Sierra Leone Free Education Project Stakeholder Engagement Plan (SEP) Ministry of Basic and Senior Secondary Education May 2019 Stakeholder Engagement Plan (SEP) Table of Contents Abbreviations and Acronyms ........................................................................................................................ 2 1. Introduction .......................................................................................................................................... 3 2. Stakeholder Engagement ...................................................................................................................... 3 3. Brief Summary of Previous Stakeholder Engagement Activities .......................................................... 4 4. STAKEHOLDER IDENTIFICATION AND ANALYSIS ................................................................................... 6 4.1. Target Stakeholders and Other Interested Parties ....................................................................... 7 4.2. Potential Roles, Interest and Influence of Key Stakeholders ........................................................ 8 4.3. Disadvantaged / Vulnerable Individuals or Groups ...................................................................... 9 5. STAKEHOLDER ENGAGEMENT PROGRAM .......................................................................................... 11 5.1. Purpose and Timing of Stakeholder Engagement Program ........................................................ 11 5.2. Proposed Strategy for Information Disclosure ........................................................................... 14 5.3. Proposed Strategy for Consultation............................................................................................ 15 5.4. Proposed Strategy to Incorporate the View of Vulnerable Groups ............................................ 17 5.5. Responsibilities and Resources for Implementing Stakeholder Engagement Activities ............. 18 6. GRIEVANCE REDRESS MECHANISM .................................................................................................... 18 6.1. Introduction ................................................................................................................................ 18 6.2. GRM scope and use..................................................................................................................... 19 6.3. Procedures .................................................................................................................................. 19 6.4. Awareness-building..................................................................................................................... 22 6.5. Staffing and capacity-building..................................................................................................... 23 6.6. Transparency, monitoring and reporting.................................................................................... 24 7. Monitoring and Reporting .................................................................................................................. 25 7.1. Involvement of Stakeholders in Monitoring Activities ............................................................... 25 Annex 1: Grievance Form............................................................................................................................ 27 Annex 2: Notification Form ......................................................................................................................... 28 1 ABBREVIATIONS AND ACRONYMS ASC Annual School Census CBO Community-Based Organization CERC Contingent Emergency Response Component CoP Communities of Practice EMIS Education Management Information System EPA Environmental Protection Agency ESCP Environmental and Social Commitment Plan ESF Environmental and Social Framework ESMF Environmental and Social Management Framework ESP Education Sector Plan ESRS Environmental and Social Review Summary GBV Gender-based Violence GRM Grievance Redress Mechanisms GRS Grievance Redress Service HCI Human Capital Index IDA International Development Association IPF Investment Project Financing JSS Junior Secondary School LC Local Council M&E Monitoring and Evaluation MBSSE Ministry of Basic and Senior Secondary Education MIS Management Information System MoF Ministry of Finance NDP National Development Plan PFMU Project Fiduciary Management Unit PIU Project Implementation Unit REDiSL Revitalizing Education Development in Sierra Leone SBM School-based Management SEA Sexual Exploitation and Abuse SEP Stakeholder Engagement Plan SGBV Sexual and Gender-based Violence SMC School Management Committee SSS Senior Secondary School TSC Teaching Service Commission WAEC West African Examinations Council 2 1. INTRODUCTION The proposed Free Education Project is a five-year International Development Association (IDA)-funded project supported with a US$70 million credit. The project’s main implementing agency is the Ministry of Basic and Senior Secondary Education (MBSSE). Activities supported under the proposed project would aim to address school- and system-level challenges facing the education sector building on successful activities and approaches supported under the on-going Revitalizing Education Development in Sierra Leone (REDiSL) Project and existing research on effective approaches in Sierra Leone and in other settings. The proposed Project will be comprised of five components: Component 1 – School Improvement Program; Component 2 - Teacher Professional Development and Management; Component 3 - System Administration, Governance and Accountability; Component 4 - Program Management, Coordination and Monitoring and Evaluation. Component 5 is a Contingent Emergency Response Component (CERC), which allows for rapid reallocation of project proceeds in the event of a natural or man-made disaster or crisis that has caused or is likely to imminently cause a major adverse economic and/or social impact. The project is well-aligned with Government and World Bank priorities and strategies focusing on addressing education sector challenges and transforming the education system in the long-term. Its primary objective is to increase the number of children in schools with improved learning conditions and better teaching practices and to strengthen system accountability. The project’s main implementing agency is the Ministry of Basic and Senior Secondary Education (MBSSE) and the project will be implemented using the World Bank’s Environmental and Social Framework (ESF). The Bank’s Environmental and Social Development Specialists prepared an Environmental and Social Review Summary (ESRS) which included information on the type and scope of the proposed project, its potential risks and impacts; and the Environmental and Social Risk Classification (ESRC) which has a preliminary classification as Moderate. The project will invest in physical infrastructure and has the potential to generate significant opportunities in many ways; improving quality learning outcomes, improving school completion rate, training and capacity building, opportunities for employment etc. In line with the government’s commitment to inclusive education the project will pay special attention to issues affecting persons with disabilities and other vulnerable social groupings as well as closely monitor the key social issues identified by the initial environmental and social screening such as gender, gender-based violence [GBV], disability inclusion. Further analysis and consultation on these issues should reveal constraints and opportunities to promote equal access to the project related benefits. 