FEDERAL REPUBLIC OF NIGERIA FEDERAL REPUBLIC OF NIGERIA MINISTRY OF FINANCE SUSTAINABLE PROCUREMENT, ENVIRONMENTAL AND SOCIAL STANDARDS ENHANCEMENT PROJECT (SPESSE) Draft Stakeholder Engagement Plan AUGUST 2019 FEDERAL REPUBLIC OF NIGERIA ACRONYMS ACE Africa Center of Excellence BPP Bureau of Public Procurement CBN Central Bank of Nigeria CE Center of Excellence CPAR Country Procurement Assessment Report CPF Country Partnership Framework CPS Country Partnership Strategy DLI Disbursement-linked indicator DLR Disbursement-linked results EA Environmental Assessment E&S Environment and Social EAD Environmental Assessment Department at the Ministry of Environment (also EA Department) EEP Eligible expenditure program EIA Environmental Impact Assessment Act ERGP Economic Recovery and Growth Plan ES Environmental Standards ESF World Bank Environmental and Social Framework ESMP Environmental and Social Management Plan FGD Focus Group Discussion FGIP Fiscal Governance and Institutions Project FGN Federal Government of Nigeria FMWASD Federal Ministry of Women Affairs & Social Development FU Federal University GIFMIS Government Integrated Financial Management System IA Implementing Agency ICT Information and Communication Technology IFR Interim Financial Report INFU Independent National Facilitation Unit IPF Investment Project Financing IPPIS Integrated Payroll and PEronnel Information System ITCILO International Training Center of the Intetnational Labor Organization ITPV Independent Certified Third-Party Verifiers IVA Independent Verification Agent KII Key Informant Interview LMS Learning Management System M&E Monitoring and Evaluation MDAs Ministries, departments, and agencies MOF Ministry of Finance (also FMoF) NERGP National Economic Recovery and Growth Plan (also ERGP) nGRen Nigerian Research and Education Network NESREA National Environmental Standards and Regulations Enforcement Agency NPVCA Nigerian Procurement Value Chain Analysis NUC National Universities Commission OAuGF Office of the Auditor General of the Federation i SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA OCDS Open Contracting Data Standards PEMFAR Public Expenditure Management and Financial Accountability Review PES Procurement, Environment and Social PFA Performance and Funding Agreement PIFANS Programmatic Integrated Fiduciary Assessment of Nigeria States PIU Project implementation unit PP Public Procurement PS Procurement Standards PSGRDP Public Sector Governance Reform and Development Project SEEFOR State Employment and Expenditure for Results SFTAS States Fiscal Transparency, Accountability and Sustainability SLOGOR State and Local Governance Reform SORT Systematic Operations Risk Tool SPESSCE Sustainable Procurement, Environmental and Social Standards Centers of Excellence SPESSE Sustainable Procurement, Environmental and Social Standards Enhancement SS Social Standards TA Technical Assistance TOR Terms of Reference TWG Technical Working Group ii SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Contents 1.0 Introduction .................................................................................................................. 3 1.1 Project Background .......................................................................................... 3 1.2 Project Description .......................................................................................... 4 1.3 Project Components ........................................................................................ 4 1.4 Applicable World Bank Environmental Social Standards (ESSs) .............. 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Bookmark not defined. 1.6 Structure of Stakeholder Engagement Plan..................................................... 7 3.0 Project Stakeholder identification and Analysis ..................................................... 9 3.1 Stakeholder Categorisation ............................................................................. 9 4.0 Stakeholder Engagement Program .................................................................................... 12 4.1 Engagement Methods and Tools .......................................................................... 12 4.2 Description of Engagement Methods .............................................................. 19 4.3 Description of Information Disclosure Methods ............................................. 27 4.3.1 Timetable for Disclosure .................................................................................. 27 5.0 Grievance Management..................................................................................................... 30 5.1 Grievance Redress Mechanism (GRM) .............................................................................. 30 5.2 Grievance Resolution Framework ......................................................................... 30 5.3 SPESSE Grievance Escalation Process ................................................................... 31 5.4 Grievance logs ....................................................................................................... 32 5.5 Monitoring and reporting on grievances ....................................................... 33 5.6 Points of contact ............................................................................................ 33 5.7 World Bank Grievance Redress System ......................................................... 34 6.0 Monitoring and Reporting ................................................................................................ 36 6.1 Reporting .............................................................................................................. 36 6.2 Training ....................................................................................................................... 36 Figures ii SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA 1.0 Introduction The Sustainable Procurement, Environmental and Social Standards Enhancement (SPESSE) Program is an $80 Million capacity building project targeted at sustainably enhancing capacity in managing procurement, environment and social (E&S) standards in the public and private sectors in Nigeria. This project is critical to the Government of Nigeria as it contributes directly to the current administration’s Economic Recovery and Growth Plan (ERGP), which is aimed at accelerating structural reforms to alleviate increasing poverty and inequality by: bringing consistency to the monetary and fiscal policy, spurting job-creation through policies consistent with private sector development, and creating sustainable fiscal space for desperately needed investments in human and physical capitals and importantly, reduce the cost of governance. Social risk classification in this project is “low� because construction of infrastructure or buildings are not envisaged. The project will not finance activities that involve land acquisition, restrictions on land use, or involuntary resettlement. The allocation of funding to SPESSCEs will be based on the funding needs of each center. Each center’s funds will be distributed across a set of disbursement-linked indicators/results (DLIs/DLRs). Given that the project seeks to build capacity within the public and private sectors, it is critical to engage these various stakeholders. In this regard, the multisectoral agencies involved in the project would engage their internal and external stakeholders, to ensure that there is adequate buy-in for the project and all stakeholders are able to participate by contributing meaningfully to the process and are able to raise questions, concerns and request clarifications whenever necessary throughout the project life-cycle. This is very important particularly for the vulnerable groups because it would give them opportunities to contribute and play a key role in the process. The SEP is a participatory tool designed to provide guidance on how the various agencies involved in the SPESSE program would identify, map/categorize, engage and maintain a responsive and transparent communication line with their stakeholders. The SEP is crucial to the overall project goal because the role of every stakeholder is important to the successful implementation of the project. This SEP provides guidelines for stakeholder engagement during preparation and implementation of the project. It would also guide the disclosure process for the entire SPESSE program. This SEP is a living document and will be updated throughout the project lifecycle. It will be: • Disclosed prior to project commencement; • Be the strategic tool for all project related engagements; • Periodically updated and changes validated during project implementation; and • Monitored and its effectiveness evaluated towards the end of the project Although this initial SEP has been developed with significant input from the Bank, overall stakeholder engagement will be carried out by the key implementing agencies and subsequent activities would be captured to update the draft at a strategic level, by each implementing agency. 1.1 Project Background One of the key impediments to achieving efficiency and effectiveness of public investments is the lack of adequate Procurement, Environmental and Social (PES) systems capacity in the country, which are 3 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA major factors in improving governance and delivery. This is in addition to the lack of reliance on digital technologies and capitalizing on the digital economy. Procurement, environmental and social standards is strategic to achieving the government goals because of the rising poverty level which has been linked to poor procurement related practices which is prone to corruption and wastage. Losses relating to poor procurement practice is significant to the nation because approximately 60 percent of the Nigerian budget expenditure passes through the procurement process. The government has been implementing some reforms in the procurement process with its development partners but there still remains the challenge of these reforms trickling down to the state government and local government level. There is also the lack of adequate procurement capacity due to the absence of capacity development strategy and a shortage in the number of qualified procurement professionals. This necessitates an urgent need to strengthen procurement institutions and systems to improve transparency and accountability in procurement. With respect to the environmental and social aspects, the nation has weak technical and operational capacities for environmental and social due diligence in all sectors in addition to the scarcity of personnel with the requisite environmental and social skills. This project is in response to the significant gaps identified in the procurement, environmental and social sectors in the governance of the Nigerian economy. 