STAKEHOLDER ENGAGEMENT PLAN (SEP) REPUBLIC OF TURKEY MINISTRY OF INDUSTRY AND TECHNOLOGY SOCIAL ENTREPRENEURSHIP, EMPOWERMENT AND COHESION IN REFUGEE AND HOST COMMUNITIES IN TURKEY PROJECT Draft STAKEHOLDER ENGAGEMENT PLAN 27 November 2019 1 STAKEHOLDER ENGAGEMENT PLAN (SEP) GLOSSARY Consultation: The process of gathering information or advice from stakeholders and taking these views into account when making project decisions and/or setting targets and defining strategies. Dialogue: An exchange of views and opinions to explore different perspectives, needs and alternatives, with a view to fostering mutual understanding, trust and cooperation on a strategy or initiative. Local communities: Refers to groups of people living in close proximity to a project that could potentially be impacted by a project. (“Stakeholders,� in contrast, refers to the broader group of people and organizations with an interest in the project.) Community Implementing Partners: Refers to local community-based, and non-governmental organizations, foundations or a consortium of such entities with private service providers that have sound knowledge of and access into communities through trusting relationships and will deliver a holistic set of services to both refugees and host communities. Partnerships: In the context of engagement, partnerships are defined as collaboration between people and organizations to achieve a common goal and often share resources and competencies, risks and benefits. Project: Refers to Social Entrepreneurship, Empowerment and Cohesion Project, which is funded under the European Union Commission’s Facility for Refugees in Turkey (FRIT). Project Area: A geographical area within which direct and indirect impacts attributable to a project can be expected. Typically, a Project Area is (i) unique to a project (ii) larger than the actual footprint of a project; and encompasses socio-economic issues and impacts, as well as issues and impacts associated with other disciplines (e.g. environment, health and safety). Defining the Project Area is used to determine a project’s area of influence and responsibilities. It also provides guidance on the area within which impacts need to be monitored, and managed, and it also assists with defining project stakeholders that should be engaged during an environmental and social assessment process. Stakeholder: Refers to individuals or groups who: (a) are affected or likely to be affected by the project (project-affected parties); and (b) may have an interest in the project (other interested parties). Stakeholder engagement: It is a continuous process used by the project to engage relevant stakeholders for a clear purpose to achieve accepted outcomes. It includes a range of activities and interactions over the life of the project such as stakeholder identification and analysis, information disclosure, stakeholder consultation, negotiations and partnerships, grievance management, stakeholder involvement in project monitoring, reporting to stakeholders and management functions. It includes both state and non-state actors. 2 STAKEHOLDER ENGAGEMENT PLAN (SEP) Table of Contents GLOSSARY .................................................................................................................................................... 2 ABBREVIATIONS .......................................................................................................................................... 5 1. INTRODUCTION ...................................................................................................................................... 7 1.1 About the Project ................................................................................................................................. 8 1.2 SEP Objectives and Scope ................................................................................................................. 11 2. NATIONAL REGULATIONS AND INTERNATIONAL STANDARDS ...................................................... 12 2.1 National Regulations ......................................................................................................................... 12 2.2 World Bank Environmental and Social Standards on Stakeholder Engagement ...................... 13 3. BRIEF SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES ................................ 14 3.1 Key Stakeholder Meetings and Consultations ............................................................................... 14 3.2 Lessons Learned in Engaging Communities/Stakeholders from Previous Projects .................. 16 4. STAKEHOLDER MAPPING AND ANALYSIS ......................................................................................... 19 4.1 Stakeholder Mapping and Analysis ................................................................................................. 19 4.2 Stakeholder Analysis ......................................................................................................................... 24 5. STAKEHOLDER ENGAGEMENT PROGRAM ........................................................................................ 33 5.1 Overview of Stakeholder Engagement Program ........................................................................... 33 5.2 Overview of Stakeholder Engagement Methods .......................................................................... 39 5.2.1 Consultation Meetings .............................................................................................................. 39 5.2.2 Participatory Engagement Methods........................................................................................ 39 5.2.3 Participatory Assessment .......................................................................................................... 39 5.2.5 Information Desks ...................................................................................................................... 39 5.2.6 Grievance Redress Mechanism ................................................................................................ 39 5.2.7 Training workshops .................................................................................................................... 40 5.2.8 Communication Materials......................................................................................................... 40 5.2.9 Presentations .............................................................................................................................. 40 5.2.10 Project Brochure ...................................................................................................................... 40 6. IMPLEMENTATION ARRANGEMENTS FOR STAKEHOLDER ENGAGEMENT .................................. 40 6.1 Elaboration of Stakeholder Engagement Responsibilities ........................................................... 40 6.2 Information Disclosure ...................................................................................................................... 41 6.3 Estimated Budget............................................................................................................................... 42 6.4 Monitoring and Reporting of the SEP ............................................................................................. 42 3 STAKEHOLDER ENGAGEMENT PLAN (SEP) 7. GRIEVANCE REDRESS MECHANISM ................................................................................................... 42 7.1 Purpose and Scope ............................................................................................................................ 42 7.2 GRM Overview & Structure .............................................................................................................. 43 7.3 GRM Communication & Process ...................................................................................................... 44 7.4 Grievance Logs ................................................................................................................................... 45 7.5 Monitoring and Reporting on Grievances ...................................................................................... 45 7.6 World Bank Grievance Redress System .......................................................................................... 46 Annex 1. Sample Grievance Form and Grievance Closeout Form ..................................................... 47 4 STAKEHOLDER ENGAGEMENT PLAN (SEP) ABBREVIATIONS CIP Community Implementing Partner CSO Civil Society Organization TDA Turkish Development Agency DGMM Directorate General for Migration Management ESMF Environmental and Social Management Framework ESSN Emergency Social Safety Net FRiT EU Facility for Refugees in Turkey GRM Grievance Redress Mechanism GT Government of Turkey EU European Union EUD European Union Delegation to Turkey M&E Monitoring and Evaluation MoIT Ministry of Industry and Technology NGO Non-Governmental Organization PIU Project Implementing Unit SEECO Social Entrepreneurship, Empowerment and Cohesion Project SEP Stakeholder Engagement Plan SGM Sub-Grant Manual TRC Turkish Red Crescent UN United Nations UNHCR United Nations Higher Commission for Refugees WB World Bank 5 STAKEHOLDER ENGAGEMENT PLAN (SEP) 6 STAKEHOLDER ENGAGEMENT PLAN (SEP) 1. INTRODUCTION Turkey is both a transit and reception country for migrants and refugees and hosts the highest number of refugees in the world. Turkey is hosting more than 3.6 million Syrians, who are under temporary protection, in addition to an estimated 400,000 asylum seekers and refugees from other nationalities. Turkish society has demonstrated resilience and innovation in the way it has absorbed displaced Syrians. Turkey has adopted a developmental approach to forced displacement, pursuing policies that have granted displaced Syrians access to services and to the labor market. In 2016, Turkey established the Emergency Social Safety Net (ESSN) program to address the basic needs of its refugee population, with financial support from the European Union’s Facility for Refugees in Turkey (FRiT) through its humanitarian arm, the Directorate-General for European Civil Protection and Humanitarian Aid Operations (DG-ECHO). As of March 2019, at a cost of 998 million EUR, more than 1.5 million displaced Syrians had benefited from this multi-purpose cash transfer program providing monthly assistance through debit cards to the most vulnerable refugees in Turkey. While the ESSN program has supported Syrians through a critical transitional stage, a major constraint of this program is its limited sustainability in ensuring that ESSN beneficiaries continue to use the skills and benefits that they have acquired to maintain and improve their economic self-reliance. The Government of Turkey has planned to phase out the ESSN in order to move toward more developmental approaches that help refugees pursue an independent socio-economic life in Turkey. The ESSN exit strategy calls for a focus on adopting comprehensive support programs that assist both host communities and refugees, and which proposes inclusive business and employment models that link refugees to economic opportunities to build self-reliance and strengthen their resilience. However, there are several barriers to sustainable employment for refugees and host communities. By March 2019, only 31,185 Syrians had received work permits.1 The low number of work permits issued is considered indicative of the information, language, and skills barriers facing the refugees. The result is that more than two thirds of Syrian households are unable to rely on predictable job opportunities and those who work in the informal sector may face exploitation and poor working conditions.2 Women refugees are particularly disadvantaged, often placing their children at greater risk.3 Despite the highly responsive efforts of the Turkish government, there are also emerging concerns regarding social cohesion in a number of affected communities. In 2017 and 2018, measures of social cohesion in Turkey within communities hosting Syrians revealed declines in trust, acceptance, and belonging, with some variance for location. Factors contributing to these tensions include the protracted nature of the displacement crisis, the decreasing likelihood of near-term return, declining economic performance within Turkey, enduring cultural and social distance between each community, and the broader regional political volatility. Perceptions that Syrians outcompete hosts for low-wage jobs and are pushing rents up, perceived violations of social norms by displaced communities, and perceived preferential access to public services and assistance for Syrians have also contributed to deteriorating social cohesion in host areas. 1 Ministry of Family, Labor and Social Services (MoFLSS). 2 Inter-Agency Coordination Turkey. Regional Refugee Resilience Plan 2019-2020 Turkey Chapter. 2018. Outcome Monitoring Report. 3 World Bank. 2017. ‘Syrians’ Employment Opportunities and Challenges in Turkey’. Qualitative Assessment (unpublished). 