2. STAKEHOLDER ENGAGEMENT The World Bank has a long history of multi-stakeholder engagement and strategies to promote effective project preparation, project implementation and project monitoring, which entails empowering citizens to participate in the development process and integrating citizen voice in development programs as key accelerators to achieving results. Therefore, the World Bank is committed to mainstreaming stakeholder engagement in operations it supports in order to improve outcomes. Stakeholder engagement is defined as the two-way interaction between stakeholders and the government implementing agencies within the scope of the project that gives stakeholders a voice in decision-making with the objective of improving the intermediate and final development outcomes of the 3 intervention (see figure 1). The spectrum of stakeholder engagement includes consultation, collaboration and participation, and integration and responsiveness to stakeholder concerns leading empowerment. Figure 1. Feedback loops created between government and stakeholders As a part of project preparation, the Government has carried out a Stakeholder Engagement Analysis which was aimed at identifying (i) who will be directly or indirectly affected by the project, (ii) how the project to reach out to stakeholders, and (iii) how would the project share information and get stakeholders involved in the decision-making and implementation of the project. This Stakeholder engagement Plan therefore summarizes findings of the analysis and describes the timing and methods of engagement with stakeholders throughout the life-cycle of the project. The process of preparing the Stakeholder Engagement Plan was inclusive as it was designed to accommodate the needs and circumstances of diverse range of stakeholders, paying special attention to identified disadvantaged or vulnerable individuals or groups with consideration for stakeholders’ communication and physical accessibility challenges. 3. BRIEF SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES During the project identification and preparation stage, several consultations took place at the national level involving the MBSSE and at the local and school levels involving other agencies and key stakeholders (see table 1). Table 1. List of stakeholder Engagement Activities conducted during the project identification and preparation stage Stakeholder Main topics discussed • Challenges facing the MBSSE. • Goals/objectives MBSSE wants to achieve. • Strategies to achieve the goals. MBSSE • Indicators the MBSSE wants to use to measure attainment of the goals (results framework). • Monitoring mechanism for the project. 4 Stakeholder Main topics discussed • Implementation arrangement for the project. • Alignment of the project with national strategy. • Investment viability of the project. • Sustainability considerations in the project design. MoF • Contribution of the project to the county’s economic development, poverty reduction and shared prosperity. • Contribution of the project to enhanced human capital. • Challenges facing the PFMU. PFMU • Aspects that need improvement to enhance the operations of PFMU. Local Government Finance • Educational decentralization work in the country. Department (LGFD) • Roles and responsibilities devolved to local level. • Challenges the TSC is facing. • Goals/objectives TSC wants to achieve. • Strategies to achieve the goals. TSC • Strategies to improve teacher management and teacher. Deployment. • Functions and operations of TSC (human resources, budget, annual plan, activities). • Challenges the WAEC is facing. • Goals/objectives WAEC wants to achieve. • Strategies to achieve the goals. WAEC • Strategies to improve quality of examinations. • Functions and operations of WAEC (human resources, budget, annual plan, activities). • Educational decentralization work in the country. • Roles and responsibilities devolved to local level. • Monitoring of schools by LCs. Local Councils • How LCs support education activities. • How LCs work with District Education Offices. • Existing Committees at the LCs and district levels. • Budgetary allocations for education at the LCs. • Educational decentralization work in the country. • Role of District Education Offices (DEOs). • Interaction between DEOs and schools. District Education Offices • How the DEOs support education activities. • How the DEOs work with LCs. • Existing committees at the district levels. • Does SMC function well? • How the performance-based grant work. • Challenges facing schools. • Monitoring visits by inspectors, supervisors, local councils, School heads district education offices, local TSC. • Community support in school management. • Main causes of children’s dropout. • Supply of teaching and learning materials (e.g. textbooks) Effects of the Free Quality Education Program on student enrollment. 5 Stakeholder Main topics discussed • Does the school charge parents any fees? • Challenges teachers are facing. • Professional development training for teachers. • Issues on gender, GBV and inclusive education. • Actions to take to address GBV, gender, inclusive education. • Challenges facing schools. • Competences and qualifications of teachers. • Monitoring visits by inspectors, supervisors, local councils, district education offices, local TSC. • Community support in school management. • Causes of children’s dropout. • Supply of teaching and learning materials (e.g. textbooks). Teachers • Effects of the Free Quality Education Program on student enrollment. • Does the school charge parents any fees? • Challenges teachers are facing. • Do teachers receive professional development training? • Are there any issues relating to gender, GBV and inclusive education? • Functions and operations of SMC • Presence of PTA in schools • Payment of school fees by parents • Awareness on how the performance-based grant is spent and utilized? Parents • Challenges schools face • Satisfaction by parents with school performance • Sharing information by schools • Community support in school management • Causes of children’s dropout. • Issues on gender, GBV and inclusive education • Access to information. • Information disclosure Students • Issues of gender, GBV, and inclusive education. • Child labor/forced labor • School performance • Access to information Communities • Information disclosure • Issues on gender, GBV and inclusive education • Activities of NGO in education sector NGOs • Challenges schools are facing • Support provided by DPs in the education sector Development partners (DPs) • Challenges schools are facing • Issues on gender, GBV and inclusive education 4. STAKEHOLDER IDENTIFICATION AND ANALYSIS 6 4.1. Target Stakeholders and Other Interested Parties In this framework, the following people are considered as stakeholders: (i) those who are affected or likely to be affected by the project; (ii) those who may have an interest in the project. Table 2 summarizes affected (target stakeholders) and non-affected parties who may be directly or indirectly affected by the project. Table 2. List of Potentially Affected Stakeholders and Other Interested Parties Area of Interest by Target Project Component Target Stakeholders Other Interested Parties Stakeholders Component 1: School Improvement Program 1.1 Performance MBSSE, heads, Provision of performance-based MoF, Policy makers, based school teachers and financing (PBF) communities, NGOs financing SMCs/Board of governors 1.2 Physical Local contractors Renovation and construction of Ministry of Lands, Local improvement to schools contractors, Chiefs and learning environment Heads, teachers, Maintenance of infrastructure local authorities, EPA, SMCs Ministry of Works, Local Council, Community engagement Ministry of Labor, communities Information and Ministry of Social communication Welfare, Gender and Local councils, Provision of land, permission children Protection community, chiefs from the local authorities and (MSWFGP) the traditional heads. Community ownership of the project School pupils/ Users of school infrastructure students 1.3 Provision of Heads, teachers, Provision of reading materials Parents, local supplementary