1.2 Project Description The proposed project is the first attempt to develop and implement a curricula for procurement and E&S standards in Nigeria by offering professionalization and academic tracks in a custom-made, fit- for-purpose and sustainable manner through Centres of Excellence established in Nigerian Federal Universities similar to the Africa Center of Excellence (ACE) programs. While ACEs focus on regional collaboration within Sub-Saharan Africa, this project will focus on collaboration with Nigerian public, private, academic and sector partners. The cornerstone of this project is the creation of Centers of Excellence (SPESSCE) in Nigerian Universities to deliver capacity building in a sustainable manner in procurement, environmental and social standards. To accompany such an initiative, key stakeholders will be effectively engaged in design, implementation and monitoring. This capacity development project is strategically and operationally planned in an aligned and coordinated manner across all tiers of government and involving all stakeholders (national and sub-national government, development partners, NGO’s, private sector, etc.). Additionally, it is tightly linked to real-time performance and change management program. This creates continued urgency for using the newly developed capacities, and it creates a feedback loop from learning to performance which in turn helps inform curriculum design/enhancement and instruction delivery mechanisms. The adopted methodology will ensure a holistic approach to the elevation of capacities in Nigeria in full reliance on technology and E-learning tools and facilities. 1.3 Project Components This multi-disciplinary project is composed of two main components a. Component I: Technical assistance and Support to implementing agencies; and b. Component II: Establishment and operating the Centers of Excellence (SPESSCE). Project Sub-Components: Component I is composed of the following sub-components: 4 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA c. Technical Assistance and DLI-based Support to Bureau of Public Procurement (BPP), Environmental Assessment Department and Federal Ministry of Women Affairs & Social Development d. Technical Assistance and DLI-based Support to National Universities Commission (NUC) e. Technical Assistance to NUC for the Campaign for Change f. Technical Assistance to the Ministry of Finance (MoF) Component II is composed of the following sub-components: g. Funding support to the CE to facilitate project startup h. DLI-based support to operating the CEs Graphic Illustration of SPESSE project Components Sustainable Capacity Building in PP, ES & SS COMPONENT I. Technical Assistance & COMPONENT II. Support to Implementing Agencies Centers of Excellence BPP EA Dept. MWASD NUC MOF 6 Centers Tracks Offered Selected & by SPESSCEs Funded I.a.1.i Capacity I.a.2.i Capacity I.a.3.i Social I.d.i Development I.b.i Degrees’ Implementation Building Strategic Building Strategic Standards Management Coordination Plan for PP Plan E&SS PP ES SS I.a.1.ii PP I.a.2.ii ES I.a.3.ii Support to I.b.ii Monitoring & Certification Certification TWG Evaluation Track A Track A Track A Scheme Scheme Track B Track B Track B I.a.3.iii SS I.c. Campaign for Track C Track C Track C Certification Change Scheme Track D Track D Track D Track E Track E Track E 1.5 Stakeholder Engagement Plan and Disclosure This Stakeholder Engagement Plan (SEP) will BE disclosed publicly. This plan addresses specific risks identified by stakeholders, including the exclusion of certain beneficiaries in target areas, risks to vulnerable peoples etc. and will be updated as and when necessary. The objective is to establish a systematic approach for stakeholder engagement, maintain a constructive relationship with them, consider stakeholders’ views, promote and provide means for effective and inclusive engagement with project-affected parties throughout the project life-cycle, and ensure that appropriate project information is disclosed to stakeholders in a timely, understandable, 5 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA accessible and appropriate manner. The project will set up a project-specific Grievance Redress and Feedback Mechanism for people to report concerns or complaints if they feel unfairly treated or are affected by any of the sub-projects. 1.6 Stakeholder Engagement within the context of SPESSE The underlying principle of stakeholder engagement for the project will be that engagement shall be: a) free of manipulation, b) free of interference, coercion, and intimidation, and conducted based on timely, relevant, understandable and accessible information, in a culturally appropriate format. It shall involve interactions between project’s stakeholders and shall provide stakeholders with an opportunity to raise their concerns and opinions and shall ensures that this information is taken into consideration when designing the project and making decisions. The project’s stakeholder’s engagement aims at creating a “social licence�1 and will depend on mutual trust, respect and transparent communication between SPESSE and its stakeholders. It will thereby improve decision-making and environment and social performance. This could lead to managing costs and risks, enhancing reputation, avoiding conflict, improving corporate policy, identifying, monitoring and reporting on impacts, and managing stakeholder expectations. 1.7 Principles for effective stakeholder engagement The project’s Stakeholder Engagement Plan (SEP) shall be informed by a set of principles defining its core values underpinning interactions with identified stakeholders. Common principles based on “International Best Practice� include the following: • Commitment is demonstrated when the need to understand, engage and identify the community is recognised and acted upon early in the process; • Integrity occurs when engagement is conducted in a manner that fosters mutual respect and trust; • Respect is created when the rights, cultural beliefs, values and interests of stakeholders and affected communities are recognised; • Transparency is demonstrated when community concerns are responded to in a timely, open and effective manner; • Inclusiveness is achieved when broad participation is encouraged and supported by appropriate participation opportunities; and • Trust is achieved through open and meaningful dialogue that respects and upholds a community’s beliefs, values and opinions. 1.8 Overall objectives The overall objectives of SEP as stated in the ESS-10 are to: • To identify the roles and responsibility of all stakeholders and ensure their participation in the complete project cycle • Establish a systematic approach to stakeholder engagements that will help SPESSE identify stakeholders and build and maintain a constructive relationship with them, in particular project-affected parties • Assess the level of stakeholder interest and support for the project and to enable stakeholders’ views to be considered in project design and implementation 1 Social license refers to the ongoing acceptance of a company or industry's standard business practices and operating procedures by its employees, stakeholders and the public 6 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA • Promote and provide means for effective and inclusive engagement with project- affected parties throughout the project life -cycle on issues that could potentially affect them. • Ensure that appropriate project information on environmental and social risks and impacts is disclosed to stakeholders in a timely, understandable, accessible and appropriate manner and format with special consideration for the disadvantaged or vulnerable groups. • Provide project-affected parties with accessible and inclusive means to raise issues and grievances and allow EWSC to respond to and manage such grievances. • To devise a plan of action that clearly identifies the means and frequency of engagement of each stakeholder • To allocate budgetary and other resources in the project design, project implementation, and Monitoring and Evaluation (M&E) for stakeholder engagement and participation SEP provides an opportunity for all-inclusive approach in project preparation, planning, implementation and monitoring processes. It is geared toward ensuring meaningful and a wide consultative process guided by World Bank’s Environmental and Social Framework (ESF), particularly ESS-10. . 1.8 Structure of Stakeholder Engagement Plan The structure of the stakeholder engagement plan will be as follows; 2.0 Stakeholder Engagement Regulatory Context 3.0 Stakeholder Identification and analysis 4.0 Stakeholder Engagement Program 5.0 Grievance Redress Mechanism 6.0 Monitoring and Reporting 2.0 Stakeholder Engagement Regulatory Context This section presents a brief overview of the national legal provisions that necessitates citizenship engagement, disclosure of public information and adequate response to queries, concerns and grievances raised by the public on key government actions. 2.1 Key National Legal Provisions for Environmental and Social Safeguards and Citizen Engagement 2.1.1 The Freedom of Information Act The purpose of the Act is to make public records and information more freely available, provide for public access to public records and information, protect public records and information to the extent consistent with the public interest and the protection of personal privacy, protect serving public officers from adverse consequences for disclosing certain kinds of official information without authorization and establish procedures for the achievement of those objectives. This Act applies not only to public institutions but also to private organisations providing public services, performing public functions or utilising public funds. According to the Act, - All stakeholders are entitled to access to any records under the control of the government or 7 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA public institution - Any stakeholder denied information can initiate a court proceeding to effect the release of such information - All public institutions shall make available any records as requested by the stakeholders within a period of 7 days 2.1.2 Constitution of the Federal Republic Chapter two of the Nigerian constitution takes socioeconomic rights of Nigerians into account. This chapter includes that no citizen should be denied the right to environment, the right to secure and adequate means of livelihood, right to suitable and adequate shelter, the right to suitable and adequate food etc. Section 20 of the constitution also takes into account the use of resources and provides that the environment must be protected and natural resource like water, air, and land, forest and wild life be safeguarded for the benefit of all stakeholders. 