7 STAKEHOLDER ENGAGEMENT PLAN (SEP) 1.1 About the Project The project development objective is to improve women’s livelihoods and social cohesion for refugees and host communities in target areas in Turkey. Its beneficiaries will include refugees and host community members in provinces with high numbers of ESSN beneficiaries, with a special emphasis on female beneficiaries. Institutional beneficiaries will include MoIT, participating Development Agencies andlocal public bodies, primarily those with high refugee populations. Non-governmental organizations familiar with target communities will also benefit from their role in implementation. The project provinces (and relevant development agencies) are Adana (Cukurova), Mersin (Cukurova), Gaziantep (Silkroad), Adıyaman (Silkroad), Kilis (Silkroad), Mardin (Tigris), Hatay (East Mediterranean), Osmaniye (East Mediterranean), Kahramanmaraş (East Mediterranean), Diyarbakır (Karacadag) and Şanlıurfa (Karacadag) as depicted below. Figure 1: Proposed Target Provinces and Development Agencies Table 1: Refugees by Province and by Share to total Population Share of Refugees to Number of Syrian Refugees Province Total Population August 2019 (%) Adana 240,870 10.85 Mersin 201,291 11.09 Gaziantep 443,290 21.85 Adıyaman 24,951 4.00 Kilis 116,037 81.41 Mardin 87,217 10,52 Hatay 429,923 26.67 Osmaniye 49,254 9.22 Kahramanmaraş 89,553 7.82 8 STAKEHOLDER ENGAGEMENT PLAN (SEP) Diyarbakır 33,389 1.93 Şanlıurfa 430,537 21.15 Source: Ministry of Interior, Directorate General of Migration Management The project will be implemented through three components, as described in Figure 1. Figure 2. Project Diagram Component 1: Social Entrepreneurship for Women in Refugee and Host Communities Component 1 will finance activities to support social entrepreneurship in refugee and host communities in the selected target provinces abovementioned. This component will directly benefit those receiving start-up support services, subgrants and employment in social enterprises; indirect beneficiaries are the buyers of goods and users of services provided by the social enterprises. Subcomponent 1A will finance support services for social entrepreneurs and subcomponent 1B will fund the subgrants for incubation or acceleration of social enterprises. The elements of this approach aim to maximize the potential for success of the project-supported social enterprises and enables the participation of less privileged women and youth in social entrepreneurship. 9 STAKEHOLDER ENGAGEMENT PLAN (SEP) The program of incubation support services will target approximately 2,200 beneficiaries and accelerator support services 190 ( refugee and host community members in equal numbers), 1,800 new social enterprises will receive subgrants and 180 existing enterprises will receive acceleration sub-grants. At least 70 percent of beneficiaries of social entrepreneurship support services and subgrants will be women, 30 percent will be youth (both women and men, aged 18-29). Component 2: Community livelihoods-related facilities in refugee and host communities To address gaps in facilities, support the efforts of refugee and host community women to earn-income, and promote dialogue and engagement of refugees, host communities and municipal authorities around social enterprises, component 2 will finance: (i) the capacity building and facilitation activities for refugees and host communities to engage in participatory decision-making processes over local needs and priorities for livelihoods-related facilities; and (ii) the cost of establishing/renovating selected livelihoods-related facilities. A minimum allocation for facilities will be US$ 100,000 and the maximum will be set at US$ 300,000. Depending on final subproject selected and costs, a target of approximately 70 facilities has been set benefiting around 7,000 refugees and host community members. Component 3: Institutional Capacity Strengthening and Project Management This component will finance project management, M&E and communications (and visibility) as well as targeted capacity building of national (MoIT, DAs) and local actors (municipalities, local authorities, NGOs, other stakeholders) to strengthen their capabilities to support women’s livelihoods development in this project and in the future. The Ministry of Industry and Technology will be the recipient and implementing agency for the project, delegating responsibilities for the implementation of Components 1 and 2 to five regional Development Agencies (DAs). 1.2 Environmental and Social Risks of the Project The environmental and social risks for this project have been assessed as being Substantial (Risk categories are Low/Moderate/Substantial/High). The World Bank’s environmental and social standards that are relevant for this project include: ESS1 Assessment and Management of Environmental and Social Risks and Impacts; ESS2 Labor and Working Conditions; ESS3 Resource Efficiency and Pollution Prevention and Management; ESS4 Community Health and Safety; and ESS10 Stakeholder Engagement and Information Disclosure. The project will exclude any subgrant that involves land acquisition, has impact on biodiversity and cultural heritage and takes place in any natural and critical habitats. Real estate purchase and major construction works will also be excluded. While intrinsic social risks of the project are moderate, contextual factors contribute to the substantial risk. The project is expected to have positive impacts on vulnerable groups as its main target groups are mainly women and youth from refugee and host communities. It aims to improve livelihood opportunities, inclusion and social cohesion among these groups. The project is not expected to cause direct irreversible or unmanageable impacts, as the project will exclude from sub-grant and livelihood support financing any activities causing land acquisition, involuntary resettlement and impacts on cultural heritage. Impacts on 10 STAKEHOLDER ENGAGEMENT PLAN (SEP) community health and safety are expected to be low to moderate and will be managed by adhering to mitigation measures included in the ESMF, including a Code of Conduct for construction workers; Occupational Health and Safety risks such as injuries and fatalities during small civil works are expected to be minor due to limited scale and short duration of construction works to be financed under the Project. Child and forced labor are reported to be observed among Syrian refugees and in some industries in Turkey. The risk will be mitigated with procedures included in the ESMF, with more details to be provided in the SGM which will explicitly exclude any activities which involve child and forced labor. While grants are used, DAs together with the CIPs will have the supervisory role to ensure that the grant is utilized as per the SGM and employees who are hired by the social enterprises are registered to the national social security system with appropriate work permits. Contextual risks stemming from geopolitical context and existing social tensions between host communities and Syrian refugees are considered substantial which will be mitigated through various measures built in project designs as well as steps included in the ESMF and sub project ESMPs. The development of a project SEP that will be implemented from project start to completion will define various strategies to engage with separate stakeholders in addition to employing communications specialists to prevent any social tension. In addition, participatory assessments will be also utilized in monitoring and evaluation activities to help tailor project support to the needs of potential beneficiaries, helping further avoid disruption in social cohesion. Due to cultural gender norms, women may lack interest and willingness to engage in the project. Risks related to Gender Based Violence directly related to the Project is deemed to be low, although domestic/intimate partner violence is reported among Syrian refugees which may be unintentionally exacerbated as a result of changes in intra-household relationships as a result of the Project. Such risks will be mitigated through monitoring of the Code of Conduct, training sessions on Sexual Exploitation and Abuse/Sexual Harassment (SEA/SH) and SEA/SH sensitive GRM, as provided under the ESMF. MoIT and the DAs are new counterparts for the World Bank and will be working with the World Bank on socio- economic issues impacting refugees and host communities for the first time. MoIT has prepared a draft Environmental and Social Management Framework (ESMF) that describes mitigation measures to manage social and environmental risks. The main environmental risks and impacts are expected to be limited and manageable, including noise, dust and waste management that are confined to small works such as simple construction, refurbishment, and retrofitting. 1.3 SEP Objectives and Scope The objectives of this SEP are to: • Identify stakeholders who are indirectly or directly affected by and/or interested in the project • Outline modalities for information dissemination and stakeholder engagement activities, including their purpose, frequency and location during project preparation and implementation • Promote and provide means for effective and inclusive engagement with project-affected parties throughout the project life on issues that could potentially create an impact • Define the roles and responsibilities of different actors to implement and monitor these activities • Elaborate on the blueprint for a functional grievance redress/beneficiary feedback mechanism • Ensure that technically and culturally appropriate project information on environmental and social risks and impacts is disclosed in a timely, understandable, accessible format. The SEP for SEECO is structured as follows: Section 2 outlines the relevant national regulations and the World Bank’s Environmental and Social Standards. Section 3 summarizes previous stakeholder engagement activities. Section 4 covers the stakeholder mapping, segmentation and analysis, and is followed by section 5 which in turn elaborates on a detailed stakeholder engagement program and key 11 STAKEHOLDER ENGAGEMENT PLAN (SEP) methods of engagement. Section 6 focuses on SEP implementation arrangement and section 7 provides a description of the project’s grievance redress mechanism. 2. NATIONAL REGULATIONS AND INTERNATIONAL STANDARDS 2.1 National Regulations Table 1 summarizes the national legal and regulatory requirements that are relevant for the SEP. Table 1. Relevant National Legal & Regulatory Requirements Right of petition, Right to Information and Appeal to the Ombudsperson (Constitution, Article 74) “Citizens and foreigners resident in Turkey, with the condition of observing the principle of reciprocity, have the right to apply in writing to the competent authorities and to the Grand National Assembly of Turkey with regard to the requests and complaints concerning themselves or the public. The result of the application concerning himself/herself shall be made known to the petitioner in writing without delay. Everyone has the right to obtain information and appeal to the Ombudsperson. The Institution of the Ombudsperson established under the Grand National Assembly of Turkey examines complaints on the functioning of the administration1.� Right to Constitutional Complaint (Constitution, Article 148) The Law on Establishment and Duties of Development Agencies No. 5449 and the Presidency Decree No.4 regulate “Everyone may stakeholders the apply and relations to the Constitutional ofthe Court on Development grounds that oneAgencies within the of the fundamental provinces rights they and freedoms operate. within the Development scope Agencies of the European are unique Convention on Humanin the sense Rights which that they haveby are guaranteed governing boards the Constitution hascomprised been violatedof bymultiple public authorities. stakeholders In order and to make act asan application, separate ordinary legal publiclegal remedies entities. must The be exhausted .�1 Board of the DA is the decision- Administrative making body “Article 24, of the Appeal agency. process In the regions - The applicant composed whose request of one was for information rejectedthe province, mayAdministrative appeal to the BoardBoard withinconsists fifteen of the days governor, starting from theMayor of metropolitan official notification municipality, before appealing Chairman for judicial of the should review. Appeals Provincial Council, be written. Chairman The Board of the shall render a decision within Chamber 30 days.� Chairman of the Chamber of Commerce and three representatives from the private of Industry, Law on the Right to Information (Articles 11 and 24) “Article 11 - The institutions and agencies shall provide the requested information within 15 working days. However, where the requested information or document is to be obtained from another unit within the applied institution and agency or it is necessary to receive the opinion of another institution or if the scope of the application pertains more than one institution; the access shall be provided in 30 working days. In this case, the applicant shall be notified in writing of the extension and its reasons within 15 working days.� The Environmental Impact Assessment Regulation No. 29186 (Article 1) 1) In order to inform the investing public, to get their opinions and suggestions regarding the project; Public Participation Meeting will be accomplished on the date given by Ministry and Ministry qualification given institution / organization and project owners as well as the participants of the project affected community will be expected to attend in a central location determined by the Governor. a) The competency issued institutions / organizations by the Ministry will publish the meeting date, time and place through widely published newspaper at least ten (10) calendar days before the determined date for the PPM. b) Public Participation meeting will be held under the Director of Environment or through Urbanization or authorized chairman. The meeting will inform the public regarding the project, receive views, questions and suggestions. The Director may seek written opinions from the participants. Minutes of meeting will be sent to Ministry, with one copy kept for the Governorship records. 2) Governorship will announce the schedule and contact information regarding for the public opinion and suggestions. Comments received from the public will be submitted to Commission as per the schedule. 3) Members of Commission may review the Project implementation area before the scoping process, also may attend to public participation meeting on the date announced. 4) The competency issued institutions / organizations by the Ministry could provide studies as brochures, surveys and seminars or through internet in order to inform the public before the Public Participation Meeting. 12 STAKEHOLDER ENGAGEMENT PLAN (SEP) sector and/or NGOs. In practice, Development Agencies commonly conduct consultations with different stakeholders, depending on the area in which they launch technical and financial support programs. Before programs are designed and executed, conferences, outreach activities and consultations are conducted by technical staff of the DAs in order to solicit feedback and confirm demand from public for the technical and financial support programs that DAs will initiate. 