VCRTP World Bank ESMP Package 1
VCRTP World Bank ESMP Package 1
Prepared for:
Ministry of Infrastructure and Public Utilities, Public Works Department
Quality Information
Revision History
Submitted
Revision Revision Date Details
Name/Position
A 22/06/2022 Draft for review ESS Consulting/International Environment Specialist
B 12/07/2022 Final Draft ESS Consulting/International Environment Specialist
Table of Contents
1 Introduction ................................................................................................................................................................. 8
1.1 Scope and Objectives ..................................................................................................................................... 8
1.2 Integration of the ESMP .................................................................................................................................. 9
1.3 Disclosure ........................................................................................................................................................... 9
2 Project Description .................................................................................................................................................. 10
2.1 Overview of Proposed Works .................................................................................................................... 10
2.1.1 Bridge Upgrades and Replacements ............................................................................................... 11
2.1.2 Proposed Bridge Design Types ......................................................................................................... 13
2.1.3 Bridge Realignment Sections.............................................................................................................. 15
2.1.4 Climate Resilient Box Culverts ........................................................................................................... 17
2.1.5 Detour Roads ........................................................................................................................................ 18
2.2 Ancillary Works and Sites ........................................................................................................................... 18
2.2.1 Aggregate Sourcing ............................................................................................................................ 18
2.2.2 Construction Camps .............................................................................................................................. 19
2.2.3 Workers Accommodations .................................................................................................................. 19
2.2.4 Haulage ................................................................................................................................................. 20
3 Consents and Permitting ........................................................................................................................................ 22
3.1 Permits ............................................................................................................................................................. 22
3.2 World Bank Operational Policies .............................................................................................................. 22
4 Stakeholder Engagement...................................................................................................................................... 24
4.1 Public Consultations to Date ........................................................................................................................ 24
4.2 Stakeholder Engagement and Consultation Plan .................................................................................... 24
4.2.2 Key Messages ....................................................................................................................................... 25
4.2.3 Implementation Plan ............................................................................................................................ 26
4.3 Resources and Responsibilities .................................................................................................................... 28
4.4 Grievance Redress Mechanisms ................................................................................................................. 28
5 Environmental and Social Mitigation and Monitoring ..................................................................................... 30
5.1 Management Tables ..................................................................................................................................... 30
5.2 Supplementary Management Processes ................................................................................................... 30
5.2.1 Land Tenure, Access and Acquisition ................................................................................................ 30
5.2.2 OHS ........................................................................................................................................................ 31
5.2.3 HIV Prevention and Gender Based Violence ................................................................................. 34
5.3 Contractors ESMP (CESMP) ......................................................................................................................... 36
1 Introduction
The Government of Vanuatu (GoV) has requested support from the World Bank (WB) to develop strong and
more climate resilient infrastructure. The Vanuatu Climate Resilient Transport Project (VCRTP) has been
developed to strengthen an approximate total of 65km (5km of existing sealed road and 60km of unsealed
road) of the South Santo Road on Espiritu Santo between Luganville and Tasiriki due to the important role it
plays in linking east to west while also serving transit traffic between its northwest via Tasiriki and Luganville.
Tasiriki functions as a gateway for the northern part of the country. Santo accounts for 20 percent of the
national population and 26 percent of the country’s road network, but only 24 percent of Sanma’s roads
are sealed compared to 37 percent for Shefa. Road infrastructure is inadequately maintained, and in need
of both rehabilitation and more routine maintenance. Poor road conditions are driving up transport costs,
hindering access to services and markets, and restricting economic growth in rural areas.