2.1.4 Nigerian Environmental Assessment Law This act provides guidelines for activities for which EIA is compulsory (such as mining operations, road development, coastal reclamation involving 50 or more hectares, etc.). It prescribes the procedure for conducting and reporting EIAs and dictates the general principles of an EIA. The EIA act enshrines that consideration must be given to all stakeholders before the commencement of any public or private project by providing for the involvement and input of all stakeholders affected by a proposed project. 2.1.5 Other Legal Provisions on Stakeholder Engagement and Disclosure The Nigerian Urban and Regional Planning Act, Cap N138, 2004 provides that any land development plan must be disclosed to stakeholders to prove that such projects would not harm the environment or constitute nuisance to the community. 2.2 World Bank Environmental and Social Standard on Stakeholder Engagement The World Bank’s Environmental and Social Framework (ESF)’s Environmental and Social Standard (ESS) 10, “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� (World Bank, 2017: 97). Specifically, the requirements set out by ESS10 are the following: • “Borrowers will engage with stakeholders throughout the project life cycle, commencing such engagement as early as possible in the project development process and in a timeframe that enables meaningful consultations with stakeholders on project design. The nature, scope and frequency of stakeholder engagement will be proportionate to the nature and scale of the project and its potential risks and impacts; • Borrowers will engage in meaningful consultations with all stakeholders. Borrowers will provide stakeholders with timely, relevant, understandable and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation; • The process of stakeholder engagement will involve the following, as set out in further detail in this ESS: (i) stakeholder identification and analysis; (ii) planning how the engagement with stakeholders will take place; (iii) disclosure of information; (iv) consultation with stakeholders; (v) addressing and responding to grievances; and (vi) reporting to stakeholders. 8 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA • The Borrower will maintain and disclose as part of the environmental and social assessment, a documented record of stakeholder engagement, including a description of the stakeholders consulted, a summary of the feedback received and a brief explanation of how the feedback was taken into account, or the reasons why it was not.� (World Bank, 2017: 98). A Stakeholder Engagement Plan proportionate to the nature and scale of the project and its potential risks and impacts needs to be developed by the Borrower. It has to be disclosed as early as possible, and before project appraisal, and the Borrower needs to seek the views of stakeholders on the SEP, including on the identification of stakeholders and the proposals for future engagement. If significant changes are made to the SEP, the Borrower has to disclose the updated SEP (World Bank, 2017: 99). According to ESS10, the Borrower should also propose and implement a grievance mechanism to receive and facilitate the resolution of concerns and grievances of project-affected parties related to the environmental and social performance of the project in a timely manner (World Bank, 2017: 100). For more details on the WB Environmental and Social Standards, please follow the link below: https://www.worldbank.org/en/projects-operations/environmental-and-social- framework/brief/environmental-and-social-standards 3.0 Project Stakeholder identification and Analysis Project stakeholders are ‘people who have a role in the Project, or could be affected by the Project, or who are interested in the Project’. Project stakeholders can further be categorized as primary and secondary stakeholders. Primary stakeholders are individuals, groups or local communities that may be affected by the Project, positively or negatively, and directly or indirectly especially those who are directly affected, including those who are disadvantaged or vulnerable. Secondary stakeholders are broader stakeholders who may be able to influence the outcome of the Project because of their knowledge about the affected communities or political influence over them�. Thus, the SPESSE Project stakeholders are defined as individuals, groups or other entities who: (i) Have a role in the project implementation (also known as ‘implementing agencies’); (ii) are impacted or likely to be impacted directly or indirectly, positively or adversely, by the Project (also known as ‘affected parties’); and (iii) May have an interest in the Project (‘interested parties’). They include individuals or groups whose interests may be affected by the Project and who have the potential to influence the Project outcomes in any way. 3.1 Stakeholder Categorization For the purposes of effective and tailored engagement, the stakeholders of SPESSE can be divided into three core categories: 1. Implementing Agencies 2. Affected Parties 3. Interested Parties 3.1.1 Implementing Agencies This category of stakeholders encompasses the leading agencies responsible for overseeing the successful implementation of the SPESSE program. They include the: 9 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA • Federal Ministry of Finance (FMoF); • Federal Ministry of Women Affairs and Social Development (FMWSD); • Technical Working Group (TWG) on Social Development (Ministry of Women and Social Development, Ministry of Labour and Productivity, and Ministry of Power, Works and Housing); • The EA Department of the Federal Ministry of Environment; • Bureau of Public Procurement (BPP); and • Nigerian University Commission (NUC) In order to meet best practice approaches, SPESSE Project implementing agencies will apply the following principles for stakeholder engagement: • Openness and life-cycle approach: Public consultations for the project(s) will be arranged during the whole life-cycle, carried out in an open manner, free of external manipulation, interference, coercion or intimidation; • Informed participation and feedback: Information will be provided to and widely distributed among all stakeholders in an appropriate format; opportunities are provided for communicating stakeholders’ feedback, for analyzing and addressing comments and concerns; • Inclusiveness and sensitivity: Stakeholder identification is undertaken to support better communications and build effective relationships. The participation process for the project(s) is inclusive. All stakeholders at all times are encouraged to be involved in the consultation process. Equal access to information is provided to all stakeholders. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods. Special attention is given to vulnerable groups identified by the project which include the rural population, people living with disabilities, women, and disadvantaged youth. 3.1.2 Affected Parties This comprises of persons, groups and other entities studying at one of the implementing Nigerian Universities who will be recipients/beneficiaries of the capacity building program. This group is the core target audience and will be directly affected by the project implementation or/and outcomes. A subset of this category are the vulnerable groups. A significant factor in achieving inclusiveness of the engagement process is safeguarding the participation of vulnerable individuals in public consultations and other engagement forums established by the program. Vulnerable Groups are persons who may be disproportionately impacted or further disadvantaged by the project as compared with any other groups due to their vulnerable status2, and that may require special engagement efforts to ensure their equal representation in the consultation and participation in the program. 2 Vulnerable status maystem from an individual’s or group’s ethnic or social origin, color, gender, language, religion, political or other opinion, property, age, culture, literacy, sickness, physical or mental disability, poverty or economic disadvantage, and dependence on other individuals or unique natural resources. 10 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA The vulnerable groups identified by the project include the persons with disabilities3 and women4. Women are considered especially vulnerable as the curriculum and training programs may exclude their participation. Further there could be heightened risks of sexual harassment at the project related workplace and academic courses. Minor civil works may lead to presence of contractor workers and potential impacts of harassment and GBV incidence. Engagement with the vulnerable groups and individuals often requires the application of bespoke measures and assistance aimed at the facilitation of their participation in the project-related decision making so that their awareness of and participation in the process are commensurate to those of the other stakeholders. 3.1.3 Interested Parties Interested Parties include stakeholders who may not experience direct impacts from the Project but who consider or perceive their interests as being affected by the project and/or who could influence the project and the process of its implementation in some way. Specifically, this category will include the following individuals and groups: • The local population who can benefit indirectly from the capacity building program; • Residents and business entities, and individual entrepreneurs in the area of the project that can benefit from the capacity training program; • Local contractors who can support in the delivery of the SPESSE program; • Environmental and Social Consulting organizations in Nigeria that have staff that can be trained and will help build a cadre of trained professionals • Environmental protection authorities; • Local, regional and national level civil societies and non-governmental organizations (NGOs) with an interest in PES safeguards; • Other government ministries and regulatory agencies at regional and national levels including environmental, technical, social development and labor authorities; • SPESSE employees and contractors; and • Mass media and associated interest groups, including local, regional and national printed and broadcasting media, digital/web-based entities, and their associations. Local NGOs and initiative/advocacy groups particularly those focusing on social development issues represent the considerable capacity that the project(s) may tap for disseminating information and raising awareness of the planned activities among the potentially affected communities in the project area. NGOs typically have well established interaction with the local communities, are able to propose the most effective and culturally appropriate methods of liaising based on the local customary norms and prevailing means of communication and possess the facilitation skills that may be utilized as part of the project’s consultations. In addition, NGOs may lend assistance in disseminating information about the proposed project(s) to the local communities, including in the remote areas (e.g. by placing information materials about the project in their offices, distributing the project information lists during events that they are organizing), and provide venues for the engagement activities such as focus-group discussions. 