MBSSE, parents, Digital libraries community, reading materials pupils/ students NGOs/community-based organizations (CBOs) Component 2: Teacher Professional Development and Management 2.1 Cluster based TSC Provision of the framework for continuous professional development, professional guidance and review of Tertiary institutions, development continuous professional NGOs development Teachers Career development and SLTU training 2.2 Strengthening TSC Capacity building SLTU TSC for efficiency Database on teachers teacher management MBSSE Capacity building MBSSE and deployment Digital Database for recruitment (MSWFGP) and deployment Component 3: Systems Administration, Governance and Accountability 7 3.1 Strengthening MBSSE, WAEC, Curriculum review (gender and NGOs curriculum and Headteachers disability, special needs teacher MSWGCA assessment TSC training SLTU framework Local Council Monitoring and evaluation 3.2 Strengthening MBSSE, Capacity building MoF, policy makers planning and system headteachers management 3.3 Promoting MBSSE, Capacity building, Local community, gender equality in Headteachers, gender and disabilities visibility, Traditional leaders, education Teachers and Curriculum diversity, Religious leaders, NGOs, gender advocacy A safe environment from sexual MSWGCA and women rightsharassment and school based groups GBV, safeguarding policy and referral pathway strengthen Guidance counselors Component 4: Program Management, Coordination and Monitoring and Evaluation 4.1 Program MBSSE Oversight and evaluation Local councils Management and MoF Capacity building coordination Monitoring and Evaluation 4.2. Potential Roles, Interest and Influence of Key Stakeholders Table 3 maps out the potential role, interest and influence in the SEA for each of the stakeholders. Table 3. Potential Roles, Interest and Influence of Key Stakeholders Stakeholder Potential Role of Stakeholder Interest Influence Provides administrative oversight and High High coordination for project Lead in stakeholder engagement and consultations MBSSE Lead in complaints and grievance redress MoF Allocate financial resources High High Ministry of Justice Provides legal advice to project low low PFMU Day-to-day Fiduciary coordination of project High High Local Government High Medium Finance Department Disburses funds to SMCs (LGFD) Provision of the framework, guidance and review High Medium TSC of continuous professional development Curriculum review and performance assessment Medium Low WAEC standards Community engagement High High Local Councils Information and communication 8 Stakeholder Potential Role of Stakeholder Interest Influence District Education Curriculum review and performance assessment High High Offices standards, Supervision Career development and training, administration High High School heads, Teachers, of funds and supervision SMCs School Pupils/ students Beneficiaries of Project interventions High Low Local contractors Renovation and construction of schools High Medium Parents Quality of teaching and learning High Medium Provision of land, permission from the local High High Local community, chiefs authorities and the traditional heads. Community ownership of the project safeguarding policy and referral pathway Medium Medium NGOs strengthen Guidance counselors Dissemination of information in local and national High Medium Media news Development partners Medium High budgetary support and technical assistance (DPs) 4.3. Disadvantaged / Vulnerable Individuals or Groups Disadvantaged/vulnerable individuals and groups, who often do not have a voice to express their concerns or understand the impacts of a project, are sometimes excluded from stakeholder engagement. Table 4 shows potential disadvantaged/vulnerable individuals/groups and limitations they may have regarding participating in in the consultation process. Table 4. List of Disadvantaged/Vulnerable Individuals/Groups Project component Vulnerable Peculiar Preferred means of Additional Resources groups and Characteristics/ notification/Consul Required individual Needs tation 1. School Improvement Program 1.1 Performance-based School Remote community level Provide transportation from School Financing stakeholders Distance, Poor meetings/fora, rural areas to meeting places, in remote Communication Community notices provision of information on poor rural network Local radio noticeboards, recruitment of areas volunteers to disseminate information to remote areas 1.2 Physical Physically Lack of access to Meet Disability Provide transportation cost to Improvements to the challenged meeting places, Commission, persons with disability to Learning Environment persons with long distance to Local/community participate, Information visual and school radio, the media translated to indigenous hearing infrastructure, languages, sign language/ impairment meetings braille Transportation, language barrier, visual impairment 9 Project component Vulnerable Peculiar Preferred means of Additional Resources groups and Characteristics/ notification/Consul Required individual Needs tation 1.3 Provision of Visually and Lack of braille or In schools and local Audio devices, braille, sign Supplementary hearing sign language, community languages, translators, Reading Materials impaired, language barrier infographics illiterate persons 2. Teacher Professional Development and Teacher Management 2.1 Cluster-based teachers with Accessibility, lack Special training Braille, special training Continuous physical of information needs such as facilitators, sign language Professional disabilities and funding for braille, audio translators/interpreters Development for (mobility, training in devices, accessible Teachers hearing, and special needs venues vision impairment) 2.2 Strengthening TSC Teachers in Accessibility, lack More information Transportation for Efficient Teacher remote areas of information, dissemination Management and limited voice through the local Deployment radio and town criers, posters, local language skits and discussions. 3. System Administration, Governance and Accountability 3.1 Strengthening Local Limited voice, Focus group Transportation Curriculum and communities, low meetings, Assessment Framework Women/Fede representation, Engagement at the ration/Associ lack of access to local level including ation of information, the use of radio and Persons with town hall meetings Disability 3.2 Strengthening Local Limited voice, Focused group Transportation Planning and System communities, low meetings, Management women/Girls representation, engagement at the People with lack of access to local level including disabilities information, the use of radio and (Disability town hall meetings Commission) 3.3 Promoting Gender Women, girls, Cultural and focus group Engagement of local NGOs and Equality in Education poor and traditional meeting, use of CBOs who work with disadvantage barriers gender champions, vulnerable people at the d children poverty community level to help pregnant stigma disseminate information and school age organize consultation girls 4. Program Management, Coordination and Monitoring and Evaluation 10 Project component Vulnerable Peculiar Preferred means of Additional Resources groups and Characteristics/ notification/Consul Required individual Needs tation Program Management, Stakeholders Limited voice, Focus group More information Coordination and in remote Low meetings, dissemination through the Monitoring and areas representation, engagement at the local radio and town criers, Evaluation Lack of access to local level including posters, local language skits information, the use of radio and and discussions. Community town hall meetings level engagement/consultations rather than at a district headquarters 5. STAKEHOLDER ENGAGEMENT PROGRAM 5.1. Purpose and Timing of Stakeholder Engagement Program As set out in ESS10, stakeholder engagement is an inclusive process that must be conducted throughout the project life cycle. Table 5 presents an outline of key stakeholder engagement activities to take place during the project preparation stage through to implementation and closure. Table 5. Proposed Stakeholder Engagement at Preparation stage Project component Target stakeholders Expected discussion and decisions Project preparation stage 1. School Improvement Program 1.1 Performance-based • MBSSE and District • How Performance-based financing (PBF) can School Financing Education Offices be improved. • SMCs and school • Stakeholders understanding of the purpose of heads PBF and use of the funds for intended purposes. • Inclusive process for designing and agreeing on intervention for financing • How Monitoring will be conducted. 