2.2 World Bank Environmental and Social Standards 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 of ESS10 are: • “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. • 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). This standard requires that the Borrower prepares a Stakeholder Engagement Plan (SEP) that is proportionate to the nature and scale of the project and its potential risks and impacts, disclose it as early as possible before project appraisal, and seeks the views of stakeholders on the SEP, including on the identification of stakeholders and proposals for future engagement. An updated SEP needs to be disclosed by the Borrower subsequent to any significant changes to the original version (World Bank, 2017: 99). In addition, the Borrower should also develop 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)4. 4Details for the WB Environmental and Social Standards are available at: www.worldbank.org/en/projects- operations/environmental-and-social-framework/brief/environmental-and-social-standards and http://projects- beta.vsemirnyjbank.org/ru/projects-operations/environmental-and-social-framework/brief/environmental-and-social-standards 13 STAKEHOLDER ENGAGEMENT PLAN (SEP) 3. BRIEF SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES 3.1 Key Stakeholder Meetings and Consultations To date stakeholder engagement efforts have included meetings with key stakeholders, including government agencies, development agencies, development partners, NGOs, community centers and temporary accommodation centers. Table 2 summarizes key aspects and inputs from these stakeholder engagement efforts. Table 2. Summary of Meetings with Key Stakeholders Location Date Participants Key Points of Discussion Government Agencies Ankara July 3, 2019 Ministry of • Developing the project design, timeline and Industry and critical milestones Technology • Understanding Ministry’s strategies and priorities for the project • Discussing the implementation arrangements of Development Agencies Ankara July 2, 2019 Directorate • Informing on the World Bank’s support in General of technical assistance and projects for refugee Migration and host communities Management • Discussion of social cohesion aspects of the national harmonization strategy Osmaniye July 8, 2019 Osmanyie • Understanding the needs and livelihood Cevdetiye Refugee opportunities of the refugee population who Camp are transitioning out to urban settlements Development Agencies Adana July 8, 2019 Çukurova • Review of DA structure and its support programs, Development including a women’s production cooperative and Agency a school-based community development project which was targeting youth-at-risk groups • Discussion of findings of CDA’s social analyses on migrant issues, agricultural seasonal workers and children’s well-being • Learning lessons from CDA’s support for local institutions with small social infrastructure through its guided support schemes and various entrepreneurship and incubation centers via partnerships with university and chamber of commerce in order to foster business development Gaziantep July 9, 2019 İpekyolu • Discussion of IDA’s experience in implementing Development grant schemes for women and other vulnerable Agency groups of the community, including support for a Women Entrepreneurship Support Center with 14 STAKEHOLDER ENGAGEMENT PLAN (SEP) the Gaziantep Chambers of Commerce of Gaziantep Ankara September 10, Cukurova, • Introducing project design details and 2019 Ipekyolu, Eastern implementation arrangements Mediterreanean, • Collecting feedback from Development Agencies Karacadag, Dicle • Understanding current support schemes of Development Development Agencies Agencies and DG of Development Agencies, MoIT Hatay, Diyarbakir, September 26, Eastern • Discussion on Project implementation Mardin, Sanliurfa 30, October 1, Mediterreanean arrangements 3 DA, Diyarbakir- • Exploring possible roles and responsibilities of Karacadag DA, DAs and potential Community Implementing Mardin- Dicle DA Partners and Sanliurfa- • Collecting feedback on capacity building support Karacadag DA needs of DAs • Knowledge and experience sharing with local NGOs Development Partners Ankara July 10, 2019 FRIT Coordination • Key steps and requirements of the new projects Office, Delegation funded under the Facility for Refugees in Turkey of the European Union to Turkey Ankara July 5, 2019 UNHCR • Learning experiences and knowledge sharing on entrepreneurship projects of UNHCR on the ground Ankara July 4, 2019 UNDP • Learning experiences and knowledge sharing on projects of UNDP on the ground Ankara July 4, 2019 ILO • Learning experiences and knowledge sharing on employment and labor market demand of refugee and host communities Community Centers/NGOs Gaziantep July 9, 2019 GAP CATOM • Exploring lessons from the Center’s efforts to community center provide multipurpose services to women with different needs, including Turkish literacy classes, basic sewing classes, maternity tracking and women’s hygiene, child-friendly spaces with kindergarten facilities Gaziantep July 9, 2019 Gaziantep • Discussing lessons from the Center’s bottom-up Metropolitan approach to the design of its services with Municipality- participation of beneficiaries. ENSAR community • Discussing challenges around the lack of center transportation services for women to attend to the trainings provided by the center, and for children to attend schools • Discussion of the possibility of middle-class Syrians who are educated and are able to speak the Turkish language to act as change agents and be role models for the Syrian community members 15 STAKEHOLDER ENGAGEMENT PLAN (SEP) Gaziantep July 9, 2019 SADA Women • Exploring lessons from cooperatives targeting Center Syrian, Afghan and Turkish women • Discussing experience from developing cooperative production lines include shoe- leather-making, food production and textile • Exchange on factors that have facilitated women’s participation and motivation in setting up cooperatives including the importance of husbands and family members being consulted from the very beginning for their consent and their continuous support Ankara July 4, 2019 Civil Society • Exchange regarding key activities of the Civil Development Society Development Center Center, Ankara • Discussing lessons from the Center’s response to the refugee influx in Turkey Ankara July 2, 2019 Red • Learning on Turkish Red Crescent’s socio- Crescent Ankara economic and community development Community Center programs for refugee and host communities • Observing the Community Center’s services to local communities in Ankara In addition to the stakeholder engagement activities described above, the World Bank, in partnership with MoIT and DAs, has conducted beneficiary dialogues with youth and women groups in October 2019 ahead of Project approval. The methodology included focus group discussions to capture a broad range of experiences and situations for refugee and host community women/youth in project areas in Turkey. The sessions took place both separately and jointly (refugee and host communities), in Turkish and Arabic. The findings of the beneficiary dialogues include recommendations for the SEECO guidelines will be included in the Project Operations Manual. Public consultations for the ESMF drafted by MoIT will take place before project effectiveness and key points of discussions will be updated in this SEP, together with the outcomes of beneficiary dialogues. 3.2 Lessons Learned in Engaging Communities/Stakeholders from Previous Projects The project incorporates global lessons on forced displacement solutions, in parallel with implementation experience from World Bank-financed and other development partner projects in Turkey. The key lessons are as follows: In projects that focus on addressing forced displacement, it is important to engage both refugees/IDPs and host communities. A 2018 ICRC Report shows that in various urban settings, host communities often perceive IDPs as a burden when displacement becomes protracted;5 displacement is shown to exacerbate pre-existing problems of employment and markets, land and housing, infrastructure, waste management and other public services.6 Literature also shows societies where relationships and social identities are rigid have more difficulties maintaining social cohesion in situations where there is rapid social change, 5 ICRC (2018). Displaced in Cities: Experiencing and Responding to Urban Internal Displacement Outside of Camps. https://www.icrc.org/en/publication/4344-displaced-cities-experiencing-and-responding-urban-internal-displacement-outside 6 Ibid. 16 STAKEHOLDER ENGAGEMENT PLAN (SEP) such as when there is forced displacement.7 Project evaluations,8 show that having separate activities for IDPs and host communities can aggravate problems and tension by creating competition for resources.9 The project adopts this learning by applying a single set of activities that supports socio-economic benefits for both refugees and host communities. One of the most important potential development impacts of a project aiming to support refugees is increased social cohesion. A recent review of the thirty World Bank projects that directly or indirectly aimed at promoting social cohesion in settings where there is forced displacement recommends a number of steps that will be taken up by the project and associated analytical work, i.e. (i) a simple definition of social cohesion be applied,10 (ii) a nuanced political economy study and historical analysis, (iii) take a longer-term strategic approach to supporting social cohesion, (iv) incorporating measures and assessment of social cohesion via social cohesion indices, and (v) incorporate indicators to measure social cohesion. This project understands social cohesion as having the intra-community, inter-community and community-institutional dimensions, will have completed a field study in a sample set of communities, will adopt a first-do-no-harm approach and includes a social cohesion indicator.11 Addressing the needs of refugee women requires addressing root causes of gender inequality and gender-based violence. Evidence points to the fact that women and girls from displaced households are more vulnerable than others to gender-based violence (GBV)12, including rape and forced/child marriages.13 Violence against women, in turn, limits women’s earning capabilities.14 In a 2015 survey, 94% of respondents, including practitioners, policy-makers, researchers and activists working on GBV identified women’s economic dependency on men as the single most important factor or cause of violence against women.15 At the same time, working women can face violence on their way to work, especially when they use public transport or live in informal settlements or camps.16 A 2018 assessment of Syrian women and girls in Turkey noted that GBV is prevalent amongst the Syrian population and is closely linked with socio-economic challenges that Syrian women and girls face daily. The project will complement gender-related efforts by focusing on awareness-raising and education campaigns. Addressing the root causes of gender inequality is therefore essential when aiming to reduce violence against women. There is also evidence that if the gender inequalities that drive violence against women are not addressed, 7 De Berry and Roberts (2018). Social Cohesion and Forced Displacement: A Desk Review to Inform Programming and Project Design. World Bank, Washington, DC. Available at: http://documents.worldbank.org/curated/en/125521531981681035/Social- cohesion-and-forced-displacement-a-desk-review-to-inform-programming-and-project-design 8 For instance [add] and World Bank IEG Project Performance Assessment Report (2018) of the Colombia Peace and Development Project. 9 IEG Op cit. 10 The set of relationships between individuals and groups in a particular environment and between those individuals and groups and the institutions that govern them in a particular environment 11 De Berry, Op cit. 12 World Bank (2018). Gender Based Violence in Fragile, Conflict, and Violence (FCV) Situations: Five Key Questions to be Answered. World Bank, Washington, DC. Available at: http://documents.worldbank.org/curated/en/500211539840991140/Gender-Based-Violence-in-Fragile-Conflict-and-Violence- FCV-Situations-Five-Key-Questions-to-be-Answered 13 Ibid. 14 Georgia, T. (2015) DFID Guidance Note on Addressing Violence Against Women and Girls (VAWG) Through DFID’s Economic Development and Women’s Economic Empowerment Programmes: Part B, London: VAWG Helpdesk. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/444145/Health-guidance- note-partB_2_.pdf 15 Ibid. 16 Haspels et al., 2001 in Georgia, T. ibid. 17 STAKEHOLDER ENGAGEMENT PLAN (SEP) economic empowerment initiatives can make the lives of women worse. DFID’s women’s economic empowerment program highlights the need for: improving women’s knowledge and communication capabilities in work and in the home; promoting formal employment away from the home; promoting women’s organizations and networking; and increasing women’s access to business development services and financial services are some of the key enabling or facilitating factors for promoting women’s empowerment.17 A holistic approach to address gender issues for Syrian refugees and Turkish women from host communities has been considered in the design of the project. Investments to promote socio-economic inclusion of refugees and host communities is sustainable when activities are designed and implemented in partnership with local stakeholders. A World Bank review of social cohesion approaches globally highlights the importance of history, and organizations embedded in communities are most likely to understand the socio-political economy issues, and understand that social cohesion is greater than refugee-host community dynamics.18 The project will adopt an implementation approach whereby Development Agencies appoint Community Implementing Partners (NGOs, foundations, or a consortium of such entities) that have sound knowledge of and access into communities through trusting relationships and will deliver a holistic set of services. A non-state— state approach which also champions local women leadership and develops platforms for engagement with local authorities is proposed. Facilitating refugees and host communities to identify their own priorities and mechanisms for socio- economic inclusion will create more sustainable and relevant action – platforms for engagement and feedback from beneficiaries is key to targeting and locally relevant solutions. The project seeks to build on existing development planning processes while enhancing the participation of refugees and host communities. Beneficiary engagement has dual benefits. First, it leads to better understanding of needs, improved efficiency of activities, and sustainability of investments; and second, engaging refugee and host community groups (and targeted engagement with women, youth, and people with disabilities) fosters harmonization and cohesion. This approach will be supported by skilled facilitation of local actors, capacity building of women leaders, transparency and access to user-friendly information, and mutually-beneficial processes and outcomes. The project will mobilize refugee and host community beneficiaries (both women and men) and provide capacity-building support to enhance their participation in local socio- economic development processes. Key development partners working with the Turkish authorities in refugee response programs, like UNHCR19, have built their communication with communities strategy for refugees and host communities on three pillars: (1) Effective two way communication and information disclosure channels (2) inter-agency coordination with other development partners (3) Cooperation with Turkish authorities (DGMM and Ministry of Labor, Family and Social Services). UNHCR’s survey findings on the communication sources, tools and needs of refugee communities indicate that: • The principal sources of information are usually unofficial and informal, both offline (through informal networks) and online (through group platforms on social media such as Facebook). Given the informal nature of the channels, refugees feel uncertain about the authenticity of the information they have. Moreover, these channels pose the risk of being prone to inadvertent or deliberate 17 Kabeer, 2011 in Georgia, T, ibid. 18 De Berry, Op Cit. 19 UNHCR, July 2019, Factsheet, Communication with Communities: https://reliefweb.int/sites/reliefweb.int/files/resources/71060.pdf 18 STAKEHOLDER ENGAGEMENT PLAN (SEP) misinformation and misunderstandings, which can spread quickly to a wider population within a short period of time. • Official sources, such as national authorities-DGMM, United Nations agencies, and partners, are the most trusted sources to provide accurate information. • Key information gaps that remain among the refugee population are on their rights, obligations and the services available to them in Turkey. A majority of respondents have indicated that they are not sufficiently informed of their rights and obligations. Follow-up focus group discussions by UNHCR, however, suggest that refugees tend to have the necessary information, while considering themselves insufficiently informed. Similarly, the Turkish Red Crescent (TRC), working both on the humanitarian protection and livelihood dimensions of the refugee response agenda has been implementing a thorough stakeholder engagement and communication strategy. Mainly the strategy consists of consultation meetings with refugee and host community members, provincial directorate of migration and other local government authorities, conducting beneficiary satisfaction surveys, information desks at the TRC Community Centers, Communication Materials, Complaints and Response Mechanism, and including an advisory committee consisting of both refugee and host community members. 4. STAKEHOLDER MAPPING AND ANALYSIS A key element of any SEP is effective identification of key stakeholders. Stakeholders are defined as individuals or groups who can affect, are affected by, or have a legitimate interest in the Project. For the purpose of the SEP, the term “Project-affected parties� (PAPs) includes “those likely to be affected by the project because of actual impacts or potential risks to their physical environment, health, security, cultural practices, well-being, or livelihoods. These stakeholders may include individuals or groups, including local communities� (World Bank, 2018b). They are the individuals or households most likely to observe changes from environmental and social impacts of the project. The term “Other interested parties� (OIPs) refers to “individuals, groups, or organizations with an interest in the project, which may be because of the project location, its characteristics, its impacts, or matters related to public interest. For example, these parties may include regulators, government officials, the private sector, the scientific community, academics, unions, women’s organizations, other civil society organizations, and cultural groups� (World Bank, 2018b). 4.1 Stakeholder Mapping and Analysis This section identifies the comprehensive list of stakeholders that are relevant for the project. Stakeholders are divided into PAPs and OIPs in the following tables. Table. 3 Stakeholder Mapping Stakeholder Groups Details PAPs Women and youth from host and refugee communities, male Project affected household members, community members, community leaders, parties (PAP) children of refugee and host community families, social enterprises, people employed by social enterprises, existing 19 STAKEHOLDER ENGAGEMENT PLAN (SEP) community businesses, buyers of goods and users of services provided by the social enterprises Government MoIT, Ministry of Trade, Ministry of Family, Labor and Social Authorities Services, Ministry of Education, DGMM, DAs, municipal authorities, Small and Medium Enterprise Development Agency (KOSGEB), FRIT Coordination office at Presidency of the Republic of Turkey, Strategy and Budget Office of Presidency, Other Interested Private Sector Private sector-existing social enterprises, other enterprises, Parties (OIP) contractors, chambers of commerce and industry Project Implementing FRIT Project Steering Committee, Regional level multi- Partners stakeholder advisory platforms, CIPs, local NGOs International EU Delegation to Turkey, WB, UNHCR, UNDP, ILO, IOM, Turkish Development Partners Red Crescent NGOs International, national & provincial level NGOs working on women livelihoods, refugee and host community support Media International, national and local media General Public Perception of general public influences host community perception in general Stakeholders Relevance/Area of Influence Significance PROJECT AFFECTED PARTIES Women and Women and youth from refugee communities are disadvantaged with High youth from regard to access to livelihood and job opportunities. Their forced- refugee displacement history and also language barriers may add another layer of communities vulnerability. They are the main project beneficiaries. Services to help women and youth set up social enterprises will be defined separately according to their needs. Women and Women and youth from host communities are disadvantaged with regard High youth from host to access to livelihood and job opportunities in the Turkish labor market. communities Women have low participation rates and youth have higher unemployment incidence compared to national average. They are also the main project beneficiaries. Services to help women and youth set up social enterprises will be defined separately according to their needs. Vulnerable groups Vulnerable groups may be from both the refugee and host communities High who will be among the project beneficiaries. They maybe illiterate or have different vulnerabilities (such as disabilities) which would require differentiated measures for meaningful engagement to project activities and information disclosure. Male household Male household/community support is important for women to take part in Medium members and project activities and work outside the home in social enterprises community elders Host community The host community will have a stake in the identification and members implementation of local needs and priorities for livelihoods-related facilities Medium that will support social enterprise development Mukhtars Mukhtars have a stake in the identification and implementation of local Medium needs and priorities for livelihoods-related facilities Existing social Existing social enterprises will be able to apply for support under the enterprises project, and those selected will benefit from grants and capacity-building High (cooperatives, limited liability companies, sole 20 STAKEHOLDER ENGAGEMENT PLAN (SEP) traders, associations, corporations and foundations) Children of Children will benefit from livelihood facilities projects under Component 2 Medium refugee and host that support childcare facilities and are also expected to benefit from some community of the activities of social enterprises families Employees of Employees under social enterprises will benefit from Medium social enterprises employment/livelihoods due to project support Buyers of goods Depending on the goods and services provided by the social enterprises, and users of they will have an impact on their success Medium services provided by the social enterprises. OTHER INTERESTED PARTIES Government Authorities Presidency of Presidency has the role in approving and supervising the effectiveness of all High Republic of FRIT recipient operations on behalf of the Government of Turkey. The FRIT Turkey, FRIT office has the coordination role among recipient government agencies and Coordination will exercise this oversight over the SEECO project. Office Ministry of Recipient and implementing agency of the project High Industry and Technology Ministry of Trade The Ministry would collaborate on the preparation of legislation on social Medium enterprises with MoIT, and is looking for successful examples in the social business sector to inform policy and legal framework changes Directorate DGMM provides overall oversight and coordination of policies and Medium General of strategies relating to the area of migration and coordinates institutions and Migration organizations working on refugee response efforts such as the SEECO Management project Ministry of The Ministry can influence the policies and legislative framework which High Family, Labor and regulates work permits, work and employment conditions of Syrians under Social Services Temporary Protection, Turkish citizens, foreign residents and temporary workers, which impacts social enterprise development. MoLSS is also responsible agency for coordinating the ESSN Exit Strategy. Government Authorities (Provincial Level) Development DAs will be responsible for the implementation of all aspects of the project High Agencies for at local level (including through CIPs); provide technical and financial Adana, Mersin, resources for enterprise development and the overall development of the Gaziantep, entrepreneurship ecosystem in their regions Adıyaman, Kilis, Mardin, Hatay, Osmaniye, Kahramanmaraş, Diyarbakır and Şanlıurfa. Government Authorities (Local Level) Municipal and Local authorities will be support the engagement of refugees and host High other local communities in participatory decision-making processes over local needs Authorities and priorities for livelihoods-related facilities and have responsibility for 21 STAKEHOLDER ENGAGEMENT PLAN (SEP) (Councilors and sustaining livelihoods investments over time administrators) International Development Partners The EU Facility for Refugees in Turkey is financing the project. FRIT Delegation of the manages a total of €6 billion, is designed to ensure that the needs of European Union refugees and host communities in Turkey are addressed in a High to Turkey comprehensive and coordinated manner. The Facility focuses on humanitarian assistance, education, migration management, health, municipal infrastructure, and socio-economic support. UNHCR In Turkey, the main areas of UNHCR’s work are leading and coordinating Low the efforts of the United Nations agencies in support of Turkey’s response to the Syria refugee crisis. UNHCR will be a key partner in project implementation. UNDP UNDP manages the Syria Crisis Response and Resilience Programme with Low related programming in Turkey. The project will seek to coordinate efforts with UNDP, where relevant, in SEECO project areas. The ILO office in Turkey strives to guarantee the core elements of social Low justice, which are respect for human rights, decent living standards, human working conditions, employment opportunity and economic security for ILO working people everywhere. In line with this objective, the ILO aims to combat child labour, to increase women and youth employment, to strengthen social dialogue and eliminate informal economy. The SEECO project will coordinate with ILO, where relevant, on social enterprises and refugee/host community employment activities. World Bank EU FRIT has an administrative agreement with the World Bank, through High which it will provide funding for the Social Entrepreneurship, Empowerment and Cohesion in Refugee and Host Communities in Turkey Project. The WB’s role is that, as “administrator of funds�, it has the role of supervision and implementation support to the recipient agencies Project Implementing Partners FRIT Project The SC is comprised of representatives from MoIT, other government Steering agencies and other relevant stakeholders, including the EC and the World Medium Committee Bank. As requested by MoIT, the committee can act as an advisory body (national level) and take decisions, if requested. Community CIPs will be appointed by DAs to carry out project activities directly with the High Implementing refugee and host community beneficiaries in selected project locations. Partners Community-Based WLCs will be responsible for leading the communities’ engagement and Organizations/ social cohesion activities under the project. High Women’s Livelihoods Committees (WLCs) Private Sector Private sector Private sector actors will have an overall interest to integrate social Medium (private sector businesses into their supply chain; will need to be engaged in considering organizations, the sustainability of the project and social enterprise investments. chambers of commerce, multinational companies) Existing Depending on which part of the market value chain to which they provide Low 22 STAKEHOLDER ENGAGEMENT PLAN (SEP) community goods/services, existing community businesses may benefit from, or businesses provide support or investment in, social enterprises under the project. Contractors Contractors will be required to implement civil works in compliance with Medium ESSs. Small and SMEs Development Organization will have an interest in the success of Low Medium project-supported social enterprises as part of Turkey’s broader Enterprises Entrepreneurship Strategy developed by KOSGEB. Development Organization of Turkey NGOs, Media and Public CSOs (national CSOs may have an interest in sharing their experiences and lessons learned Low and provincial in related activities to support refugees/host level) communities/entrepreneurship and exploring potential areas for collaboration; some CSOs may serve as CIPs for the project. Media (local, The media will have a key role in disseminating information on the efforts Medium national & and results of the project international) General Public The public will have a broad interest in the project’s results and Medium beneficiaries. Public perception is also important in influencing host community perception and hence social cohesion outcomes of the project. 