3 Persons with disabilities the demand and supply side barriers to inclusive education so as not to exacerbate inequality and limit the ability of persons with disability from attending, completing and accessing quality learning 4 women to face multiple barriers based on gender and its intersections with other factors, such as age, ethnicity, poverty, and disability, in the equal enjoyment of the right to quality education. This includes barriers, at all levels, to access quality education and within education systems, institutions, and classroom 11 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA 4.0 Stakeholder Engagement Plan The objective of the engagement and consultations plan under the project is to: (a) Begin early in the project planning process to gather initial views on the project proposal and inform project design; (b) Encourage stakeholder feedback, particularly as a way of informing project design and engagement by stakeholders in the identification and mitigation of environmental and social risks and impacts; (c) Ensure that stakeholders have an understanding of how the project is likely to affect them (d) Ensure consistency in messaging (e) Continue engagement on an ongoing basis as risks and impacts arise and manage stakeholders’ expectations; (f) Ensure prior disclosure and dissemination of relevant, transparent, objective, meaningful and easily accessible information in a timeframe that enables meaningful consultations with stakeholders in a culturally appropriate format, in relevant local language(s) and is understandable to stakeholders; (g) Consider and responds to feedback; (h) Support active and inclusive engagement with project-affected parties; (i) Ensure that consultation(s) is/ are free of external manipulation, interference, coercion, discrimination, and intimidation; and (j) Ensure consultation (s) is/are documented and disclosed by the SPESSE 12 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA 4.1 Summary of Stakeholder Consultations to Date The ministries and institutions were consulted to inform them about the project, World Bank ESF and general safeguard concerns that need to be mainstreamed into the project. Their support to the project was also solicited along with a discussion on needs and capacities. Subsequently, a stakeholder workshop was held at National Universities Commission, Abuja on the 27th August 2019, where stakeholders were convened to discuss and make further inputs on the instruments of the project like the Stakeholders Engagement Plan, the ESCP and the ESMF. The following were the summary of consultations undertaking with relevant stakeholders during the appraisal stage: Highlights of Consultation with MWASD: The Ministry of Women Affairs have the mandate to advise government on social issues including women protection and safety, Gender base violence, sexual health and protection, women right to work and working conditions, child labour, etc. During consultation with the Ministry of Women Affairs and Social Development (MWASD) the following issues were identified and discussed: • Women inclusion and opportunity for even participation in the SPESSE project; • Gender based violence, sexual exploitation and harassment against women and girls and how SPESSE project will guide against such in this project; • Labour influx and how to ensure that it is reduced or not pose a threat to women health and participation in SPESSE, either as workers or students; • Child labour occurrences during construction stage and how SPESSE project will avoid or manage this situation it its project; • Waste generation types from the project and how SPESSE will manage wastes • Mandate of MWASD and its capacity to implement its social responsibilities as will be assigned in SPESSE project The consultation concluded the need to train staff of the MWASD and in particular, the importance of ensuring that the PIU at all levels are fortified with skilled personnel that will carry out mandates on GBV/SEA, labour influx, child labour, grievance redress and other social safeguards concerns. Highlights of Consultation with the EA Department of the Federal Ministry of Environment The EA department has the mandate to regulate EIA and ensure compliance with guidelines and laws on environmental protection. It reviews EIA reports and gives approvals to EIAs. It also penalizes defaulters of EIA laws and is responsible for approving the disclosure of draft EIAs and ESMPs prepared for projects in Nigeria. Consultation with EA department focused on the following aspects: • Quality of ESIAs/ESMPs submitted for disclosures in World Bank funded projects. The EA department wants World Bank as the clearing institution to ensure that reports meet international standards at all times; 13 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA • The EA department want to be carried out more meaningfully in the preparation and monitoring of projects; • The EA department assured of its commitment to participate in projects funded by the Bank to ensure facilitation and standards. Highlights of Consultation with NUC The NUC plays vital role in the overall E&S management of the SPESSE Project. This is anchored on the fact that the Center of Excellence will be supervised directly by the NUC. Discussion with NUC focused on the following thematic issues: • World Bank ESS relevant to the project and the role of NUC; • Coordination of ESF management • Stakeholder consultation, grievance redress mechanism and GBV management 14 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Summary of Stakeholder Workshop held at NUC, Abuja Date of Stakeholder 27th August, 2019 Workshop Venue Idris Adbulkadir Audotorium, National Universities Commission, 26, Aguiyi Ironsi Street, Maitama, Abuja. Participants NUC, World Bank, Federal Ministry of Finance, Federal Ministry of Women’s Affairs and Development, Federal Ministry of Environment, Civil Society Organizations, Academia, Highlights of Discussion Stakeholders were introduced to the Environmental and Social Management Framework (ESMF). The ESMF was described as an instrument used to identify and manage the environmental and social risks of a project. The ESMF provides guidelines and procedures to be followed in preparing and implementing site specific ESMP by the respective CoEs. Stakeholders were informed about the various World Bank standards that are relevant to the SPESSE project. They were informed that the project is a low risk project on the account of no new construction being envisaged in the CoEs facilities however, environmental and social risks were anticipated which include but not limited to: • Risk of air pollution from poor handling of rehabilitation debris in the center of excellence • Noise pollution risk from movement of heavy duty vehicle during rehabilitation works • Poor waste management of electronic and rehabilitation wastes. • Gender based violence issues from exposure of students to construction workers • Gender discrimination inhibiting female participation in the SPESSE project. • Theft of procured materials. Participants were informed that the various proposed mitigation strategies for the identified risks will be contained in the ESMF document and disclosed for public accessibility and input in accordance to the guideline of Federal Ministry of Environment and also at the World Bank external website. Questions and Concerns The questions and concerns raised by the participants are as follows; • Project considerations about the issues of climate change • What will be done about the electronic wastes 15 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA • What are the mitigation strategies adopted for the identified risks • What is the level of engagement of the stakeholders • How do we ensure attitudinal change towards environmental management in Nigeria? How questions and • Since the project is a low risk project, it is not envisaged that activities Concerns were addressed during implementation will contribute to climate change issues. However, activities such as burning of e-waste and debris will be avoided through good waste management practices which shall be enshrined in the ESMP to be prepared by the CoEs during implementation. • The mitigation strategies for the various identified risks are contained in the ESMF document which would be made available to the public during public disclosure. • Concerning e-waste disposal, the ESMF recognizes that when the specific sites and type of activities and volume of e-waste from the project would have been known in sufficient details, each implementing agency will prepare a waste management plan as an annex of the ESMP instrument required for safeguard implementation. • On the issue of attitudinal change regarding environmental and social standards, the CoEs are committed by the ESMF/ESMP to demonstrate compliance and commitment in implementation of mitigation measures which will give rise to good practices and change. Summary/Conclusion A participant from a representing civil society organization stated how they can be utilized in capacity building especially on social issues, through volunteer work. Addition of disaster risk management into the ESMF was suggested but the likelihood of it occurring in the existing universities is low and unlikely as no history or pattern of such is known in the participating CoEs. It was agreed that further comments or suggestions can still be added when the project documents like the ESMF, SEP have been publicly disclosed. Participants expressed their appreciation of the future impacts the project will have on development in Nigeria. 