1.2 Physical • MBSSE, local councils, • Environmental and Social Risk Assessment and Improvements to the district education mitigation plans Learning Environment offices • Organizational structure for E&S • SMCs and school implementation heads, teachers and • Project Grievance Mechanisms pupils • Disclosure of ESMF, RPF, SEP, ESCP and other • traditional and related E&S information opinion leaders, local • Effective ways to provide school communities infrastructure. • EPA • Supervision of school infrastructure and • Ministry of Labor maintenance of quality standard. • MSWFGP • GRM dissemination • NGO/CSOs • GRM 11 Project component Target stakeholders Expected discussion and decisions 1.3 Provision of • MBSSE • Teachers utilization of reading materials to Supplementary • SMCs and school improve children’s reading proficiency. Reading Materials heads, teachers and • Reading Materials in accessible formats for pupils/ Students teachers and students with disabilities • Reading materials to include sex and adolescent education and GBV relevant information targeting boys and girls. 2. Teacher Professional Development and Teacher Management 2.1 Cluster-based • TSC • Strengthening pedagogical skills by TSC. Continuous • Teachers • Effective use of teacher and other teaching Professional aids by teachers Development for • Improvement of teachers teaching skills after Teachers the training. 2.2 Strengthening TSCs • TSC • Issues TSC encounter regarding teacher for Efficient Teacher management and deployment Management and • Incentives for deployment of teachers, Deployment especially female teachers to remote areas 3. System Administration, Governance and Accountability 3.1 Strengthening • MBSSE, WAEC • How curriculum and assessment framework Curriculum and • School heads can be improved and be more inclusive. Assessment Framework • What capacity building is needed. 3.2 Strengthening • MBSSE • How annual school census (ASC) is conducted. Planning and System • School heads • What information needs to be captured Management through (ASC). • How to ensure quality assurance • How EMIS system can be improved. 3.3 Promoting Gender • MBSSE • What gender related issues exist. Equality in Education • Schools heads and • How the project can address gender issues. SMCs • What activities are implemented by other • NGOs and DPs partners. 4. Program Management, Coordination and Monitoring and Evaluation Program Management, • MBSSE • How to monitor the project activities and Coordination, • PFMU of MoF achievement of results framework Monitoring and • Local council Evaluation Project implementation stage 1. School Improvement Program 1.1 Performance-based • MBSSE and District • Whether schools improved school School Financing Education Offices performance (students, teachers) after • SMCs and school receiving PBF. heads • Whether school stakeholders understand the • Ward education purpose of PBF and use the funds for intended committees purposes. • Local councils • Whether monitoring mechanism works. 1.2 Physical • MBSSE, local councils, • Sub-project Environmental and social Improvements to the district education screening Learning Environment officers, EPA 12 Project component Target stakeholders Expected discussion and decisions • • Assessment and preparation of ESHIA, ESMP, • SMCs and school • RAPs as needed heads, teachers and • Disclosure of any follow up safeguards pupils instruments • Compensation and resettlement as required • traditional and • Training and awareness on community Health opinion leader, local and Safety including GBV prevention communities • Awareness on project GRM • EPA • Environmental permitting • Ministry of Labor • How school infrastructure improvement can • MSWFGP take place. • WASH • What kinds of challenges are identified at NGO/CSOs implementation stage? • District environmental • Whether monitoring and supervision take officers, place. • Local councils 1.3 Provision of • MBSSE •Whether reading materials are delivered to Supplementary • Headteachers schools on time. Reading Materials • teachers • Whether teachers use materials to improve children’s reading proficiency. 2. Teacher Professional Development and Teacher Management 2.1 Cluster-based • TSC • Whether TSC has developed good professional Continuous • Teachers training program. Professional • Headteachers • Whether teachers are using the tablet Development for effectively. Teachers • Whether there is an improvement in teacher performance. 2.2 Strengthening TSC • TSC • What is the strategy developed to improve for Efficient Teacher • Teachers teacher management and deployment Management and Deployment 3. System Administration, Governance and Accountability 3.1 Strengthening • MBSSE, WAEC • Whether activities are implemented as Curriculum and • School heads scheduled. Assessment Framework • teachers • Whether capacity is built by the project interventions. 3.2 Strengthening • MBSSE • What implementation challenges are Planning and System • School heads identified. Management • teachers • Whether the project achieved expected results. 3.3 Promoting Gender • MBSSE • Whether the project has addressed gender Equality in Education • Schools heads and issues. SMCs/Board of • What challenges are identified. Governors • NGOs and DPs 4. Program Management, Coordination and Monitoring and Evaluation 13 Project component Target stakeholders Expected discussion and decisions Program Management, • MBSSE • Whether the project achieved the targets. Coordination, • PFMU of MoF • Whether project management, coordination, Monitoring and • Local councils monitoring and evaluation are implemented Evaluation properly. 5.2. Proposed Strategy for Information Disclosure Table 6 describes what information will be disclosed, how it will be disclosed and the frequency with which it will be disclosed to each of the stakeholder groups. Table 6. Strategy for Information Disclosure Project List/ Type of Methods of Timetable/ Target Responsibl component information to disclosure Frequency stakeholders e be disclosed proposed stakeholder s 1. School Improvement Program 1.1 School School feedback Every term Parents, SMCs, Performance- performance form displayed in communities, Board of based School information and school board and civil governors Financing information on society use of PBF 1.2 Physical ESMF, RPF, Disclose in Before Civil society, MBSSE Improvements Stakeholder country appraisal local to the Learning Engagement in two local communities, Local Environment Plan, ESCP newspapers and Parents, Councils. Infrastructure on the After building SMCs/ improvement government infrastructure contractors Board of plan, website. Hard improvement Governors construction copy should be plan is schedule, GRM available in key approved documents institutions. Posted on local council/communit y noticeboards and radios. 