23 STAKEHOLDER ENGAGEMENT PLAN (SEP) 4.2 Stakeholder Analysis This section provides an analysis of stakeholders that have medium or high significance. However, those with low significance stated in the above table will be also included in the stakeholder activities, as required. Table 4. Stakeholder Analysis Stakeholder Concerns & Issues Expectations from Project Risks Mitigating Measures PROJECT-AFFECTED PARTIES Women and youth They do not have sufficient • The project will provide • Women may face challenges • The project will carry out from refugee opportunities for livelihood them with funding for that might hinder the participatory assessments to communities generation and social livelihood generation sustainability of the identify, and find solutions to, entrepreneurship and social enterprises, such as child care, locally-relevant constraints of entrepreneurship safe transportation, working Turkish women and refugees Language barriers of refugee • The selection of outside their neighborhoods, • The project will include market communities beneficiaries will be cultural norms and male analysis to identify the skills and based on transparent resistance talents of target beneficiaries to Eagerness to engage and integrate criteria and will be • Beneficiaries may not have the ensure relevance to the incubation to Turkish society unbiased required skills and talents that and acceleration support services. • They will be provided are relevant to ensure • It will also enhance the support with technical assistance relevance to the incubation and system for social enterprises by and capacity building for acceleration support services establishing a business alliance on incubating/accelerating • Exogenous variables such as a responsible sourcing which their social enterprises limited business environment reinforces and creates a mutually may be a challenge for the dependent system sustainability of the enterprises • Language training and to improve • Social tensions may exist social cohesion between refugees between refugee and host and host communities through community women social enterprise development and participatory engagement in livelihoods facilities Women and youth They do not have sufficient • The project will provide • Women may face challenges • The project will carry out from host opportunities for livelihood them with funding for that might hinder the participatory assessments to communities generation and social livelihood generation sustainability of the identify, and find solutions to, entrepreneurship and social enterprises, such as child care, locally-relevant constraints of entrepreneurship safe transportation, working Turkish women and refugees • The selection of outside their neighborhoods, • The project will include market 24 STAKEHOLDER ENGAGEMENT PLAN (SEP) Women and youth have lower rates beneficiaries will be cultural norms and male analysis to identify the skills and of employment based on transparent resistance talents of target beneficiaries to criteria and will be • Beneficiaries may not have the ensure relevance to the incubation Openness to engage with women unbiased required skills and talents that and acceleration support services. and youth groups from refugee • They will be provided are relevant to ensure • It will also enhance the support communities, however less interest with technical assistance relevance to the incubation and system for social enterprises by to integrate/harmonize and capacity building for acceleration support services establishing a business alliance on incubating/accelerating • Exogenous variables such as a responsible sourcing which their social enterprises limited business environment reinforces and creates a mutually may be a challenge for the dependent system sustainability of the enterprises • To improve social cohesion • Social tensions may exist between refugees and host between refugee and host communities through social community women enterprise development and participatory engagement in livelihoods facilities Vulnerable groups Vulnerable groups may be from • The project will provide • Vulnerable people among both • During outreach activities of CIPs both the refugee and host them with funding for host and refugee communities and project information disclosure communities who will be among livelihood generation may face challenges to activities, certain measures will be the project beneficiaries. They and social affectively attend the project undertaken to include vulnerable maybe illiterate or have different entrepreneurship activities. This could be due to groups in the project. vulnerabilities (such as disabilities) • The selection of language barriers, illiteracy or • For those disabled persons who which would require differentiated beneficiaries will be other challenges such as want to engage in the project, the measures for meaningful based on transparent different disabilities project will include measures for engagement to project activities criteria and will be • They may have certain their accessibility. and information disclosure. unbiased disabilities which may limit • For illiterate, verbal and non- • They will be provided them to benefit from the technical communication will be with technical assistance project equally as other utilized. and capacity building for beneficiaries. incubating/accelerating their social enterprises Male household They may create barrier for women The project will provide They may challenge or create Outreach and training will also be members and to be engaged in employment and benefits not only for hindrances for women to targeted to male household members community elders livelihood generation activities, or women but also for the participate in the project and community elders, including be unwilling to take on household community at large discussion of topics such as the responsibilities in the absence of benefits of social enterprises for women households and gender roles, managing finances and access to services 25 STAKEHOLDER ENGAGEMENT PLAN (SEP) Community The community may perceive that • They will have • Limited buy-in/willingness • Capacity building and facilitation members/leaders/ social enterprises and investments opportunities to express from the community activities for refugees and host Mukhtars in livelihoods facilities only benefit their • Tensions/community concerns communities to engage in a small number of target priorities/preferences to over funding being spent on participatory decision-making beneficiaries, and that project determine which refugees rather than host processes over local needs and support is directed primarily to municipal livelihood communities priorities for livelihoods-related Syrian refugees at the expense of generation facilities Turkish hosting communities assets/facilities should • Proactive efforts to disseminate be information regarding the project established/renovated • Social cohesion baseline • The project’s activities survey/monitoring will not exacerbate social • Project feedback/grievance redress tensions among refugees mechanism and hosts, and other members of the community Owners/leaders of • Perception that support for • The project’s activities Limited or no buy-in from owners • Proactive efforts to disseminate existing social new/growing social enterprises will lead to a better of existing social enterprises information regarding the project enterprises led by women and youth is at the business climate and • Outreach to existing social expense of their enterprises opportunities for social enterprises regarding the possibility • Concerns that new/burgeoning enterprises overall of training/coaching and enterprises will be a source of • Existing social enterprises accelerator grants under the project competition for them in an can access accelerator already limited market grants under the project Children of refugee • Need for child care for the It will not utilize child labor, • Child neglect if there is no • The project will provide subgrants families primary women participants of and will provide options for childcare support or for community livelihoods-related project activities child care as part of alternatives facilities, including kindergartens • Potential for child labor in social livelihoods facilities under • Child labor in project- and childcare facilities, child- enterprises supported under the Component 2 supported social enterprises friendly spaces project • The project will ensure strong safeguards against child labor in project-support SEs Contracted workers/ Risks related to adherence to code Opportunities to provide There may be occupational Labor Management Procedures have local providers of of conduct, labor standards, and support for civil works and health and safety concerns during been prepared by MoIT and the Labor goods and services environmental and social provision of goods and civil works Management Plan that will apply to all safeguards services required for social project workers will include the Code enterprise and livelihoods of Conduct for project workers as well facilities development as principles and procedures for workers’ grivance mechanism 26 STAKEHOLDER ENGAGEMENT PLAN (SEP) Contractors Risks related to adherence to code Potential to engage workers There may be occupational MoIT and DAs will ensure that small of conduct, labor standards and to carry out small scale civil health and safety concerns during scale civil works contractors comply environmental and social works civil works as well as issue around with OHS policies and procedures safeguards in carrying out small adherence to environmental and included in the LMP and ESMF scale civil works social standards Buyers of goods and Potential to purchase a variety of Potential to purchase a There may be • The project will enhance the support users of services goods and services from social variety of goods and dissatisfaction/mistrust on their system for social enterprises by provided by the social enterprises services from social part if the social enterprises are establishing a business alliance on enterprises. enterprises unsustainable responsible sourcing which reinforces and creates a mutually dependent system • The project will provide support for assets/facilities that will be owned and operated by municipalities and thus be available when project funding stops as municipalities have the incentive to enhance economic development 27 STAKEHOLDER ENGAGEMENT PLAN (SEP) Stakeholder Concerns & Issues Expectations from Project Risks Mitigating Measures OTHER INTERESTED PARTIES Government Authorities Presidency of Republic • Presidency has the role in That the project achieves its FRIT coordination office gaining • MoIT sharing six monthly project of Turkey, FRIT approving and issuing the results, disburses smoothly limited information on project progress reports with FRIT Coordination Office effectiveness of all FRIT recipient and contributes progress and disbursement coordination office in the Presidency operations on behalf of the Government of Turkey’s figures • World Bank taking part in regular Government of Turkey. The FRIT refugee response agenda meetings and briefings with the office has the coordination role including ESSN exist Presidency and FRIT coordination among recipient government strategy office agencies. • Presidency in close relation with EU to continue to support the Government of Turkey’s efforts in refugee response Ministry of Trade • Ministry has a DG on The Ministry would Priorities of Ministry may change, • Ministry membership on FRIT Cooperatives and has recently collaborate on the new regulations on cooperative Steering committee launched `social cooperatives` as preparation of legislation on structure may impact outcomes • Member of working committee on a new model to reach out social enterprises with in both ways legal and policy framework to disadvantaged populations MoIT, and is looking for improve the social enterprise sector, successful examples in the including social cooperatives social business sector to inform policy and legal framework changes Directorate General of Alignment of policies and strategies That the project’s objectives Facing limited coordination with • DGMM membership on FRIT Steering Migration relating to the area of migration and implementation is MoIT; unable to obtain committee Management and to coordinate institutions and aligned with Turkey’s information regarding project • Regular reporting to DGMM on organizations related to these harmonization and activities and outcomes project activities and regular briefing issues migration management by WB and MoIT teams strategy