Mohamed Mohamud (DECC-OPM)
55. Mohamed Civil Society Platform

81
ANNEX 7: GENDER MAINSTREAMING AND GBV/SEAH ACTION PLAN
Gender mainstreaming
The rights of women are protected in the Constitution of Somalia (including in the particular constitution of
Somalia and that of Puntland). Women are given the right to education, allowed to work, own properties, hold
public office, and receive inheritance. However, there are risks that disparity between men and women may
possibly occur in the Somalia education project in the course of its implementation, in areas such as exclusion
from stakeholder engagement activities, priority in hiring, pay rates for similar work done, safe working
environment, health and sanitary facilities in the work place and office and others.
To address such risks, the project will take a number of differentiated measures to include female members in
stakeholder engagement processes (including consultation events and grievance redress committees);
provision of job opportunities in subprojects’ civil works; equal pay and fair working conditions (including
provision of maternity leave and nursing breaks where relevant, and sufficient and suitable toilet and washing
facilities, separate from men and women workers). These measures are also included in the LMP and SEF.
Gender mainstreaming can be incorporated into the project with lessons from the Africa Region Gender Action
Plan (GAP).94 This plan lays out the World Bank Africa Region’s strategy for addressing gender inequality. The
plan’s objective is to advance development for both men and women through operations grounded in robust
evidence and informed country dialogue.
Management of GBV/SEAH risks

While incidence of GBV/SEAH in Somalia is a significant contextual challenge, preliminary assessment of
project-related Sexual Exploitation and Abuse (SEA)/GBV/SEAH (based on the risk assessment tool) has been
conducted during project preparation. Given the significant GBV/SEAH risks the context of pervasive insecurity,
the project will adopt a robust approach to address potential GBV/SEAH risks. Relevant mitigation measures to
address these risks will be included in the ESMP as follows:
1) Code of conduct (CoC) for project workers with SEA/GBV/SEAH-related protections;
2) Plan for sensitization/awareness raising for the community and intended training activities for
workers on CoC and SEA provisions;
3) Mapping and collaboration with GBV/SEAH service providers;
4) A Reporting and Response Framework that outlines key requirements for reporting cases if they
arise and measures to enable safe, ethical, survivor-centered response;
5) An Accountability Framework that outlines how the PMU/PIU/contractor/primary suppliers will
handle allegations, including related to investigation (in alignment with national processes) and
sanctions for potential perpetrators;
6) Establishment of special channel/procedures for safe, confidential reporting of GBV/SEAH
incidence that connect to the project GRM, and enable training of GRM operators on how to
respond to cases that come forward;
7) GBV/SEAH requirements to be clarified in bidding documents (including requirements for CoCs,
training of workers, and how GBV/SEAH related costs will be covered in the contract); bid
evaluation to include consideration for GBV/SEAH response proposal; and
8) Make additional funds available to implement measures to address GBV/SEAH and SEA risks and
impacts that may arise during Project implementation.
The project will also include provision of capacity building and training of relevant stakeholders, including
contractors and project workers, in additional to capacity building for government partners. GBV/SEAH risks
should be monitored throughout project implementation through regular re-assessment with the risk
screening tool, particularly as new project locations are determined, and through regular monitoring
engagement.
94
See http://siteresources.worldbank.org/INTAFRICA/Resources/AFR-Gender-Action-Plan-FY13-17.pdf for
more details