1.3 Provision of Information on Notification When schools Parents, SMCs, School Supplementary delivery date of displayed in receive and heads, Reading materials school board notification of communities teachers Materials delivery 2. Teacher Professional Development and Teacher Management 2.1 Cluster- Training Through district After training Teachers TSC based information TSC and school date is set SLTU Continuous heads, website of Professional TSC 14 Project List/ Type of Methods of Timetable/ Target Responsibl component information to disclosure Frequency stakeholders e be disclosed proposed stakeholder s Development SLTU for Teachers 2.2 Strategy of Through district Throughout Teachers, civil TSC Strengthening teacher TSC, website of the project society SLTU TSC for Efficient management TSC Teacher and deployment SLTU Management and Deployment 3. System Administration, Governance and Accountability 3.1 Findings of National After national Government MBSSE Strengthening national assessment report assessment is officials Curriculum and assessment and dissemination analyzed TSC, SLTU Assessment workshop School heads Framework and teachers 3.2 Results of school Report After the School MBSSE Strengthening annual census completion of stakeholders Planning and Website of MBSSE activities System School standards and social media Government Management officials 3.3 Promoting Supporting Website of As needed Students, MBSSE Gender Equality information on MBSSE, social parents, SMCs in Education prevention and media, poster on and responses to local councils, and communities school-based newspapers gender violence 4. Program Management, Coordination and Monitoring and Evaluation Program Information on Government’s Bi-annual Civil society MBSSE and Management, the project website Local councils PFMU Coordination results Community and Monitoring framework Monitoring and Evaluation groups 5.3. Proposed Strategy for Consultation Table 7 is a proposed strategy for consultation. Methods vary depending on target audience, nature of activities and level of interest of the stakeholder group in project activity. Table 7. Strategy for Information Disclosure Project Topic of Methods used Timetable Target Responsibil component consultation stakeholders ities 1. School Improvement Program 1.1 PBF Focus group Every term SMCs MBSSE Performance- implementation discussion and 15 Project Topic of Methods used Timetable Target Responsibil component consultation stakeholders ities based School interview with Financing stakeholders 1.2 Physical Infrastructure Meetings and After SMC, local MBSSE Improvements improvement focus group beneficiary councils, local to the Learning plan discussion schools are award Environment identified committee 1.3 Provision of Monitoring of Meetings After District MBSSE Supplementary delivery to beneficiary education Reading schools and schools are office, local Materials utilization of identified councils, local materials ward committee 2. Teacher Professional Development and Teacher Management 2.1 Cluster- Development of Meetings During the Teachers, DPs TSC based training contents preparation Continuous stage Professional Development for Teachers 2.2 Strategy of Interviews and Throughout Teachers, TSC Strengthening teacher meetings the project government TSC for Efficient management officials, DPs Teacher and deployment Management and Deployment 3. System Administration, Governance and Accountability 3.1 Curriculum and Meetings and During the Government MBSSE Strengthening assessment focus group preparation officials, Curriculum and framework discussions stage resource Assessment persons, Framework Leading teachers, DPs 3.2 School annual Meetings During the Government MBSSE Strengthening census and preparation officials, DPs Planning and school standards stage System Management 3.3 Promoting Mechanism to Meetings, focus Throughout Government MBSSE Gender Equality address gender group discussions, the project officials, in Education issues interviews. resource persons, DPs 4. Program Management, Coordination and Monitoring and Evaluation Program Project Meetings Bi-annual Government MBSSE and Management, performance and officials, local PFMU Coordination, the project councils, Community 16 Project Topic of Methods used Timetable Target Responsibil component consultation stakeholders ities Monitoring and results Monitoring Evaluation framework group 5.4. Proposed Strategy to Incorporate the View of Vulnerable Groups The MBSSE is responsible for ensuring inclusion and representation, including for vulnerable groups. The project has developed a strategy which aims to remove obstacles to participation of such groups (see table 8). Table 8. Strategy to incorporate vulnerable groups Target groups Strategy Stakeholders in remote poor • Information translated to indigenous/local languages. rural areas and who have • Robust engagement with local community-based organizations. limited access to • Resources allocation to wards representatives and councilors. information • Provision of transportation or transportation cost. • More information dissemination through the local radio and town criers, posters, local language skits and discussions. Village/chiefdom/district level meetings • Community level engagement/consultations than at a district headquarters. • Engagement of local NGO’s and CBO’s who work with vulnerable people at the community level to help disseminate information and organize consultations Females • The project will arrange separate consultation sessions (e.g., meetings and focus group discussion) men and women separately. • Smaller and gendered focus group discussions where women and girls are at ease to speak. • The project will use various communication measures including women associations or organizations to reach out to female groups at the district/chiefdom/village levels • The project will use various measures including sensitization, community empowerment, and provision of psychosocial counseling and support services to address gender issues in education such as workshops on gender issues, advocacy and media campaigns Disabled stakeholders • The project will use various communication measures to reach out disabled such stakeholders. (Disability Commission) • Information will be translated to sign language/ braille. • Information will be shared with them through supporting organizations. District/chiefdom/village level meetings • Engagement of local NGO’s and CBO’s who work with vulnerable people at the community level to help disseminate information and organize consultations. Vulnerable/ Disadvantaged • The project will arrange separate consultations sessions for different families target groups. 17 • The project will use various communication measures to reach disadvantaged family. • Project Community Liaison officer/ District MSWGCA officers/Local Councils/ward committees 5.5. Responsibilities and Resources for Implementing Stakeholder Engagement Activities Overall responsibility for the project will lie with the MBSSE, which will have a dedicated project secretariat that will be responsible for day-to-day project management and coordination of project activities. The Free project secretariat will provide reports of project progress and make this available to the Minister of Education and the World Bank. To function effectively, the project secretariat will have at least the following contract officers on hand: (a) Head (coordinator(b) M&E officer, (c) Program officer, (g) environmental specialist, (d) social Specialist, and (e) Additional administration staff as needed. Other functions, including communications and human resources, will be carried out by the MBSSE with support and guidance from the project secretariat. The Secretariat (M&E officer) is also responsible for implementation of stakeholder engagement activities and GRM activities under Component 4 Project Management, Coordination, Monitoring and Evaluation (US$6 million), working closely with the communications unit of MBSSE. Stakeholder engagement plan will be incorporated in the Project Operations Manual and Annual World Plan and Budget. Policy direction and the oversight of the project will be carried out by an Inter-Ministerial Steering Committee at the national level for policy direction and oversight. The committee will review the overall performance of the project and decide on important policy aspects to facilitate the achievement of outcomes and results. The committee will comprise of the MBSSE (including implementing agencies), Ministry of Finance, Ministry of technical and Higher Education, World Bank, and a representative from each contributing development partners. The committee will pay special attention to stakeholder engagement in preparing, implementing and monitoring the project activities, and will report on the status of the stakeholder engagement programs during project implementation. 