Ministry of Family, Ministry is coordinating the Project outcomes support • Insufficient knowledge of social • Membership of Ministry on FRIT Labor and Social Government’s ESSN Exit Strategy. ESSN Exit strategy of the enterprise development as part Steering Committee in order to Services MoLSS can establishes the policies Government. Project of ESSN exit strategy understand the implementation of and legislative framework which objectives improve the • DG of Women Status priorities FRIT projects in socio-economic regulates work permits, work and employability of vulnerable and strategy on fostering support, whether projects contribute employment conditions of Syrians groups in both refugee and women livelihoods through to any employability improvement in under Temporary Protection, host communities, support cooperatives will be critical ESSN beneficiaries Turkish citizens, refugees under the Government’s policies • Regular reporting and outreach from international protection, foreign and programs on WB and MoIT teams to raise 28 STAKEHOLDER ENGAGEMENT PLAN (SEP) Stakeholder Concerns & Issues Expectations from Project Risks Mitigating Measures residents and temporary workers employment growth to awareness regarding the role of that impact project success. incentivize women’s self- social enterprise development In addition, the DG of Women employment and Status is in charge of fostering entrepreneurship women cooperatives opportunities for both women and youth International Development Partners EU FRIT The project addresses the needs of The project addresses the The project’s results are not Project M&E and semi-annual review refugees and host communities in needs of refugees and host achieved and the project does of implementation progress; ongoing Turkey in a comprehensive and communities in Turkey in a not contribute to the overarching dialogue with EU FRIT counterparts on coordinated manner. In addition comprehensive and goals around ESSN exist strategy project progress the project is in line with ESSN Exit coordinated manner Strategy. World Bank The project addresses the needs of The project achieves the The project’s results are not Capacity building support for MoIT, refugees and host communities in PDO and that it is achieved, there are DAs and municipalities; engagement of Turkey in a comprehensive and implemented per WB implementation difficulties or local CSOs, adoption of participatory coordinated manner safeguards, procurement lack of project impact based on and gender sensitive approaches, M&E and FM requirements target outcomes and reporting system to ensure compliance with safeguards, procurement and FM requirements Project Implementing Partners FRIT Project Steering The importance of regular updates Regular updates on • Lack of national-level dialogue MoIT will assume the lead on Committee (national and action on issues that create an implementation progress and understanding of project coordination of the committee and will level) enabling policy environment for goals and results help to set the agendas and ensure key project implementation • Lack of enabling policy issues are raised and addressed by environment for project Committee Members. activities to be successfully implemented Ministry of Industry & • Adequate allocation of budgets & That the project achieves its • New to World Bank operations WB capacity building support for MoIT Technology, GD of delegation of responsibilities for results, and that it is • Need for coordination and to design, implement and monitor Development Agencies Components 1 and 2 in the implemented effectively by oversight of DAs on project social enterprise incubation and selected provinces to regional the selected Development activities acceleration activities, including hiring Development Agencies (DAs) Agencies per WB additional staff (consultants) on • Capacity building of key safeguards, FM and project’s financial management, stakeholders, including procurement standards procurement, environmental and Development Agencies, social, communications and M&E municipalities, local authorities 29 STAKEHOLDER ENGAGEMENT PLAN (SEP) Stakeholder Concerns & Issues Expectations from Project Risks Mitigating Measures and other national and local state and non-state stakeholders • Adequate visibility regarding the EU’s financial contribution to support the humanitarian and development needs of refugees and host communities in Turkey Development Agencies Adequate implementation of Achieve project targets DA • Limited experience with social • Capacity building of DAs under (provincial level) Component 1 and 2 activities in project area enterprises Component 3 and collaboration collaboration with MoIT and • No prior experience working with CIPs municipal authorities with the World Bank • World Bank engagement and • Very different operating capacity building environments across DAs • Flexibility to adapt project activities to needs of communities in DAs and based on market assessment/initial analyses Local Public Creation of sustainable solutions Establishing assets/facilities • Municipalities that are unable A precondition for funding will be Authorities for social enterprises by creating that are in line with to commit budgets for O&M that the municipality or relevant assets/facilities that will be owned municipal plans/priorities • Insufficient capacity of department commits budget for and operated by municipalities and municipal authorities to O&M, and each subproject financed thus be available when project Having successful social implement the project under Component 2 requires an funding stops as municipalities have enterprises for host and • Insufficient experience with O&M plan the incentive to enhance economic refugee communities participatory decision making • Where possible, agreements will development. and engaging refugee be made with municipalities to communities enable the beneficiaries • Potential political sensitivities themselves to participate in their /host community concerns with operation (reducing municipal involving refugees in decision costs and increasing community making process ownership) • Detailed procedures in Project Operations and SubGrant Manuals Community They will implement training and To deliver outputs on The pool of CIPs in selected • Market analysis and identification implementing partners mentoring activities for time based on CIP terms locations may have limited of possible well qualified CIPs (local level) incubation and acceleration, of reference experience with incubation and • Exchange of knowledge/experience disbursing grants to new and • To have well defined acceleration support services, across CIPs existing social entrepreneurs and written instructions and grant-making, community • Beneficiary feedback/grievance post-creation supporting services, program reporting development and institutional redress mechanisms 30 STAKEHOLDER ENGAGEMENT PLAN (SEP) Stakeholder Concerns & Issues Expectations from Project Risks Mitigating Measures and the community templates to comply with capacity building • Project M&E and CIP reporting to mobilization/decision-making and DA, MoIT and WB • The CIPs may have difficulty in DAs social cohesion activities requirements managing funding and • They will provide outreach to resources and effective members of the refugee and host implementation communities at the grassroots level to ensure that the project reaches its targets for female beneficiaries Community-Based They will develop social cohesion They are compensated for • There is lack of willingness to Engagement of CIPs to recruit Organizations/ focused activities with local their time/efforts to engage by CBOs/WLCs members to Committees – outreach Women’s Livelihoods communities to ensure local undertake social cohesion and information sharing campaign Committees relevance and address local activities • They may have expectations of challenges compensation (in cash or in kind) Private sector Integration of successful and • Inform policy and There may be limited awareness The project will provide support for a sustainable social enterprises into regulatory changes for of successful or promising social business alliance on responsible supply-value chains social enterprises enterprises and their sourcing. This will promote the services • Social enterprises services/products and/or products by these social supported by this project enterprises. The alliance will be will be successful and facilitated through private sector sustainable, thereby organizations, chambers of commerce reducing the risk of that are vocal on these issues including them in market supply chains • Document and disseminate The project will have • Any challenges related to the Preparation and implementation of successes (and challenges) with positive outcomes with project’s implementation and Communications and Visibility Plan in regard to the ESSN exit strategy regard to social enterprises results would be disseminated line with EU visibility guidelines, that • Highlight social tensions and social cohesion by the media as well emphasizes project goals and activities Media (Printed) between host and refugee • Media messaging could be and mutual benefit to refugees and communities politically charged around host communities • Highlight successes of social support provided to refugees enterprises led by vulnerable and/or aggravate social women and youth tensions and risks • Highlight instances of social cohesion 31 STAKEHOLDER ENGAGEMENT PLAN (SEP) 32 STAKEHOLDER ENGAGEMENT PLAN (SEP) 5. STAKEHOLDER ENGAGEMENT PROGRAM 5.1 Overview of Stakeholder Engagement Program The table below presents roles and responsibilities of key actors in stakeholder engagement to be conducted under the project. Detailed methods of consultations to be conducted are provided in Section V below. Table 5. Roles and Responsibilities for the Stakeholder Engagement Program Communication Engagement Responsible Subgroup Project Phase Channels/Materials Purpose Venue Frequency Party Mechanism(s) Women and youth from refugee Non-technical communities summary of project Women and youth and its Beneficiary Dialogues Localities in from host environmental and Participatory needs To apprise target beneficiaries and target Once prior to communities Preparation and social impacts assessment/ communities of project activities, municipalities ESMF Implementation planning/Participatory potential environmental and social that are Owners of existing finalization monitoring risks accessible to social entrprises subgroups Mukhtars Quarterly MoIT PIU E-mails; media reports Official meetings, site reports, Share information regarding (press releases, audio- visits/implementation biannual World Bank progress and challenges of project Planning, visual stories, project support and MoIT office, WB missions, (Development implementation; approvals for the implementation websites and project supervision missions office, VCs monitoring Partners) project transactions and social media to the target visits by the procurements channels); municipalities CMU as needed EU FRIT Emails; progress Share information regarding Planning, Official meetings, site MoIT office, WB (Development reports; PPTs; regular progress and challenges of project As needed implementation visits office, VCs Partners) briefings implementation FRIT Steering Emails; progress Share information regarding Committee Implementation reports; PPTs; regular Official meetings progress and challenges of project MoIT Office Semi-annual (Implementing briefings implementation Partners) 33 STAKEHOLDER ENGAGEMENT PLAN (SEP) Communication Engagement Responsible Subgroup Project Phase Channels/Materials Purpose Venue Frequency Party Mechanism(s) Project appraisal Preparation, package; draft ESMF, Consultations; Ongoing Development implementation LMP Dissemination information meetings, To provide training and capacity trainings and Agencies materials (leaflets, trainings/workshops; building to promote effective DA offices capacity (Implementing posters, brochures, annual assessments of project implementation building under Partners) FAQs); stakeholder DAs Component 3 engagement plan To communicate successful Implementation Non-technical project narratives of social enterprises, Private Sector e.g. summary; press Sourcing platform, entrepreneurship and formal Meetings held MoIT PIU KOSGEB, releases, audio-visual official meetings, employment; to highlight national and Ongoing chambers of stories, project emails opportunities for private sector municipal levels commerce (OIP) websites and project investment in social enterprises for social media channels sustainability Preparation and Non-technical project To keep them informed of the implementation summary; (news project’s alignment with Turkey’s Offices of DGMM (OIP) Official meetings Quarterly release, PAD) harmonization strategy and the DGMM ESSN exit strategy Press releases, To inform the general public about Implementation audiovisual stories, project’s contribution to social project websites and Emails; press entrepreneurship, formal Media (OIP) Ongoing project social media conferences employment, social cohesion, and channels; tv/radio tbd support to both refugees and host communities Preparation, Non-technical project Capacity building; inputs for needs Municipal implementation summary; assessments, market assessments, Offices of DAs/ Authorities , post implementation/plann Consultations, official training needs assessments; municipal Ongoing (Implementing implementation ing documents; meetings, workshops enagement in participatory Development authorities Partners) capacity building selection of livelihoods facilities Agencies materials under Component 2 Terms and guidance on training and mentoring activities for incubation Community Call for Proposals. and acceleration, disbursing grants Implementing Preparation, project Consultations, official to new and existing social Offices of Partners implementation planning/implementat meetings, workshops, entrepreneurs and post-creation Ongoing DAs/CIPs (Implementing ion documents, terms emails supporting services (included under Partners) of agreements with Component 1) and the community CIPs, capacity