82
ANNEX 8: INDICATIVE ENVIRONMENTAL STEWARDSHIP FRAMEWORK FOR CONTRACTORS
ENVIRONMENTAL STEWARDSHIP FOR SCHOOL INFRASTRUCTURE DEVELOPMENT FOR SOMALIA EDUCATION PROJECT
ENVIRONMENTAL
SN POTENTIAL IMPACT CODE OF CONDUCT REQUIREMENT
ISSUE
Pre-construction/Construction Phase
Passage of contractor’s vehicles through grazing reserves or
Plan and file Vehicular Traffic Movements (VTMs) so as to as much
cultivated and forested land resulting in a permanent loss of the
as possible avoid trekking through grazing reserves or cultivated,
resources.
1 Land Use thus minimizing loss of resources
The environmental effects can amplify if proper operation and
maintenance schedules are not followed.
Excess extraction of local resources, such as wood, sand, soil,
boulders, etc.
Extract materials only on need basis
Degradation of forests, erosion and landslide at steep locales due
2 Material Use Avoid sensitive areas, such as steep slopes
to boulder, stone extraction.
Follow engineer’s directions at all times
Change in river and stream ecosystem due to unchecked sand
extraction
Extract carefully and secure the top soil within 25 cm from the
surface
Limit down grading of the infrastructure such as temporary road to

Extraction of forest products and cutting of trees in the steep
50
slopes increases soil erosion and landslide due to loss of soil
binding materials
If down grading exceeds 70, construction of side drainage is
necessary
3 Slope Stability Wrong alignment can trigger slope failure
Keep optimum balance in extraction and filling of soil works, geo-
hazardous assessment and mapping
Haphazard disposal of construction waste can disturb slopes
Use designated disposal site and avoid side-casting of spoil
Improper drainage facilities can result in erosion and landslides
Provide proper drainage
Use bio-engineering on exposed slopes

83
ENVIRONMENTAL
ISSUE
Avoid as much as possible areas with high biodiversity
Wildlife habitats at forests, shrub-lands along water Efficient movement of machinery and other traffic
infrastructure corridor are affected by the infrastructure
construction activities Control poaching activities and regulate movement of labour force
4 Wildlife
and their dependents into the forest area
Wildlife and human conflicts increase as wildlife might destroy
the crops or attack the construction workers District Forest or Range Office and its subsidiary body should be
involved in monitoring the activities of the construction workers
and officials to minimize wildlife harassing, trapping and poaching
It is strongly recommended that the cross-drainage outlets must be
Higher flow rate of surface water and water logging induce
channeled to the confirmed natural drains
landslides, erosion
If horizontal slope exceeds 5%, construction of flow control device
5 Drainage Hard-pan setting in school environment to contribute to
necessary every 20 m
enhanced surface runoff
Construction of walkways for use by children and teachers in the
schools
Use minimum and efficient use of wood products for construction
Protected areas and highly forested areas
Initiate plantation at damaged and damage prone areas
Protection of Degradation of forest areas
6
Vegetation
Increase liability of local forest user groups
Degradation of agricultural land
Avoid protected areas or densely forested areas
Selected spoil dumping sites should be used
After disposal, the area should be levelled and compacted

Disposal of
Dumping of wastes along the infrastructure such as roads or
7 Construction It is recommended to conserve the soil by planting indigenous
elsewhere
Wastes plants including grasses
Wastes could also be used as levelling materials along the

infrastructure

84
ENVIRONMENTAL
ISSUE
Proper sanitation area needs to be demarcated
Disposal of Sanitary Unmanaged sanitary waste disposal creating health problems and
8
Wastes public nuisance
Check for hygiene of work force
Impacts on Infrastructure such as road crossings at water supply, irrigation
9 Avoid as much as possible the crossing over such amenities
amenities lines may be disturbed or damaged
Dust generation from construction activities, construction
Possibly construction period should be during any of the two rainy
vehicular movement increases air pollution
seasons when soil moisture content is highest in Somalia (March-
May or October-December)
10 Pollution Noise pollution likely from construction machinery operation and
vehicular movement
Enforce speed limit of vehicles and construct the infrastructure such
Sanitary problems likely at the construction and workforce
as road according to volume and size of traffic movement
quarters.
Operation Phase
1 Encroachment Unmanaged settlement, constructions near the new schools Community zoning recommended, with enforcement
Enforce speed limit of vehicles
Dust generation from vehicular movement increases air pollution
Pollution/Vehicle
3 Maintain traffic size movement
Emission Noise pollution likely from vehicular movement and enhanced
student numbers
Discourage use of horns
Infrastructure such as water construction is likely to increase
landscape scars
Such damage cannot be avoided but can be minimized through re-
4 Aesthetics
In addition, if the construction spoils are disposed of improperly, plantation of indigenous species and greenery development
the ground vegetation would be destroyed which will be visible
from a distance
• Ensure that school construction designs include the installation
Issues with potable of appropriate potable water supply facilities
Water supply and availability problems arising from the huge
5 water supply and • School operation costs to take into account expenses related to
numbers of school-going children
sanitation problems provision of safe and potable water for school children,
teachers, and other stakeholders
• Establish and maintain continuous liaison with the host
Poor management
communities including sensitization on safety and health issues
of ESHS, as well as
6 Critical ESHS issues arising from the increased student numbers on construction sites
risks to community
• Install and maintain appropriate safety and warning signage in
health and safety
schools where constructions works are in progress