6. GRIEVANCE REDRESS MECHANISM 6.1. Introduction There is currently no clearly defined GRM reporting system in the education sector. Strengthening system accountability is a key outcome of the project. To this end, the project needs to establish a grievance redress mechanism (GRM). The project is expected to strengthen accountability for beneficiaries and provide channels for project stakeholders to provide feedback on project activities. It is also expected to provide a mechanism that allows for the identification and resolution of issues affecting the project, including safeguards related complaints, misconduct of staff, misuse of funds, abuse of power, and other improper behavior. By increasing transparency and accountability, the GRM aims to reduce the risk of the project inadvertently affecting citizens/beneficiaries and serves as an important feedback and learning mechanism that can help improve project impact. A separate GRM will be established by contractors during implementation to address employee grievances consistent with ESS 2. The GRM established under the project should be accessible to all, including ethnic, religious, gender, and other special groups. The mechanism focuses not only on receiving and recording complaints but also on how complaints are resolved. The GRM should be supported by an information campaign and training. 18 While feedback should be handled at the level closest to the complainant, all complaints should be registered and follow the set procedures. 6.2. GRM scope and use Scope: The project should include a GRM that will be available for project stakeholders to submit questions, comments, suggestions and/or complaints, or provide any form of feedback on all project- funded activities. Who Can Use The GRM? Project beneficiaries, project affected people (i.e. those who will be and/or are likely to be directly or indirectly affected, positively or negatively, by the project), as well as the broader citizenry can use the GRM for the purposes of making complaints or providing feedback. Project affected people include those who will be affected in resettlement issues. There should be no charge for making a complaint or conveying comments or suggestions. 6.3. Procedures 6.3.1. Establishment of Grievance Redress Committee/Body The Grievance Redress Committee (GRC) shall be established by MBSSE in consultation other relevant parties to the project. The membership of the GRC shall comprise of representatives from the following; a. MBSSE b. Local Contractors c. Local Council/Chiefs d. Legal Officer e. NGOs/Civil society Organization f. Persons with Disability Association g. PFMU h. GRM Manager… 6.3.2. Channels to make complaints It is suggested that the project will establish the following channels through which citizens/beneficiaries can make complaints regarding project activities. a. A dedicated email address [EMAIL] b. A dedicated phone line [TOLL FREE NUMBER] c. On the project website [WEB ADDRESS] d. Feedback boxes located at [LOCATIONS including remote locations] e. Letters sent to [ADDRESS] f. Verbal or written complaints to project staff (directly or through project meetings). (If project stakeholders provide verbal feedback/complaint, project staff will lodge the complaint on their behalf, and it will be processed through the same channels. Project at all stages will have options for use of local languages+ interpreters when submitting complaints. g. Constitution of Grievance Committee members (which include women) h. Project meetings set up at the [specify] level, each of which include women. i. Oral language interpreters for lodging complaints 19 The project shall ensure flexibility in the channels available, make sure that different contact points are available for a person to make a verbal complaint, and that complaints addressed to the wrong person or entity are redirected to the Project secretariat. 6.3.3. Confidentiality and conflict of interest Complaints may be made anonymously, and confidentiality will be ensured in all instances, including when the person making the complaint is known. For this reason, multiple channels to make a complaint have been established and conflicts of interested will be avoided. 6.3.4. Collection/receipt of complaints The person receiving the complaint will complete a grievance form (see Annex 1), or make the form available to the complainant to fill out directly, and submit it without delay (within 24 hours) to the M&E officer of the Project Secretariat (GRM Manager) who is responsible for GRM. The complaints for the project will be collected and compiled by the Free Project Secretariat on a regular basis. 6.3.5. Sorting/categorization Once received and filed the Free Project Secretariat will sort the complaints/feedback into the following categories Category No. Classification Category 1 Safeguards, including compensation disputes, land allocation and delays in compensation Category 2 Grievances regarding violations of policies, guidelines and procedures Category 3 Grievances regarding contract violations Category 4 Grievances regarding the misuse of funds/lack of transparency, or other financial management concerns Category 5 Grievances regarding abuse of power/intervention by project or government officials Category 6 Grievances regarding Project Secretariat staff performance Category 7 Reports of force majeure Category 8 Suggestions Category 9 Appreciation 6.3.6. Recording/logging Once the complaints have been categorized, the GRM Manager logs the details regarding the complaint into the tracking system. This system may be manual (hard copy) or connected to the project MIS system. GRM files should be stored in a secure setting (password protected IT database or locked storage cabinet for hard copies). Once a complaint has been logged and sorted, the GRM Manager refers the case to the Project Coordinator. The latter shall determine the following: • The person responsible to investigate the complaint. • The timeframe within which the complaint should be resolved. • The agreed course of action (e.g. investigation, reply not requiring investigation, etc.). 20 The investigation process is determined based on the nature and gravity of the complaint, however regardless of type/category complaints all complainants should be assured of receiving feedback within 10 business days • For resettlement-related complaints, regardless of the complexity of the case, the Social Safeguards Specialist with the Project Secretariat will be involved in the conduct of the investigation in addition to, or instead of the Investigating Officer • For local level complaints, the investigation will be conducted by First Investigating Officer in five days. • For complex complaints, the investigation will be conducted by Second Investigating Officer/Entity in ten days or as otherwise agreed with the GRM Manager.1 When determining who will be the investigating officer, the Project Secretariat will ensure that there is no conflict of interest, i.e. all persons involved in the investigation process should not have any material, personal, or professional interest in the outcome and no personal or professional connection with complainants or witnesses. Once the investigation process has been established, the person responsible for managing the GRM records and enters this data into the log-book. The number and type of suggestions and questions should also be recorded and reported so that they can be analyzed to improve project communications. 