building mobilization/decision-making and materials 34 STAKEHOLDER ENGAGEMENT PLAN (SEP) Communication Engagement Responsible Subgroup Project Phase Channels/Materials Purpose Venue Frequency Party Mechanism(s) social cohesion activities envisaged under Component 2 Discuss, exchange ideas and provide Ongoing- prior Leaflets, posters (in a clear understanding on the to sub grant print and online), and description of social Target areas in Local information cycles; Preparation, videos online and entrepreneurship and the Project’s municipalities participatory Public in target implementation meetings, sectoral socio-economic benefits to both that are social media needs areas meetings, refugee and host communities; accessible by dissemination, assessments outreach regarding livelihoods the general outdoor ads with and facilities to benefit broader public messages tailored to participatory communities planning cycles cities. TV/radio tbd Preparation, PPTs on WB Apprise contractors of WB implementation requirements, • Presentations procuremet and safeguards Contractors including procurement • Public meetings requirements DA offices and safeguards Implementation Non-technical /post summary of survey Evaluate beneficiary perceptions of MoIT/DAs completion objectives, survey project outcomes and processes questionnaire, report and PPT on survey findings Beneficiary perception Twice – Women and youth survey as part of mid- baseline & from refugee & and end-line completion host communities evaluatoins surveys For Component 1 35 STAKEHOLDER ENGAGEMENT PLAN (SEP) Communication Engagement Responsible Subgroup Project Phase Channels/Materials Purpose Venue Frequency Party Mechanism(s) • Call for Applications Promote enrollment and provide for social capacity building in the social Women and youth enterprises entrepreneurship incubation and from refugee • Printed materials in acceleration program communities languages accessible to them (posters and brochures) To provide feedback, through an Implementation disseminated annual event and interactive Women and youth . through existing scorecard/community check from host outreach initiatives meeting on the quality of the communities (business chambers, training and mentoring services existing service points for Prior to each of employment) • Consultation/public the • Social media and Community Vulnerable groups participation approximately SMS messages Implementing meetings 60 cycles of disseminated Partners • Focus group Offices/ subgrants through already discussions locales in the across three available jobseeker • Presentations target years pools and channels • Capacity building municipalities of local workshops that are stakeholders. • Grievance accessible to • Interactive redress/beneficiary subgroups Annual scorecard event feedback scorecard • For disabled persons mechanism event as part who want to engage • Information desks in of community in the project, the check meeting CIP offices project will include Existing Social measures for their Enterprises accessibility. Depending on the disability circumstances, house visits may also be utilized as needed. • For illiterate, verbal and non-technical communication will be utilized in public 36 STAKEHOLDER ENGAGEMENT PLAN (SEP) Communication Engagement Responsible Subgroup Project Phase Channels/Materials Purpose Venue Frequency Party Mechanism(s) participation meeting • Printed materials • Consultation To develop additional social Community-Based (posters and meetings cohesion focused activities with Organizations/ Localities in brochures) • Focus group local communities to ensure local Women’s target discussions relevance and address local Livelihoods municipalities • Grievance challenges. Ongoing Committees that are redress/beneficiary Community accessible to feedback members/ CBOs and WLCs mechanism leaders • Information desks in CIP offices • Consultation Delivery of specialized modules • Printed materials meetings (social enterprises and the benefits (posters and • Focus group for the HH, managing finances and Localities in brochures) discussions accessing services) to involve male target • Capacity building • Grievance household members and male municipalities Male household materials redress/beneficiary elders of the community that are members and feedback accessible to Ongoing community elders mechanism male household • Information desks in members and CIP offices community elders For Component 2 Women and youth To convene capacity building and beneficiaries from • Participatory facilitation activities for refugees refugee • PPTs planning and host communities to engage in Localities in communities • Printed materials • Grievance participatory decision-making target Women and youth (posters and redress/beneficiary processes over local needs and municipalities beneficiaries from brochures) feedback priorities for livelihoods-related that are Community host communities mechanism facilities; accessible to Implementing Ongoing Community • Information desks in target groups Partners Members/Mukhta Implementation CIP offices rs Municipal Authorities • PPTs Consultations, official To ensure local coordination of all Municipal (Implementing meetings, workshops project activities and to implement offices Partners) Component 2B; align project 37 STAKEHOLDER ENGAGEMENT PLAN (SEP) Communication Engagement Responsible Subgroup Project Phase Channels/Materials Purpose Venue Frequency Party Mechanism(s) • Implementation/pla support with municipal planning nning documents municipalities • Capacity building materials 38 STAKEHOLDER ENGAGEMENT PLAN (SEP) 5.2 Overview of Stakeholder Engagement Methods 5.2.1 Consultation Meetings Consultation meetings will be convened with stakeholders including government authorities, municipal authorities, private sector businesses, chambers of commerce, civil society and existing social enterprises etc. 5.2.2 Participatory Engagement Methods Under Project components 1 and 2, participatory needs assessments will be conducted by trained CIP facilitators. These will focus on compiling information from target beneficiaries through beneficiary dialogues, focus group discussions on the economic constraints and opportunities of individuals and groups engaging in social enterprises. The needs assessments will ensure the genuine engagement of target beneficiaries in the identification of their needs and to promote interaction and substantive discussion between refugees and host communities around livelihoods development. The scope of these assessments will cover both incubation and acceleration beneficiaries. Participatory planning is a process whereby a community undertakes to reach a given socio-economic goal by consciously diagnosing its problems and charting a course of action to resolve those problems. Trained facilitators from the CIPs will conduct outreach and orientation meetings to ensure that target beneficiaries can engage meaningfully in the project. They will also organize participatory planning sessions in collaboration with the municipalities. 5.2.3 Participatory Assessment Participatory assessments and possible perception surveys will explore citizen’s experience and feedback about the project and will be carried out to inform the Project’s mid-line and end-line evaluations. The project will also utilize interactive community scorecards - a two-way and ongoing participatory tool for the monitoring of the incubation and acceleration support services. The community score card sessions will bring together Component 1 beneficiaries and CIPs/providers of capacity building services and the project to jointly analyze issues, underlying capacity building constraints, and other project constraints and find a common and shared way of addressing those issues. The scorecard will result in a joint action plan. 5.2.5 Information Desks Information Desks in DA offices will provide local residents with information on stakeholder engagement and capacity building activities where they can share information about the project with PAPs and other stakeholders. Brochures and flyers on various project related social and environmental issues will be made available at these information desks. 5.2.6 Grievance Redress Mechanism In compliance with the World Bank’s ESS10 requirement, a specific grievance mechanism will be set - up for the project. Dedicated communication materials (GRM pamphlets, posters) will be created to help local residents familiarize themselves with the grievance redress channels and procedures. In 39 STAKEHOLDER ENGAGEMENT PLAN (SEP) face-to-face meetings, the GRM and its details will also be verbally communicated for those who are illiterate. A GRM guidebook/manual will also be developed and suggestion boxes installed in each affected municipality and village. In order to capture and track grievances received under the project, a dedicated GRM Management Information System/database is planned. Internal GRM training will also take place for the MoIT PIU and contractor staff. The MoIT PIU’s website will include clear information on how feedback, questions, comments, concerns and grievances can be submitted by any stakeholder and will include the possibility to submit grievances electronically. It will also provide information on the way the GRM committee works, both in terms of process and deadlines. Refer to next section. 5.2.7 Training workshops Trainings on a variety of social and environmental issues will be provided to MoIT PIU, DAs, contractor staff and possibly relevant CIP facilitators. Issues covered will include sensitization to gender-based violence risks. 5.2.8 Communication Materials Written information will be disclosed to the public via a variety of communication materials including brochures, flyers, posters, etc. A public relations kit will be designed specifically and distributed both in print and online form. The MoIT PIU will also update its website regularly (at least on a quarterly basis) with key project updates and reports on the project’s environmental and social performance both in Turkish and Arabic. The website will also provide information about the grievance mechanism for the project. The project DAs will also have relevant information on the project in their websites, and share communication materials with CIPs, local stakeholders and beneficiaries. DAs will establish effective communication channels with local media institutions regarding the project activities. 5.2.9 Presentations Visual material will be used in public participation meetings and consultation meetings. Presentations will be made which will be summaries of written documents. 5.2.10 Project Brochure In the project introduction brochures that will be presented to the stakeholders in the initial stage, general information about the project, as well as information about grievance mechanism and liaison/feedback channels will be provided. 6. IMPLEMENTATION ARRANGEMENTS FOR STAKEHOLDER ENGAGEMENT 6.1 Elaboration of Stakeholder Engagement Responsibilities This section outlines the key implementation arrangements for the project’s stakeholder engagement. 40 STAKEHOLDER ENGAGEMENT PLAN (SEP) The MoIT PIU will assume the main responsibility for the coordination, implementation and monitoring and reporting of the SEP’s implementation. Table 6 -- Responsibilities of key actors/stakeholders in SEP Implementation Stakeholder Responsibilities • Planning and implementation of the SEP MoIT PIU- • Leading stakeholder engagement activities with development partners, the private Communications sector, FRIT Steering Committee, multi-stakeholder advisory platforms, DAs and Stakeholder • Management and coordination on resolution of grievances Specialist • Monitoring of and reporting on environmental and social performance to GOT and the World Bank • Consolidated reporting on SEP activities for the project overall Planning and implementation of SEP activities vis-à-vis: • Municipal Authorities Development • CIPs Agencies • Regional and provincial level outreach • Reporting on implementation of DA led SEP activities to MoIT PIU • Outreach to PAPs/stakeholders in DA Project areas • Make available the disclosed ESMP documents • Participation in stakeholder engagement activities arranged by DAs and CIPs, especially Local public pertaining to inputs for needs assessments, market assessments, training needs authorities assessments, and component 2 activities around participatory planning for livelihoods investments Planning and implementation of SEP activities vis-à-vis: • Municipal Authorities • Women and youth from refugee & host communities Community • Existing Social Enterprises Implementing • Community-Based Organizations/ Women’s Livelihoods Committees Partners • Community members/leaders • Other local non-governmental organizations • Male household members and community elders • Reporting on implementation of CIP led SEP activities to MoIT PIU • Inform MoIT PIU of any issues related to their engagement with stakeholders • Transmit and resolve complaints caused by the construction activities in close collaboration with and as directed by MoIT PIU by participating in the local Grievance Resolution Committee Contractors • Prepare, disclose and implement various plans (e.g. ESMP, Labor Management Plan, etc.) • Inform local communities of any environmental monitoring e.g. noise, vibration, water quality monitoring • Announce important construction activities (such as road closures and available alternatives) 6.2 Information Disclosure The MoIT PIU will create a webpage on the Project on its existing website and on the selected DA’s websites, through selected CIPs engagement activities, in addition to printed leaflets in Turkish and Arabic. All future project related environmental and social monitoring reports and the Project Operations Manual will be disclosed on the webpages of related DAs. Project updates (including news on construction activities and relevant environmental and social data) will also be posted on this website. An easy-to-understand guide to the terminology used in the environmental and social reports or documents will also be provided on the website. All information brochures/flyers will be posted on 41 STAKEHOLDER ENGAGEMENT PLAN (SEP) the website. Details about the Project Grievance Redress Mechanism will be posted on the website, as well as contact details of the DA level project teams and headquarters and CIP focal points at the municipal level. The PIU will update and maintain the website regularly (at least once on a quarterly basis). 