85
ENVIRONMENTAL
ISSUE
• Use of local language and images for signage shall be
encouraged
• Ensure that all potentially dangerous work areas have
controlled access limited to authorized persons only
• Ensure proper and adequate provision of sanitation and waste
management facilities at all construction sites
• Maintain a system of receiving and responding to any safety
concerns by the communities
• School CECs to be trained on EHS monitoring during school
operations
• Preparation of waste management plan for each waste stream
and implementation of the waste hierarchy, as part of the
Operation Phase ESMP
• Prepare and implement a simple waste management plan
subject to the concurrence of the respective PMUs in the FMS
Inefficient solid, hazardous and liquid waste and e-waste
• School CECs to provide garbage receptacles in strategic places
Waste collection and management during operation and maintenance
within the school compound area, and regularly collect and
7 management phases, leading to waste disposal problems, and resulting in
properly deposit of these wastes in the designated disposal
problems at schools polluting soils, surface and shallow groundwater, especially
areas
during the rainy seasons
• As much as practicable, reuse spoils that meets material
specifications
• When practicable, compost organic and degradable waste in
suitable container, and provide this to interested farmers for
their crop production
• Ensure that school designs adopted provide adequate learning
environment free of pests and vermin, with ample ventilation
provided
Outbreaks of Increased prevalence of communicable diseases • Periodic fumigation activities, to be prescribed in the Operation
8 diseases and poor Outbreaks of pest and vermin infestation Phase ESMP
indoor air quality General lack of cleanliness • Ensure proper and adequate provision of sanitation and waste
management facilities at all schools
• Maintain a system of receiving and responding to any safety
concerns by the communities

86
ANNEX 9: SUMMARY OF KEY E&S ASPECTS DURING THE REPORTING PERIOD
PROJECT STATUS, E&S INCIDENTS, E&S CHANGES, E&S INITIATIVES
PROJECT STATUS
PROVIDE A BRIEF DESCRIPTION OF ANY NEW DEVELOPMENTS IN RELATION TO OPERATIONS AND FACILITIES OVER THE
REPORTING PERIOD.
E&S INCIDENTS
PLEASE PROVIDE A SUMMARY OF ALL THE NOTIFIABLE E&S INCIDENTS, PER CTA DEFINITIONS.
PLEASE EXPAND OR COLLAPSE THE TABLE WHERE NEEDED.
DATE INCIDENT DESCRIPTION CLASS REPORTS SENT TO CORRECTIVE ACTIONS /
LENDERS REMEDIAL PLAN
E&S CHANGES
PLEASE PROVIDE A SUMMARY OF ALL THE NOTIFIABLE E&S CHANGES.
PLEASE EXPAND OR COLLAPSE THE TABLE WHERE NEEDED.
DATE CHANGE DESCRIPTION REPORTS SENT TO IMPLEMENTATION STATUS