6.3.7. Notification to the complainant If the complainant is known, the Project Secretariat will communicate the timeframe and course of action to her/him by phone, email or mail, within two weeks of receipt of the grievance.2 Where the complainant’s address is available, this should be provided in writing with a tracking number and the deadlines by which they will hear back from the Project Secretariat (see Annex 2 Notification Form). 6.3.8. Investigation The person responsible for investigating the complaint will gather facts in order to generate a clear picture of the circumstances surrounding the grievance. Verification normally includes site visits, review of documents, a meeting with the complainant (if known and willing to engage), and a meeting with those who could resolve the issue (including formal and informal village leaders, or other leaders). With regards to resettlement and grievances related to valuation of assets, revaluation by an independent valuer may be undertaken at the expense of the project. in case negotiations through the project GRM fails to reach an agreement. The case might have to go to the court for resolution. 1 For complex and severe complaints, senior management should be informed and assign responsibilities for conducting the investigation. Senior management should also take part in the investigation and invite observers and external experts. 2This two-week timeframe assumes the number of grievances is relatively small. The time service standard will be adjusted if the volume of grievances increases beyond a manageable level. 21 In cases of GBV related complaints no investigation should be conducted. Rather, cases should be referred to the NGO procured under the project to manage GBV cases for referral to the appropriate service providers. The results of the verification and the proposed response to the complainant will be presented for consideration to the GRM committee of the MBSSE. Once the decision has been made on the course of action and on the response to provide to the complainant, the Project Secretariat describes the actions to be taken in the grievance form (see Annex 1), along with the details of the investigation and the findings and enters it into the MIS. 6.3.9. Response to complainant If the complainant is known, the Project Secretariat communicates the proposed action to her/him via letter, email, verbally, as received within 10 days. The complainants will also be informed by who on how s/he can appeal the action decided in the initial case. The Project Secretariat will request feedback from the complainant as to whether s/he deems the action(s) satisfactory, and this will be recorded along with the details of the complaint and the response taken. 6.3.10. Possibility to appeal In the event the complainant is satisfied with the response, discussions will be held in group or individually to further clarify the positions at stake. Senior management will take part in these meetings and a final decision on the action(s) will be made. The Project Secretariat will form a Grievance Committee that will hear appeals. The Grievance Committee shall be comprised of staff from the Project Secretariat and persons who are independent from the project implementing authorities and the government. The terms of the Grievance Committee will be agreed prior to its format. The complainant is not precluded from appealing outside the project/Project Secretariat GRM3 if they are not satisfied with the proposed response. 6.4. Awareness-building 6.4.1. Information provided in an accessible format Information about the grievance handling system is expected to be distributed to all beneficiaries and project affected people through regular information channels used by the project, including initiating meetings at the start of the project, public consultations held on resettlement, public meetings during project implementation, brochures/pamphlets in local languages, posting on notice boards and online (including council meetings, meetings vulnerable groups, meetings with contractors and workers. Channels of dissemination through short skits, jingles) 3 An alternate dispute mechanisms such as a court of elders or to the formal legal system. 22 The Project Secretariat will include information provided on the scope of the GRM, the eligibility criteria to make a complaint, the procedure to make a complaint (where, when and how), the investigation process, the timeframe(s) for responding to the complainant, as well as the principle of confidentiality and the right to make anonymous complaints. 6.4.2. Proactive advertisement/regular public information campaigns information campaigns will be designed by the Project Secretariat before project commencement to encourage the use of the GRM. The campaigns will use local media (e.g. TV, newspaper, radio). When organizing and conducting these campaigns, special efforts shall be made to reach vulnerable groups. The campaigns should include information on the scope of the GRM, the eligibility criteria to make a complaint, the procedure to make a complaint (where, when and how), the investigation process, the timeframe(s) for responding to the complainant, principle of confidentiality and right to make anonymous complaints. Information on complaints received and resolved will be reported as part of the project’s routine quarterly reporting. Also, a summary of implementation of the grievance mechanism will be provided to the public on an annual basis, after removing identifying information on individuals to protect their identities. 6.5. Staffing and capacity-building 6.5.1. Roles and responsibilities The Project Secretariat will allocate responsibilities to Project Secretariat staff (unless the GRM is outsourced). These will be documented in the first Quarterly Progress Report and kept updated. - Overall management of the GRM system - Developing and maintaining awareness-building - Collection of complaints - Recording/logging of complaints - Notification to the complainant - Sorting/categorization of complaints - Investigation - Decision-making based on the investigation results - Processing appeals - Publishing responses to complaints - Organization and implementation of information materials and awareness campaigns - Budgeting of the GRM - Reporting and feedback on GRM results 6.5.2. Capacity-building Training for all relevant staff and relevant stakeholders will be held annually, or as otherwise agreed. New staff will receive training as a regular part of the onboarding process. The training will include all aspects of the GRM set out in this chapter. All trainings should include information on the GRM principles and procedures. The training will have an emphasis on accountability to the complainant. A key focus at the 23 outset will be shifting from informal complaint resolution, to the logging of all complaints/feedback into this system. Dedicated trainings should be provided to staff directly engaging with beneficiaries, those handling the system, and those involved in the management and oversight of the system. 6.6. Transparency, monitoring and reporting 6.6.1. Transparency Policies, procedures and regular updates on the GRM system, the complaints made and resolved, will be available online, as well as on local/ministerial notice boards and other permanent displays. They will be updated quarterly. 