4.2 Engagement Methods and Tools The project will utilize various methods of engagement that will be used by the implementing agencies as part of their continuous interaction with the stakeholders. For the engagement process to be effective and meaningful, a range of techniques need to be applied that are specifically tailored to the identified stakeholder groups. Methods used for consulting with Government officials may be different from a format of liaising with the local communities (e.g. focus group discussions, displays and visuals with a lesser emphasis on technical aspects). The format of every engagement activity should meet general requirements on accessibility, i.e. should be held at venues that are easily reachable and do not require long commute, entrance fee or 16 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA preliminary access authorization, cultural appropriateness (i.e. with due respect to the local customs and norms), and inclusivity, i.e. engaging all segments of the project affected parties including the vulnerable individuals. If necessary, logistical assistance should be provided to enable participants from the remote areas, persons with limited physical abilities and those with insufficient financial or transportation means to attend public meetings scheduled by the project. Ensuring the participation of vulnerable individuals and groups in project consultations may require the implementation of tailored techniques. The vulnerable groups identified by the project include the rural population, people living with disabilities, women, and disadvantaged youth. Particular attention will be given to the vulnerable groups to ensure that they are not denied project benefits. This will be done by focus group discussions, monitoring participation rates, undertaking beneficiary assessments, using online platforms to allow access to otherwise disadvantaged groups, and ensuring that at least 30% of participant trainees are females. Information that is communicated in advance of public consultations primarily includes an announcement thereof in the public media – local, regional and national, as well as the distribution of invitations and full details of the forthcoming meeting well in advance, including the agenda. It is crucial that this information is widely available, readily accessible, clearly outlined, and reaches all areas and segments of the stakeholders. These parameters can be achieved through the following approaches: • Advance public notification of an upcoming consultation meeting follows the same fundamental principles of communication. That is, it should be made available via publicly accessible locations and channels. The primary means of notification may include mass media and the dissemination of posters/ advertisements in public places. The project keeps proof of the publication (e.g. a copy of the newspaper announcement) for accountability and reporting purposes. Existing notice boards in the implementing agencies and the universities may be particularly useful for distributing the announcements. When the notifications are placed on public boards in open air, it should be remembered that the posters are exposed to weather, may be removed by by-passers or covered by other advertisements. The project’s staff will therefore maintain regular checks in order to ensure that the notifications provided on the public boards remain in place and legible. • Another critical aspect of the meeting preparation process is selecting the methods of communication that reach the potential audience with lower levels of literacy or those who are not well-versed in the technical aspects of the project. Oral communication is an option that enables the information to be readily conveyed to such persons. This includes involving the selected stakeholder representatives and institutional leaders to relay up-to-date information on the project and consultation meetings to the various target audiences. Advertising the project and the associated meetings via radio or television and making direct calls (in case fixed-line or mobile phone communication is available) is another method that allows reaching out to the remote audiences. The announcement of a public meeting or a hearing is made sufficiently in advance, thereby enabling participants to make necessary arrangements, and provides all relevant details, including date, time, location/venue and contact persons. • Placement of the project materials in the public domain is also accompanied by making available a register of comments and suggestions that can be used by any member of the affected parties, other stakeholders and general public to provide their written feedback on 17 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA the contents of the presented materials. As a rule, the register is made available for the entire duration of the requisite disclosure period. Where necessary, a project representative or an appointed consultant should be made available to receive and record any verbal feedback in case some stakeholders experience a difficulty with providing comments in the written form. • Drafting an agenda for the consultation meeting is an opportunity to provide a clear and itemized outline of the meeting’s structure, sequence, chairpersons, a range of issues that will be discussed and a format of the discussion (e.g. presentation/ demonstration followed by a Questions & Answers – Q&A session, facilitated work in small groups, feature story and experience sharing, thematic sessions with a free speaking format enabling the mutual exchange of ideas). A clearly defined scope of issues that will be covered at the meeting gives the prospective participants an opportunity to prepare their questions and comments in advance. It is essential to allocate a sufficient amount of time for a concluding Q&A session at the end of any public meeting or a hearing. This allows the audience to convey their comments and suggestions that can subsequently be incorporated into the design of the project. Keeping a record of all public comments received during the consultations meetings enables the project’s responsible staff to initiate necessary actions, thereby enhancing the project’s overall approach taking onto consideration the stakeholders’ priorities. The recorded comments and how they have been addressed by the project becomes an appropriate material for inclusion in the project’s regular reporting to the stakeholders. As a possible option in addition to the Q&A session nearer the close of the public meeting/hearing, evaluation (feedback) forms may be distributed to participants in order to give them an opportunity to express their opinion and suggestions on the project. This is particularly helpful for capturing individual feedback from persons who may have refrained from expressing their views or concerns in public. Questions provided in the evaluation form may cover the following aspects: ➢ Participant’s name and affiliation (these items are not mandatory if the participant prefers to keep the form confidential) ➢ How did they learn about the Project and the consultation meeting? ➢ Are they generally in favour of the Project? ➢ What are their main concerns or expectations associated with the Project or the particular activity discussed at the meeting? ➢ Do they think the Project is of benefit to them and the stakeholder group they represent? ➢ Is there anything in the Project design and implementation that they would like to change or improve? ➢ Do they think that the consultation meeting has been useful in understanding the specific activities of the Project, as well as associated benefits and outcomes? What aspects of the meeting do they particularly appreciated or would recommend for improvement? Bearing in mind that some of the participants might find completion of the evaluation form challenging due to the literacy constraints or concerns about their confidentiality, the distribution of the feedback forms should always be explained that completing the form is optional. Project beneficiaries should also be assured that completion of the evaluation form is entirely voluntary and does not affect their status as beneficiaries. Some persons may be willing to express their feedback verbally and in this case a member of Project staff will be allocated to take notes. 18 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA • Distribution of targeted invitations to the consultation meeting or a hearing is an important element of the preparation process and is based on the list of participants that is compiled and agreed in advance of the consultation. Invitations may be sent both to certain individuals that have been specifically identified as relevant stakeholders (e.g. representatives of government ministries and agencies) and as public invitees (e.g. addressed to initiative and professional bodies, local organizations, and other public entities).. Means of distributing the invitations should be appropriate to the customary methods of communication that prevail for the stakeholder. The various means of distribution that can be used includes direct mail (post); other existing public mailings, utility bills, or circulars from a local authority.. All invitations that are sent can be tracked in order to determine and manage the response rate. If no response has been received, the invitation can be followed up by a telephone call or e- mail where possible. 4.5 Description of Engagement Methods International standards increasingly emphasize the importance of a consultation being ‘free, prior and informed’, which implies an accessible and unconstrained process that is accompanied by the timely provision of relevant and understandable information. In order to fulfil this requirement, a range of consultation methods are applied. A summary description of the engagement methods and techniques that will be applied by project developer is provided in Error! Reference source not found. below. The summary presents a variety of approaches to facilitate the processes of information provision, information feedback as well as participation and consultation. An attendance list should be made available at the commencement of all engagement activities in order to record all participants who are present at the meeting. Wherever possible, attendees’ signatures should be obtained as a proof of their participation. Details of the attendees who were not initially on the list (e.g. those participating in place of somebody else, or general public) should be included in addition to those who have registered for the meeting in advance. In most cases and as a general practice, the introductory initial part of the meeting should be delivered in a format that is readily understandable to the audience of laypersons and should be free of excessive technical jargon. If necessary, preference should be given, whenever possible, to the oral and visual methods of communication (including presentations, pictorials, illustrations, graphics and animation) accompanied by hand-out materials imparting the relevant information in understandable terms rather than as text laden with technical intricacies. If a large audience is expected to attend a public meeting or a hearing, necessary arrangements will be made to ensure audibility and visibility of the presentations. This includes provision of a microphone, proper illumination, projector, places allocated for the wheelchair users, etc. Taking records of the meeting is essential both for the purposes of transparency and the accuracy of capturing public comments. At least three ways of recording may be used, including: • Taking written minutes of the meeting by a specially assigned person or a secretary; 19 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA • audio recording (e.g. by means of voice recorders); and • Photographing. The latter should be implemented with a reasonable frequency throughout the meeting, allowing notable scenes to be captured but at the same time not distracting or disturbing the audience excessively. Where feasible, a video recording may also be undertaken. Combination of these methods ensures that the course of the meeting is fully documented and that there are no significant gaps in the records which may result in some of the important comments received from the stakeholder audience being overlooked. Table 1 shows some tools for engagement for information disclosure and feedback. 