LENDERS
IMPROVEMENTS/INITIATIVES REGARDING E&S PERFORMANCE
BRIEFLY DESCRIBE IMPROVEMENTS/INITIATIVES IMPLEMENTED DURING THE REPORTING PERIOD ON MANAGEMENT OF E&S
ASPECTS (E.G. ENERGY/WATER SAVINGS, SUSTAINABILITY REPORTS, WASTE MINIMIZATION, ETC.)
ESS1: Assessment and Management of Environmental and Social Risks and Impacts
E&S IMPACT / RISK ASSESSMENT
HAVE ANY SUPPLEMENTAL ENVIRONMENTAL, SOCIAL, HEALTH AND SAFETY IMPACT/RISK STUDIES BEEN CONDUCTED DURING THE
REPORTING PERIOD? (PLEASE PROVIDE COPIES)
Compliance with Environmental and Social Management Plans

The status of the ESMP implementation should be described and any issues that remain outstanding
should be detailed.

87
ESS2. Labor and Working Conditions

HUMAN RESOURCES MANAGEMENT
HAVE ALL DIRECT WORKERS SIGNED COCS AND RECEIVED ORIENTATION?

☐ YES ☐NO
PLEASE PROVIDE DETAILS .
# community # direct # Female direct Turnover # Contracted

workers workers workers workers95
Previous
period
Reporting
period
PROVIDE THE FOLLOWING INFORMATION REGARDING THE WORKFORCE:
IS THERE A FUNCTIONING AND ACCESSIBLE WORKER GRM

LIST THE WORKER-RELATED GRIEVANCES AND THEIR STATUS
OCCUPATIONAL HEALTH AND SAFETY

DESCRIBE THE MAIN CHANGES IMPLEMENTED IN TERMS OF OCCUPATIONAL HEALTH AND SAFETY (OHS) DURING THE
REPORTING PERIOD, E.G. REVISION OF THE OHS MANAGEMENT PROCEDURES, ACTION PLANS FOR TECHNICAL IMPROVEMENTS,
LEADING/LAGGING INDICATORS USED/INTRODUCED, IDENTIFICATION OF HAZARDS, NEW CONTROLS, ETC.
PLEASE ATTACH HEALTH & SAFETY AUDIT REPORTS AVAILABLE FOR THE REPORTING PERIOD.
☐ COPIES ATTACHED WITH THIS REPORT ☐ COPIES AVAILABLE UPON REQUEST ☐NOT AVAILABLE
ACCIDENT STATISTICS MONITORING

Report TOTAL numbers This reporting period Last reporting period (not cumulative)96
for each parameter COMMUNITY DIRECT CONTRACTED COMMUNITY DIRECT WORKERS CONTRACTED
WORKERS WORKERS WORKERS WORKERS WORKERS
Total number of
workers
Total man-hours
worked – annual
Total number of lost
time occupational
injuries97
Total number of lost
workdays98 due to
injuries
95
See ESS2 definitions.
96
To be provided after the project has been operational for at least two consecutive years.
97
A lost-time injury (LTIs) is the incapacity to work for at least one full workday beyond the day on which the accident
or illness occurred.
98
Lost workdays are the number of workdays (consecutive or not) beyond the date of injury or onset of illness that
the employee was away from work or limited to restricted work activity because of an occupational injury or illness.

88
Lost time injury

frequency99
Fatalities
Vehicle collisions100
PROVIDE DETAILS FOR THE NON-FATAL LOST TIME INJURIES DURING THIS REPORTING PERIOD.
UNOPS/IOM / contractor/ Total Description of Cause of Corrective measures to
Subcontractor employees? workdays lost injury accident prevent reoccurrence
PROVIDE DETAILS FOR FATAL ACCIDENTS DURING THIS REPORTING PERIOD, IF ANY, (AND PROVIDE COPIES OF ACCIDENT
INVESTIGATION AND RESPECTIVE CORRECTIVE PLAN).
Date of Accident Type of Accident Description of # of Preventive measures taken
Accident Fatalities after the incident
OHS TRAINING
DESCRIBE HEALTH AND SAFETY TRAINING PROGRAMS CARRIED OUT IN THE REPORTING PERIOD.
DATE TYPE OF AUDIENCE DESCRIPTION OF TRAINING (AND DURATION) NUMBER OFATTENDEES
WORKPLACE MONITORING
PLEASE PROVIDE COPY OF ANY WORKPLACE MONITORING REPORTS DEVELOPED FOR THE REPORTING PERIOD.
ESS3. Resource Efficiency and Pollution Prevention