6.3 Estimated Budget The estimated budget allocated for implementing the stakeholder engagement plan over four years is approximately 2,145,000 EUR. 1,050,000 EUR is allocated for community mobilization setting up participatory groups for decision making for the livelihoods facilities, 275,000 EUR is planned for workshops with different stakeholders and 820,000 EUR for communication and visibility activities. 6.4 Monitoring and Reporting of the SEP Component 3 of the Project will support monitoring and evaluation (M&E) activities to track, document, and communicate the progress and results of the project, including monitoring of the Stakeholder Engagement Plan. An M&E team within the MoIT PIU will be responsible for overall compilation of progress and results. The PIU will also monitor the quality of the community mobilization and other inclusion, voice and agency activities with communities as measured through community scorecards, which will be discussed and verified along with financial records and project implementation records. Feedback and grievances received through the grievance redress/beneficiary feedback mechanism will also be included in the semiannual reporting. Finally, the findings of the baseline and end line beneficiary perception surveys will also be included in M&E efforts. Stakeholder Engagement Plan activities will be monitored every six months and reported in project progress reports biannually. 7. GRIEVANCE REDRESS MECHANISM 7.1 Purpose and Scope The DAs and MoIT receive formal requests and grievances through the Presidential Communication Center (CIMER). Other than CIMER, DAs can receive formal grievances either in a writing or through their online web channels. Given that all kinds of complaints are received by CIMER from the public and tracing project-specific requests, concerns or complaints will be difficult through CIMER, also it is only available to Turkish citizens, a project specific grievance mechanism will be needed. In accordance with the requirements of the World Bank, a grievance mechanism open to the use of all stakeholders, directly or indirectly affected by the project will be established. The project-based GRM is intended to serve as a mechanism to: • Allow for the identification and impartial, timely and effective resolution of issues affecting the project; • Strengthen accountability to beneficiaries, including project affected people, and provide channels for project stakeholders and citizens at all levels to provide feedback and raise concerns. Having an effective GRM in place will also serve the objectives of: reducing conflicts and risks such as external interference, corruption, social exclusion or mismanagement; improving the quality of 42 STAKEHOLDER ENGAGEMENT PLAN (SEP) project activities and results; and serving as an important feedback and learning mechanism for project management regarding the strengths and weaknesses of project procedures and implementation processes. The GRM will also allow submission of anonymous grievances. The attached grievance form in Annex 1 will be utilized in the project and allow submission of anonymous grievances. In addition, the project GRM will include a channel to receive and address confidential complaints related with Sexual Exploitation and Abuse/Sexual Harassment in workplace (social enterprises). In addition, as part of the Labor Management Procedures, drafted by MoIT, MoIT PIU will also set up a worker’s grievance mechanism for project workers, who are staff of MoIT, DAs and contracted workers. 7.2 GRM Overview & Structure Who can communicate grievances and provide feedback? The GRM will be accessible to a broad range of Project stakeholders who are likely to be affected directly or indirectly by the project. These will include beneficiaries, community members, project implementers/contractors, civil society, media— all of who will be encouraged to refer their grievances and feedback to the GRM. What types of grievance/feedback will this GRM address? The GRM can be used to submit complaints, feedback, queries, suggestions or compliments related to the overall management and implementation of the project, as well as issues pertaining to sub projects that are being financed and supported by the project, including: • Mismanagement, misuse of Project Funds or corrupt practices. • Violation of Project policies, guidelines, or procedures, including those related to child labor, health and safety of community/contract workers and gender violence. • Disputes relating to resource use restrictions that may arise between or among affected communities. • Grievances that may arise from members of communities who are dissatisfied with the eligibility criteria, project activities, or actual implementation of the project by DAs and CIPs • General feedback, questions, suggestions, compliments. Standards. The SEECO GRM will establish clearly defined timelines for acknowledgment, update and final feedback to the complainant. To enhance accountability, these timelines will be disseminated widely to Project stakeholders. The timeframe for acknowledging the receipt of the grievance is 5 days. Addressing and responding to feedback is 30 days from the time that it was originally received, and this period is subject to extension upon the written consent of the MoIT PIU head. Structure. The structure of the Feedback system/GRM for the project will be comprised of three levels, from the level of the community through the central PIU level. Community Level. To ensure that the GRM is accessible to people at the community level, they will have the option to report their complaint/feedback to designated grievance focal points (GFPs) who are staff in the CIPs. Regional/DA Level. DAs will also appoint respective GRM focal points that can either receive feedback directly from stakeholders, or to whom the community level GRM focal points can escalate issues/complaints. Central/PMU Level. If there is a situation in which there is no response from the community/DA level grievance redress focal points, or if the response is not satisfactory then complainants and feedback 43 STAKEHOLDER ENGAGEMENT PLAN (SEP) providers have the option to contact the PIU directly to follow up on the issue. The PIU’s grievance redress focal point will be responsible for complaints and issues related to all districts and components. The PIU Director will make a final decision after a thorough review of the investigation and verification findings. Appeal Mechanism. If the complaint is still not resolved, the complainant may escalate/appeal to a higher level of GRM within the project at the central level. If s/he is not satisfied with the decision, then s/he can submit his/her complaint to the appropriate court of law. 7.3 GRM Communication & Process Communication. Information about the project’s GRM will be publicized as part of the initial feedback consultations in the participating communities. Brochures will be distributed during consultations and public meetings, and posters will be displayed in public places such as in project offices, local and municipal notice boards, community centers, government offices, etc. Information about the GRM will also be posted online on the PIU website, available in both languages, Turkish and Arabic. Details will be updated in Project Operational Manual and in this SEP, before project effectiveness. Process. The overall process for the GRM will be comprised of 6 steps: (1) uptake (2) sorting and processing (3) acknowledgment and follow up (4) verification, investigation and action (5) monitoring and evaluation and (6) feedback (see figure 3). Figure 3. Feedback and GRM Process Step 1: Uptake. Project stakeholders will have the opportunity to provide feedback and report complaints through several channels (in-person, mail, telephone, project website) at different levels. Step 2: Sorting and Processing. To consolidate, monitor and report on information related to grievances, complaints and feedback related to the project will be documented upon receipt/communication at each level of the GRM, and will be classified in order to manage the grievance redress process more effectively. Feedback/complaints regarding environmental or social issues related to the project activities will be logged in the MIS and documented. Step 3: Acknowledgement and Follow-Up. Within 5 days of receiving complaint/feedback, the grievance redress focal point will inform the complainant about the timeframe and the likely course of action. At the 5-day mark, if a complaint/question is still pending, the GFP in charge of the complaint at that point should provide an update about the status of complaint/question to the person who submitted it and provide an estimate of how long it will take to resolve the grievance or respond to the query. Step 4: Verification, Investigation & Action. Verification and investigation involve gathering information about the grievance to determine its validity and to generate a clear picture of the circumstances 44 STAKEHOLDER ENGAGEMENT PLAN (SEP) surrounding the issue under consideration. This process normally includes site visits, document reviews, a meeting with the complainant (if known and willing to engage) and meetings with individuals and/or entities who can assist with resolving the issue. Potential actions include responding to a query or comment, providing users with a status update, imposing sanctions, or referring the grievance to another level of the system for further action. Depending on which channel the grievance is received, the verification and investigation can be conducted by the GFP in the CIP, or by the M&E staff in the DA or by the communications specialist at the PIU of MoIT. Step 5: Monitoring & Evaluation. Monitoring refers to the process of tracking grievances and assessing the extent to which progress is being made to resolve them. Ultimately, the PIU will be responsible for consolidating, monitoring and reporting on the total number of complaints, enquiries and other feedback for the project that has been received, resolved and that is pending at the community and DA levels, as well as feedback pertaining to the PIU. Information collected by CIPs and DAs will be compiled by the PIU for reporting at the end of every month. Step 6: Providing Feedback. This step entails informing GRM users and the public at large about the results of investigations and the actions taken. Grievance redress focal points will provide feedback by contacting the complainant directly within a 30-day period of receiving the feedback/complaint. The PIU will make quarterly reports available to the World Bank team on the implementation of the Project GRM. In addition, data on grievances and/or original grievance logs will be made available to World Bank project supervision missions. 7.4 Grievance Logs The Grievance Focal Points at the CIP level will maintain local grievance logs to ensure that each complaint has an individual reference number and is appropriately tracked and recorded actions are completed. A sample grievance form and a close-out form is attached in Annex-1. 7.5 Monitoring and Reporting on Grievances The PIU’s GRM focal point who will be the Communications and Stakeholder Specialist will be responsible for: • Collecting and analyzing the qualitative data from grievance redress focal points on the number, substance and status of complaints and uploading them into the single project database; • Monitoring outstanding issues and proposing measures to resolve them; • Submitting quarterly reports on GRM mechanisms to the Project Coordinator at the PIU. Quarterly reports to be submitted by the PIU shall include a section related to GRM which provides updated information on the following: • Status of GRM implementation (procedures, training, public awareness campaigns, budgeting etc.); • Qualitative data on number of received grievances \ (applications, suggestions, complaints, requests, positive feedback), number of resolved grievances; • Quantitative data on the type of grievances and responses, issues provided and grievances that remain unresolved; • Level of satisfaction by the measures (response) taken; • Any correction measures taken. 45 STAKEHOLDER ENGAGEMENT PLAN (SEP) Results posted on the PIU and DA websites. 7.6 World Bank Grievance Redress System Communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to existing project-level grievance redress mechanisms or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project-related concerns. Project affected communities and individuals may submit their complaint to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank’s attention, and Bank Management has been given an opportunity to respond. 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 46 STAKEHOLDER ENGAGEMENT PLAN (SEP) Annex 1. Sample Grievance Form and Grievance Closeout Form GRIEVANCE FORM Name of person receiving grievance: Date: Title: INFORMATION ABOUT COMPLAINANT Ways of Receiving Grievance (This section may not be filled if the complainant wishes to remain anonymous) Name – Surname Phone □ Phone number Information Meetings □ Address Application to Office □ District/Neighborhood Mail/e-mail □ Signature (if possible) Field visit □ Other: □ ……………………………….. DETAILS OF GRIEVANCE 47 STAKEHOLDER ENGAGEMENT PLAN (SEP) GRIEVANCE CLOSEOUT FORM ASSESSMENT OF THE GRIEVANCE Corrective Action Required: □ YES □ NO Please describe the action if it is required to close-out the case RESULT CLOSEOUT This part will be filled in and signed by the complainant and the complaint evaluation committee when the corrective action or file is closed-out. (Instead of taking the signature of the complainant, receipt or other supplementary documents can be attached to the form in order to verify that the file has been closed-out.) Responsible Person Complainant Name-Surname Name-Surname Date and Signature Date and Signature (If possible) 48