20 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Table 1: Methods/Tools for Information Provision, Feedback, Consultation and Participation Method / Tool Description and Use Contents Dissemination Method Target Groups Information Provision Distribution of Used to convey information on Printed materials present Distribution as part of ▪ Government Ministries, printed public the Project and regular updates illustrative and written consultation meetings, awareness Departments and Agencies materials: leaflets, on its progress to local, regional information on the SPESSE campaigns, discussions and ▪ All project affected parties brochures, fact and national stakeholders. program. meetings with stakeholders. sheets ▪ Project interested parties Presented contents are concise, clear and easy to understand by a ▪ Other potential stakeholders layperson reader. Graphics and pictorials are widely used to describe technical aspects and aid understanding. Distribution of A newsletter or an update circular Important highlights of Project Circulation of the newsletter or ▪ All projected affected parties printed public sent out to Project stakeholders achievements, announcements of update sheet with a specified ▪ All project interested parties materials: on a regular basis to maintain planned activities, changes, and frequency in the Project Area of newsletters/ awareness of the Project overall progress. Influence, as well as to any other ▪ Implementing Universities updates development. stakeholders that expressed their ▪ Government Ministries, interest in receiving these Departments and Agencies periodicals. Means of distribution – post, emailing, electronic subscription, delivery in person. The mailed material can be accompanied by an enclosed postage-paid comment/feedback form that a reader can fill in a return to the Project’s specified address. 21 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Method / Tool Description and Use Contents Dissemination Method Target Groups Printed Inserts, announcements, press Notification of forthcoming public Placement of paid information in ▪ All projected affected parties advertisements in releases, short articles or feature events or commencement of local, regional and national ▪ All project interested parties the media stories in the printed media – specific Project activities. printed media, including those newspapers and magazines intended for general reader and ▪ Other potential stakeholders General description of the Project and its benefits to the specialised audience stakeholders. Radio or television Short radio programmes, video Description of the Project, Project Collaboration with media ▪ Government Ministries, entries materials or documentary development update and producers that operate in the Departments and Agencies broadcast on TV. processes. region and can reach local ▪ Implementing universities Advance announcement of the audiences. ▪ All projected affected parties forthcoming public events or commencement of specific All project interested parties Project activities. Other potential stakeholders Visual presentations Visually convey Project Description of the Project Presentations are widely used as ▪ Participants of the public information to affected activities, processes and timeline. part of the public hearings and hearings, consultations, rounds communities and other interested Updates on Project development. other consultation events with tables, focus group discussions audiences. various stakeholders. and other forums attended by Project stakeholders. ▪ Government Ministries, Departments and Agencies Notice boards Displays of printed information on Advance announcements of the Printed announcements and ▪ All projected affected parties notice boards in public places. forthcoming public events, notifications are placed in visible ▪ All project interested parties commencement of specific and easily accessible places Project activities, or changes to frequented by the local public, ▪ Other potential stakeholders the scheduled process. including libraries, village cultural centres, post offices, shop, local administrations. 22 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Method / Tool Description and Use Contents Dissemination Method Target Groups Information Feedback Information Placement of Project-related Various Project-related materials Deposition of materials in publicly ▪ All projected affected parties repositories information and printed materials and documentations. available places (offices of local ▪ accompanied by a in dedicated/designated locations NGOs, local administrations, feedback that also provide visitors and libraries) for the duration of a mechanism readers with an opportunity to disclosure period or permanently. leave their comments in a Audience are also given free feedback register. access to a register of comments and suggestions. Dedicated Setting up a designated and Any issues that are of interest or Telephone numbers are specified telephone line manned telephone line that can concern to the direct project on the printed materials ▪ Any project stakeholder and (hotline) be used by the public to obtain beneficiaries and other distributed to Project interested parties. information, make enquiries, or stakeholders. stakeholders and are mentioned provide feedback on the Project. during public meetings. Initially, telephone numbers of Project’s designated staff should Project’s specialised staff can be be assigned to answer and shared with the public, respond to the calls, and to direct particularly staff involved in callers to specialist experts or to stakeholder engagement, public offer a call-back if a question relations and environmental requires detailed consideration. protection. Internet/Digital Launch of Project website to Information about Project A link to the Project web-site ▪ Project stakeholders and other Media promote various information and operator and shareholders, should be specified on the printed interested parties that have updates on the overall Project, Project development updates, materials distributed to access to the internet resources. impact assessment and impact employment and procurement, stakeholders. management process, environmental and social aspects. Other on-line based platforms can procurement, employment also be used, such as web- opportunities, as well as on conferencing, webinar Project’s engagement activities presentations, web-based with the public. 23 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Method / Tool Description and Use Contents Dissemination Method Target Groups Web-site should have a built-in meetings, Internet surveys/polls feature that allows viewers to etc. leave comments or ask questions Limitation: Not all about the Project. parties/stakeholders have access Website should be available in to the internet, especially in the English remote areas and in communities. Surveys, Interviews The use of public opinion surveys, Description of the proposed Soliciting participation in ▪ All project affected parties. and Questionnaires interviews and questionnaires to Project and related processes. surveys/interviews with specific obtain stakeholder views and to Questions targeting stakeholder stakeholder groups. complement the statutory perception of the Project, Administering questionnaires as process of public hearings. associated impacts and benefits, part of the household visits. concerns and suggestions. Feedback & A suggestion box can be used to Any questions, queries or Appropriate location for a ▪ Project affected parties, Suggestion Box encourage residents in the concerns, especially for suggestion box should be selected especially vulnerable groups. affected communities to leave stakeholders that may have a in a safe public place to make it written feedback and comments difficulty expressing their views readily accessible for the about the Project. and issues during public meetings. stakeholders. Contents of the suggestion box Information about the availability should be checked by designated of the suggestion box should be Project staff on a regular basis to communicated as part of Project’s ensure timely collection of input regular interaction with local and response/action, as stakeholders. necessary. Consultation & Participation Public hearings Project representatives, the Detailed information on the Wide and prior announcement of ▪ Project affected parities affected public, authorities, activity and/or facility in question, the public hearing and the 24 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Method / Tool Description and Use Contents Dissemination Method Target Groups regulatory bodies and other including a presentation and an relevant details, including ▪ Relevant government Ministries stakeholders for detailed interactive Questions & Answers notifications in local, regional and Departments and Agencies. discussion on a specific activity or session with the audience. national mass media. ▪ NGOs and civil societies facility that is planned by the Targeted invitations are sent out Project and which is subject to the ▪ Other interested parties to stakeholders. statutory expert review. Public disclosure of Project materials and associated impact assessment documentation in advance of the hearing. Viewers/readers of the materials are also given free access to a register of comments and suggestions that is made available during the disclosure period. Focus Group Used to facilitate discussion on Project’s specific activities and Announcements of the ▪ All project affected parties Discussions and Project’s specific issues that merit plans, processes that require Forthcoming meetings are widely especially vulnerable groups; Round Table collective examination with detailed discussion with affected circulated to participants in ▪ Project delivery agencies Workshops various groups of stakeholders. stakeholders. advance. ▪ SPESSE employees and Targeted invitations are sent out contractors to stakeholders. ▪ NGOs and civil societies ▪ Implementing Universities ▪ Relevant Government Ministries and Agencies Project Project’s designated venue for Project-related materials. Information about the info centre ▪ All project affected parties Implementation depositing Project-related Any issues that are of interest or or a field office with open hours ▪ Project interests’ parties Units (PIUs) information that also offers open concern to the local communities for the public, together with hours to the stakeholders and contact details, is provided on the ▪ Other potential stakeholders and other stakeholders. other members of the public, with Project’s printed materials Project staff available to respond distributed to stakeholders, as 25 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Method / Tool Description and Use Contents Dissemination Method Target Groups to queries or provide well as during public meetings clarifications. and household visits. 