ENVIRONMENTAL MONITORING
PROVIDE COPY OF ENVIRONMENTAL MONITORING DATA REPORTS FOR THIS REPORTING PERIOD, COLLECTED CONSISTENT
WITH THE ESMPS FOR THE SUB-PROJECTS.
BRIEFLY DESCRIBE ENVIRONMENTAL MITIGATION MEASURES IMPLEMENTED DURING THE REPORTING PERIOD TO COMPLY WITH
E&S REQUIREMENTS.
RESOURCES EFFICIENCY: ENERGY AND WATER
99
The number of lost time injuries (LTIs) recorded for Project workers per million man-hours worked by them. LTI
Frequency Rate = injuries per million hours worked = # of lost time accidents x 1,000,000 hours / total man-hours
worked).
100
Vehicle Collision: When a vehicle (device used to transport people or things) collides (comes together with violent
force) with another vehicle or inanimate or animate object(s) and results in injury (other than the need for First Aid)
or death.

89
PROVIDE DATA ON ENERGY AND WATER CONSUMPTION DURING THE REPORTING PERIOD. IF THE DATA REQUESTED ARE
AVAILABLE IN ANOTHER FORMAT, THEY CAN BE SUBMITTED INSTEAD.
DESCRIBE THE CONCESSIONAIRES’ RESOURCES EFFICIENCY MEASURES/EFFORTS BEING IMPLEMENTED TO MINIMIZE FUEL,
ENERGY, AND WATER CONSUMPTION.
HAZARDOUS AND NON-HAZARDOUS WASTE101
EROSION CONTROL, SLOPE STABILITY AND REINSTATEMENT

PLEASE DESCRIBE STATUS AND ACTIONS IMPLEMENTED IN TERMS OF EROSION CONTROL, SLOPE STABILITY, AND
REINSTATEMENT WITHIN THE PROJECT’S FOOTPRINT AND AREA OF INFLUENCE.
ESS4 Community Health, Safety and Security

COMMUNITY HEALTH AND SAFETY
PLEASE LIST AND DESCRIBE ANY INITIATIVES IMPLEMENTED IN RELATION TO COMMUNITY HEALTH AND SAFETY DURING THE
REPORTING PERIOD.
PLEASE PROVIDE THE LIST AND DESCRIPTION OF THE ACTIONS, THE EXPECTED OR ACTUAL DATES OF IMPLEMENTATION,
PROGRESS/STATUS, RESULTS OBTAINED. YOU CAN USE A TABULAR FORMAT (AS BELOW) OR PROVIDE THE INFORMATION AS
AN ATTACHMENT OF THE REPORT.
DURING THE REPORTING PERIOD, HAVE ANY EMERGENCY DRILLS BEEN CONDUCTED WITH PARTICIPATION OF THE LOCAL
AUTHORITIES, PUBLIC EMERGENCY ORGANIZATIONS, LOCAL COMMUNITIES? ARE THE COMMUNITIES AWARE OF THE
EMERGENCY RESPONSE PLANS?
ACCIDENT REPORTING
PROVIDE DETAILS FOR THE NON-FATAL CASUALTIES, INVOLVING THIRD PARTIES, DURING THIS REPORTING PERIOD.
Date of Accident Type of Accident Description of # of People Preventive measures taken
Accident Injured after the incident
PROVIDE DETAILS FOR FATAL ACCIDENTS DURING THIS REPORTING PERIOD (AND PROVIDE COPIES OF ACCIDENT INVESTIGATION
AND RESPECTIVE CORRECTIVE PLAN).
Date of Accident Type of Accident Description of # of Preventive measures taken
Accident Fatalities after the incident
GBV/SEAH/SEA ACTION PLAN
Please provide an update on the status and progress of the actions as defined in the GBV/SEAH/SEA
Action Plan. You may attach relevant monitoring reports.
101
Waste types include but are not limited to: chemical containers, chemical sludge, containers/pallets, dewatered
sludge, domestic waste, ferrous and non-ferrous scrap, hospital waste, laboratory waste, liquids, off-specification
raw materials, paint waste, sludge, solids, truck and auto tires, waste fuel hydrocarbons, waste hydraulic fluids,
waste lubricating hydrocarbons, waste solvents, waste treatment sludge, contaminated soil, creosote sleepers et c.