6.6.2. Regular internal monitoring and reporting The Project Secretariat will assess the functioning of the GRM and undertake spot checks during regular supervision visits. The Project Secretariat will work with M&E Specialist to: - Ensure accurate entry of GRM data into the management information system or other system. Produce compiled reports to the format agreed with the Project Director. - Provide a monthly/quarterly snapshot of GRM results (as set out below) including any suggestions and questions, to the project team and the management. - Review the status of complaints to track which are not yet resolved and suggest any needed remedial action. During annual/bi-annual general meetings, the project team shall discuss and review the effectiveness and use of the GRM and gather suggestions on how to improve it. 6.6.3. Reporting in quarterly and annual progress reports submitted to the Bank Quarterly and annual progress reports shall include a GRM section which provide updated information on the following: - Status of establishment of the GRM (procedures, staffing, training, awareness building, budgeting etc). - Quantitative data on the number of complaints received, the number that were relevant, and the number resolved - Qualitative data on the type of complaints and answers provided, issues that are unresolved - Time taken to resolve complaints - Number of grievances resolved at the lowest level, raised to higher levels. - Satisfaction with the action taken - Any particular issues faced with the procedures/staffing or use - Factors that may be affecting the use of the GRM/beneficiary feedback system - Any corrective measures adopted 6.6.4. Oversight and review 24 The status of the development of the GRM, the levels of use by beneficiaries/ citizens, the challenges of implementation, etc. will be discussed in semi-annual/annual portfolio meetings. The Project Secretariat will discuss with the Bank during implementation support missions any corrective measures that may be needed. An independent review/audit of the GRM, will be conducted prior to the mid-term review to assess the effectiveness and use of the mechanism, and recommend introduce improvements as necessary. 7. MONITORING AND REPORTING 7.1. Involvement of Stakeholders in Monitoring Activities The M&E activities will focus on inputs, processes, and outcomes. Given the strong alignment between the proposed project’s indicators and those to be used to monitor the implementation and measure the impact of the Government’s program, monitoring of these indicators will be incorporated into the MBSSE EMIS and will be tracked as part of standard monitoring under the technical supervision and support of the Directorate of Planning. A M&E officer of the Project Secretariat will work closely with the MBSSE to ensure data collection, cleaning, analysis, and reporting are completed according to the project requirements. The MBSSE collects data annually on all schools in basic and senior secondary education through annual ASCs, including information on gender and children with disabilities. School performance and key indicators including gender and children with disabilities will be tracked through the ASC. Given the project’s reliance on timely and reliable data for effective implementation, capacity building in the areas of data collection, analysis, reporting, and dissemination will be provided. The Free project secretariat, with support from the M&E officer and social specialist, will be responsible for monitoring and compiling a number of reports as well as ensuring the effective carrying out of the ASC and other project-supported activities reliant on data. The following reports will be required throughout the project duration at established intervals: (a) annual work plan on project implementation by component and subcomponent, including stakeholder engagement plan and (b) progress reports detailing achievements under each activity, progress on each of the indicators in the Results Framework, and analysis of identified gaps and next steps (biannually). The performance of the project will be reviewed regularly, including through biannual implementation support and supervision mission led by the Word Bank. The World Bank will provide implementation support and supervision during the project implementation period. Implementation support and supervision missions will be undertaken at least every six months and will monitor and report on progress made under the project through the implementation status and results reports (ISRs). The World Bank will also review whether the project has taken necessary actions to address issues on gender, GBV and disability. An in-depth review will be undertaken at the project implementation midpoint, by June 30, 2022. A midterm review will provide an opportunity to assess overall progress in project implementation, update the Results framework as necessary, review allocation across components, reassess the risks, and propose corrective measures to ensure achievement of the PDO. 25 Monitoring and evaluation under the project will rely on each level of the education system —from the school level, to local levels, and the central level. The MBSSE is responsible for ensuring effective monitoring processes are adopted and that information flow is smooth reaching the relevant stakeholders on time. Steps will be taken to ensure that each feedback mechanism established under the project can provide timely data to the local-level stakeholders. The project will maintain a strong GRM given the project’s reliance on community inputs for effective implementation and achievement of project outcomes. Information on the GRM will be provided in the context of SMC and school-level training. The project secretariat will ensure timely response to any grievances received. 26 ANNEX 1: GRIEVANCE FORM GRIEVANCE/INQUIRY RECORD Instructions: This form is to be completed by staff receiving the inquiry or grievance and sent to the Free Project Secretariat at the national office. Attach any supporting documentation/letters as relevant. Date Grievance Received: Name of Staff Completing Form: Grievance Received (check √): □ National □ District □ Chiefdom Mode of Filing Inquiry or Grievance (check √): □ In person □ Telephone □ E-mail □ Phone Text Message □ Website □ Grievance/Suggestion box □ Community meeting □ Public consultation □ Other ______________ Name of Person Raising Grievance: (information is optional and always treated as confidential) Gender: □ Male □ Female Address or contact information for Person Raising Grievance: (information is optional and confidential) Location where grievance/problem occurred [write in] National: District: Chiefdom: Others: Others: Brief Description of Grievance or Inquiry: (Provide as much detail and facts as possible) Category 1 Safeguards, including compensation disputes, land allocation and delays in compensation Category 2 Grievances regarding violations of policies, guidelines and procedures Category 3 Grievances regarding contract violations Grievances regarding the misuse of funds/lack of transparency, or other financial management Category 4 concerns Category 5 Grievances regarding abuse of power/intervention by project or government officials Category 6 Grievances regarding Free Project Secretariat staff performance Category 7 Reports of force majeure Category 8 Suggestions Category 9 Appreciation Who should handle and follow up on the grievance: Progress in resolving the grievance (e.g., answered, being resolved, settled): Other Comments: 27 ANNEX 2: NOTIFICATION FORM GRIEVANCE ACKNOWLEDGEMENT Instructions: This form is to be completed by the Free Project Secretariat and mailed or delivered to the complainant. Date Grievance Received: Tracking Number: Grievance Received (check √): □ National □ District □ Chiefdom Mode of Filing Inquiry or Grievance (check √): □ In person □ Telephone □ E-mail □ Phone Text Message □ Website □ Grievance/Suggestion box □ Community meeting □ Public consultation □ Other ______________ Name of Person Raising Grievance: (information is optional and always treated as confidential) Gender: □ Male □ Female Contact information for the Person Raising Grievance: (information is optional and confidential) Email: Phone: Address: 28