26 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA 4.6 Description Disclosure Methods As a standard practice, this SEP in English will be released for public review for the period of 30 days in accordance with Nigerian regulatory frameworks. Distribution of the disclosure materials will be done by making them available at venues and locations convenient for the stakeholders and places to which the public have unhindered access. Free printed copies of the SEP in English will be made accessible for the general public at the following locations: • Federal Ministry of Finance; • Federal Ministry of Women Affairs and Social Development; • Environmental Assessment Department; • The Ministries under the Technical Working Group; • National Universities Commission; • Bureau of Public Procurement; • SPESSECE at the Implementing Universities; and • Other designated public locations to ensure wide dissemination of the materials. Electronic copies of the SEP will be placed on the website of the Bank and each implementing agencies. This will allow stakeholders with access to Internet to view information about the planned development and to initiate their involvement in the public consultation process. The web-site will be equipped with an on-line feedback feature that will enable readers to leave their comments in relation to the disclosed materials. The mechanisms which will be used for facilitating input from stakeholders will include press releases and announcements in the media, notifications of the aforementioned disclosed materials to local, regional and national NGOs, relevant professional bodies as well as other interested parties. 4.3.1 Timetable for Disclosure The disclosure process associated with the release of project E&S appraisal documentation, as well as the accompanying SEP will be implemented within the following timeframe: • Placement of the SEP in public domain – Dates to be confirmed by SPESSE Implementing Agencies • 30-day disclosure period – Dates to be confirmed by SPESSE Implementing Agencies • Public consultation meetings with project stakeholders to discuss feedbacks and perceptions about the program – Dates to be confirmed by SPESSE Implementing Agencies • Addressing stakeholder feedback received on the entire disclosure package – Dates to be confirmed by SPESSE Implementing Agencies. 27 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA The SEP will remain in the public domain for the entire period of project development and will be updated on a regular basis as the project progresses through its various phases, in order to ensure timely identification of any new stakeholders and interested parties and their involvement in the process of collaboration with the project. The methods of engagement will also be revised periodically to maintain their effectiveness and relevance to the project’s evolving environment. The outline presented in the table below summarizes the main stakeholders of the project, types of information to be shared with stakeholder groups, as well as specific means of communication and methods of notification. Table 2 below provides a description of stakeholder engagement and disclosure methods recommended to be implemented during stakeholder engagement process. Table 2: Stakeholder Engagement and Disclosure Methods Stakeholder Group Project Information Shared Means of communication/ disclosure Project Affected Stakeholder Engagement Plan; Public notices. Parties Public Grievance Procedure; Electronic publications and press Regular updates on Project releases on the Project web-site. development. Dissemination of hard copies at designated public locations. Press releases in the local media. Consultation meetings. Information leaflets and brochures. Separate focus group meetings with vulnerable groups, as appropriate. Non-governmental Stakeholder Engagement Plan; Public notices. Organizations Public Grievance Procedure; Electronic publications and press Regular updates on Project releases on the project web-site. development. Dissemination of hard copies at designated public locations. Press releases in the local media. Consultation meetings. Information leaflets and brochures. Ministries, Stakeholder Engagement Plan; Dissemination of hard copies of the Departments and Regular updates on Project ESMF, ESMP package, and SEP at Agencies development; municipal administrations. Additional types of Project’s Project status reports. information if required for the Meetings and round tables. purposes of regulation and permitting. Implementing Stakeholder Engagement Plan; Public Notices Universities Regular updates on Project Consultation Meetings development; Information leaflets and brochures. Additional types of Project’s information if required for the purposes of implementation and timeline. 28 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Stakeholder Group Project Information Shared Means of communication/ disclosure Related businesses Stakeholder Engagement Plan; Electronic publications and press and enterprises Public Grievance Procedure; releases on the Project web-site. Updates on Project development Information leaflets and brochures. and tender/procurement Procurement notifications. announcements. Project Employees Employee Grievance Procedure; Staff handbook. Updates on Project development. Email updates covering the Project staff and personnel. Regular meetings with the staff. Posts on information boards in the offices and on site. Reports, leaflets. 29 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA 5.0 Grievance Management In compliance with applicable local and national laws and essentially the World Bank’s ESS10, a project - specific mechanism is being set up to handle complaints and issues. This process would be specially designed to collect, collate, review and redress stakeholders’ concerns, complaints and grievances. This process will be carried out using dedicated communication materials (specifically, a GRM brochure or pamphlet) which will be developed to help stakeholders become familiar with the grievance redress channels and procedures. Locked suggestion/complaint boxes will be posted in each implementing agency and university and they will maintain a grievance register in order to capture and track grievances from submission to resolution and communication with complainants. Project website (and that of the implementing agencies) will include clear information on how feedback, questions, comments, concerns and grievances can be submitted by any stakeholder. It will also provide information on the way grievances will be handled, both in terms of process and deadlines. 5.1 Grievance Redress Mechanism (GRM) Project-affected-people and any other stakeholders may submit comments or complaints at any time by using the project’s Grievance Redress Mechanism (GRM). The overall objectives of the GRM are to: • Provide a transparent process for timely identification and resolution of issues affecting the project and people, including issues related to specifics in program components. • Strengthen accountability to beneficiaries, including project affected people. The GRM will be accessible to all external project stakeholders, including affected people, community members, civil society, media, and other interested parties. Stakeholders can use the GRM to submit complaints, feedback, queries, suggestions, or even compliments related to the overall management and implementation of the program as it affects them. The GRM is intended to address issues and complaints in an efficient, timely, and cost-effective manner. The initial effort to resolve grievances to the complainant’s satisfaction will be undertaken by the participating section / unit of the each implementing agency /universities. If the unit is not successful in resolving the grievance, the grievance would be escalated to the implementing agency’s grievance unit and if unsuccessful at this stage, the grievance will be escalated to the SPESSE Ombudsman. All grievance that cannot be resolved at the ombudsman level shall be allowed to go the court of law. 5.2 Grievance Resolution Framework Information about the GRM will be publicized as part of the initial program consultations and disclosure in all the participating agencies. Brochures will be distributed during consultations and public meetings, and posters will be displayed in public places such as in government offices, project implementation unit offices, notice boards available to strategic stakeholders, etc. Information about the GRM will also be posted online at the universities’ and other implementing agencies’ websites. The overall grievance resolution framework will include six steps described below. The six steps demonstrate a typical grievances resolution process. • Step 1: Uptake. Project stakeholders will be able to provide feedback and report complaints through several channels such as filling up grievance forms, reporting grievances to 30 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA implementing agencies, submitting grievance via email address made available by the implementing units and via the implementing institutions’ websites collection boxes stipulated for the grievance uptake. • Step 2: Sorting and processing. Each unit / department of the implementing institutions will conduct a prompt sorting and processing of all grievances. The processing will involve the internal escalation process to specific desks to review, resolve and respond to grievances raised. • Step 3: Acknowledgement and follow-up. Within seven (7) days of the date a complaint is submitted, the responsible person within the unit will communicate with the complainant and provide information on the likely course of action and the anticipated timeframe for resolution of the complaint. The information provided to complainant would also include, if required, the likely procedure if complaints had to be escalated outside the unit and the estimated timeline for each stage. • Step 4: Verification, investigation and action. This step involves gathering information about the grievance to determine the facts surrounding the issue and verifying the complaint’s validity, and then developing a proposed resolution. It is expected that many or most grievances would be resolved at this stage. All activities taken during this and the other steps will be fully documented, and any resolution logged in the register. Step 5: Monitoring and evaluation. Monitoring refers to the process of tracking grievances and assessing the progression toward resolution. Each implementing agency would develop and maintaining a grievance register and maintain records of all steps taken to resolve grievances or otherwise respond to feedback and questions. Step 6: Providing Feedback. This step involves informing those who have raised complaints, concerns or grievances the resolutions to the issues they have raised. Whenever possible, complainants should be informed of the proposed resolution in person, which gives them the opportunity ask follow-up questions which could be answered on the spot for total resolve. If the complainant is not satisfied with the resolution, he or she will be informed of further options, which would include pursuing remedies through the World Bank, as described below, or through a court of competent jurisdiction. 