90
ESS5 Land Acquisition and Involuntary Resettlement
REPORT ANY ACTIVITIES THAT HAVE BEEN REQUIRED INVOLUNTARY RESETTLEMENT
ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources
Biodiversity Management
PLEASE REPORT ON THE MITIGATION MEASURES INCLUDED IN THE ESMF AND ESMPS
AS NEEDED, USING THE TABLE BELOW DESCRIBE ANY NEW ACTIVITIES OR EXPANSIONS THAT HAVE INCREASED THE PROJECT
FOOTPRINT INTO NEW AREAS OF HABITAT DURING THE REPORTING PERIOD.
New activity/expansion Total area covered Habitat type
ESS8 Cultural Heritage
REPORT IF CHANCE FIND PROCEDURES HAVE BEEN APPLIED IF NOT, PLEASE INDICATE NOT RELEVANT.
ESS 10 Stakeholder Engagement and Information Disclosure

91
ANNEX 10: WORLD BANK INCIDENT CLASSIFICATION GUIDE

92

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FEDERAL REPUBLIC OF SOMALIA

MINISTRY OF EDUCATION, CULTURE AND HIGHER EDUCATION

SOMALIA EDUCATION FOR HUMAN CAPITAL DEVELOPMENT

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

8th March, 2021

3.7 World Bank ESS ............................................................................................................. 15

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

6.7 Environmental and Social Benefits ................................................................................. 32

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ANNEX 8: INDICATIVE ENVIRONMENTAL STEWARDSHIP FRAMEWORK FOR CONTRACTORS . 83

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ACRONYMS AND ABBREVIATIONS

ABE Alternative to Basic Education

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

MDAs Ministries, Departments and Agencies

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

Component 3: “Enhanced instruction quality” proposes to support the development of a 2-year

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

• inclusion of out-of-school children in schooling and improvements in learning will lead to a

Table 1: Key project ESF instruments

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

project workers, teachers, and school administrators. An Accountability and

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

1. INTRODUCTION AND PROJECT CONTEXT

1.1 Project Context

2. Somalia is faced with two critical

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

1.2 The Somalia Education for Human Capital Development Project

1.3 Project Development Objective and Components

9. The project will have four compoments as described below.

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

For the new school construction:

• Community mobilization. Communities will be mobilized through Village Development

• School construction. New schools with a proportional allocation of gender-separated

Component 3: “Enhanced instruction quality” proposes to support the development of a 2-year

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

1.4 Project Beneficiaries

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

2. SCOPE AND METHODOLOGY OF THE ESMF

2.1 Purpose and Scope of the ESMF

2.2 ESMF Justification

19. The specific objectives of this ESMF are to:

2.3 ESMF Principle

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

3. POLICY, LEGISLATIVE AND INSTITUTIONAL FRAMEWORKS

3.2 Somalia National Laws, Policies and Legislations

3.2.1 Provisional Constitution of the Federal Republic of Somalia

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021

3.2.2 The Labour Code of 197217

3.2.3 The Somali Penal Code of 1962

3.2.4 The Agricultural Land Law (1975)

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) FEBRUARY 25, 2021