5.3 SPESSE Grievance Escalation Process GRM Stage One - Specific Implementing Department Level Resolve This stage would be formed of grievances collection points by specific units of the implementing agencies. As stated in the six steps framework above, this stage would involve the uptake; collation, sorting and processing; acknowledgement and the resolve as described in stage 4 – verification, investigation and action. All implementing agencies would attempt a full resolve of grievances at this stage as much as practical. A typical example of this stage process is the Centre of Excellence (CE) activating steps 1 to 4 as stated above to respond to all grievances raised to the institution. The CE would deploy all effort as much 31 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA as practical at this stage to ensure all grievances raised to it has been adequately resolved to the satisfaction of all parties involved. Should the complainant not be satisfied at stage one, the grievances shall be escalated to stage two. GRM Stage Two – Implementing Agency Level Resolve The central platform for receiving, sorting and assigning stage two grievance will be located in the NUC. Once received, sorted and processed at NUC, grievances related to different implementing agencies will be forwarded to the respective agencies. The stage two is a grievance redress platform led by the main implementing agencies. Every implementing agency would establish a grievance management unit which would deal with all the grievances escalated to it from the different units. These implementing agencies would apply the stage four as mentioned under the framework to address and resolve all grievances promptly and communicate the feedback to the complainants. Any complaints or grievances not resolved at this stage shall be escalated to the SPESSE Ombudsman. GRM Stage Three – SPESSE Ombudsman Level Resolve The SPESSE Ombudsman shall be formed of key officers from all the implementing agencies. The ombudsman shall be responsible for resolving all grievances escalated to it. The ombudsman shall meet quarterly to review the grievance registers maintained by each implementing agency and use the same to update the grievance dashboard which shall be the compendium of all grievances raised across implementing agencies. 5.4 Grievance logs Each implementing agency shall establish a grievance uptake point. • Individual reference number • Name of the person submitting the complaint, question, or other feedback, address and/or contact information (unless the complaint has been submitted anonymously) • Details of the complaint, feedback, or question/her location and details of his / her complaint. • Date of the complaint. • Name of person assigned to deal with the complaint (acknowledge to the complainant, investigate, propose resolutions, etc.) • Details of proposed resolution, including person(s) who will be responsible for authorizing and implementing any corrective actions that are part of the proposed resolution. • Date when proposed resolution was communicated to the complainant (unless anonymous). • Date when the complainant acknowledged, in writing if possible, being informed of the proposed resolution. • Details of whether the complainant was satisfied with the resolution, and whether the complaint can be closed out • If necessary, details of escalation procedure • Date when the resolution is implemented (if any). 32 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA 5.5 Monitoring and reporting on grievances Day-to-day implementation of the GRM and reporting to the World Bank will be the responsibility of the . To ensure management oversight of grievance handling, the NUC will be responsible for monitoring the overall process, including verification that agreed resolutions are actually implemented. 5.6 Points of contact Information on the project and future stakeholder engagement programs will available on the project’s website and will be posted on information boards In the respective project implementation Units The point of contact regarding the stakeholder engagement program are: Federal Ministry of Environment Description Contact details Name and position Mrs Aishat Odetoro, Project Coordinator Address: Environmental Assessment Department, Federal Ministry of Environment, Abuja E-mail: bukkiebukola@yahoo.com Telephone: To be provided Federal Ministry of Women Affairs and Social Development Description Mr Valentine Ezulu , Project Coordinator Name and position Address: Federal Ministry of Women Affairs, Abuja E-mail: valo142000@yahoo.com Telephone: To be provided Federal Ministry of Finance Description Contact details Name and position Project Coordinator Address: International Economic Relations Department, Federal Ministry of Finance, Abuja E-mail: Telephone: To be provided Bureau of Public Procurement 33 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Description Contact details Name and position Project Coordinator Address: Bureau of Public Procurement, Abuja E-mail: Telephone: To be provided Nigeria Universities Commission Description Contact details Name and position Dr Joshua Atah Address: National Universities Commission, Abuja E-mail: jaatah@nuc.edu.ng Telephone: To be provided 5.7 World Bank Grievance Redress System Communities and individuals who believe that they are adversely affected by a project supported by the World Bank may also complain directly to the Bank through the Bank’s Grievance Redress Service (GRS) (http://projects-beta.worldbank.org/en/projects-operations/products-and-services/grievance-redress- service). A complaint may be submitted in English, or in local languages, although additional processing time will be needed for complaints that are not in English. A complaint can be submitted to the Bank GRS through the following channels: • By email: grievances@worldbank.org • By fax: +1.202.614.7313 • By mail: The World Bank, Grievance Redress Service, MSN MC10-1018, 1818 H Street Northwest, Washington, DC 20433, USA • Through the World Bank Nigeria Country Office in Abuja: 102 Yakubu Gowon Crescent, Asokoro , Abuja The complaint must clearly state the adverse impact(s) allegedly caused or likely to be caused by the Bank- supported project. This should be supported by available documentation and correspondence to the extent possible. The complainant may also indicate the desired outcome of the complaint. Finally, the complaint should identify the complainant(s) or assigned representative/s, and provide contact details. Complaints submitted via the GRS are promptly reviewed to allow quick attention to project-related concerns. In addition, project-affected communities and individuals may submit complaints to the World Bank’s independent Inspection Panel, which will then determine whether harm occurred, or could occur, as a result of the World Bank’s non-compliance with its policies and procedures. Complaints may be submitted 34 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA to the Inspection Panel at any time after concerns have been brought directly to the World Bank’s attention, and after Bank Management has been given an opportunity to respond. Information on how to submit complaints to the World Bank Inspection Panel may be found at www.inspectionpanel.org. 35 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA 6.0 Monitoring and Reporting The Stakeholder Engagement Plan will be periodically revised and updated as necessary in the course of capacity building program implementation in order to ensure that the information presented herein is consistent and is the most recent, and that the identified stakeholders and methods of engagement remain appropriate and effective in relation to the project context and specific stages of the implementation. Any major changes to the project related activities and to its schedule will be duly reflected in the SEP. 6.1 Reporting Monthly summaries and internal reports on public grievances, enquiries and related incidents, together with the status of implementation of associated corrective/preventative actions will be collated by responsible staff and referred to the senior management of the project(s). The monthly summaries will provide a mechanism for assessing both the number and the nature of complaints and requests for information, along with the Project’s ability to address those in a timely and effective manner. Information on public engagement activities undertaken by the Project during the year may be conveyed to the stakeholders in two possible ways: • Publication of a standalone annual report on project’s interaction with the stakeholders. • A number of Key Performance Indicators (KPIs) will also be monitored by the project on a regular basis, including the following parameters: - Number of public hearings, consultation meetings and other public discussions/forums conducted within a reporting period (e.g. monthly, quarterly, or annually); - Frequency of public engagement activities; - Geographical coverage of public engagement activities – number of locations and Universities covered by the consultation process; - Number and details of vulnerable individuals involved in consultation meetings; - Number of public grievances received within a reporting period (e.g. monthly, quarterly, or annually) and number of those resolved within the prescribed timeline; - Type of public grievances received; - Number of press materials published/broadcasted in the local, regional, and national media; 6.2 Training SPESSE Implementing agencies will arrange necessary training associated with the implementation of this SEP that will be provided to the members of staff who, due to their professional duties, may be involved in interactions with the external public, as well as to the senior management. Specialized training will also be provided to the staff appointed to deal with stakeholder grievances as per the Public Grievance Procedure. 36 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA Project contractors and selected representatives will also receive necessary instructions for the Grievance Procedure. 37 SPESSE Program Draft Stakeholder Engagement Plan, August 2019 FEDERAL REPUBLIC OF NIGERIA 38 SPESSE Program Draft Stakeholder Engagement Plan, August 2019