The Project will (i) reseal 5km between Luganville and Saint Michel and seal the existing 60 km of gravel
road between Saint Michel and Tasiriki to enhance road resilience and connectivity during rainy seasons; (ii)
construct eleven new bridges to address loss of connectivity issues; (iii) repair three existing bridges with
improved traffic safety; (iv) construct 102 single and multicellular box culverts to meet forecasted rainfall
volume and intensities; and, (v) construct other ancillary structures to improve climate resiliency, such as
coastal protection, masonry covered drains, unvented drifts, gabion retaining walls, etc. The Project will not
create new roads however it will shift the alignment of 3 river crossings by a maximum of several hundred
meters. It will not widen existing roadways, only the existing declared network will be subject to the
improvement and maintenance program. Without the Project, the coming years will see further degradation
of the South Santo Road and further reduce the connectivity for the islands population.
Mitigation: The ESMP identifies feasible and cost-effective measures that may reduce potentially significant
adverse environmental impacts to acceptable levels. The plan includes compensatory measures if mitigation
measures are not feasible, cost-effective or sufficient.
Monitoring: The ESMP identifies the elements of the ESMP which require monitoring, how frequently they
should be monitored, when they should be monitored and who is responsible for carrying it out. Monitoring
is provided through a series of easily implemented checklists.
Grievance Redress Mechanism: A mechanism for receiving and addressing all grievances and complaints
related to the Project is set out in the ESMP. It seeks to resolve all complaints as quickly as possible to the
satisfaction of the aggrieved party.
Implementation Arrangements, Schedule and Costs: The ESMP includes a description of implementation
arrangements, including the roles and responsibilities of the Project Implementation Unit, Implementing
Agencies, Contractors, Engineers and Project consultants. The ESMP also builds scheduling of measures into
its planning including phasing and coordination with overall Project implementation plans. Where
appropriate, capital and recurrent cost estimates and sources of funds for implementation of the ESMP have
been estimated.
Capacity Development and Training: The ESMP identifies any gaps in institutional capacity and recommends
measures and costs to address them.
1.3 Disclosure
As part of the requirements of GoV law and World Bank policy, the ESMP is to be publicly disclosed and
will be the responsibility the VCRTP PIU. The PIU will ensure the ESMP is disclosed in hard copy and on their
website. Likewise, the PIU will ensure that several copies of all prepared safeguard instruments are available
locally at the PWD and DEPC offices, easily accessible to affected groups and local NGOs. The ESMP will
be disclosed in hard copy at the following places:
The ESMP is a dynamic document and will be reviewed, updated and approved as necessary throughout
the implementation of the Package 1 of the VCRTP. For each approved updated version of this ESMP, the
VCRTP Project Manager will be responsible for disclosure through the above channels.
2 Project Description
2.1 Overview of Proposed Works
The VCRTP seeks to provide a sustainable climate resilient road infrastructure along the 65km South Santo
Road corridor and will include: (i) construction of wet crossings/bridged to improve connectivity; (ii) coastal
reinforcement to protect the road; and, (iii) upgrading of gravel to paved road along the corridor
including upgrading of existing vented fords to larger culverts or bridges with adequate capacity to pass
storm flows.
These works will include strong climate resilience elements to provide resilient infrastructure solutions that
are fit-for-purpose and potentially adopting relatively new technologies.
Figure 1: Target length of South Santo Road from Sarakata Bridge to Tasiriki village including all bridges.
In line with the consultation with PWD and WB and based on the results of the detailed site survey and
detailed design carried out from January to December 2021, the project will be divided into three
construction packages in consideration of balanced distribution of construction cost per a package, current
regional conditions, construction method and urgency of implementation. Table 4 described the division of
the packages.
Table 1: Division of VCRTP works into design packages for tender
Contract
Target Sections Scope of Works
Package
Replace 11 bridges
14 Bridges and 2 culverts across entire South Santo
1 Improvements to 3 bridges
Road
Construct 2 new culverts
2 End of Section 1, 1.6km KP5.1 to 6.7 Targeted improvements to sections
This ESMP addressed the environmental and social requirements for Package 1 of the VCRTP. Packages 2
and 3 will be addressed in separate ESMPs.
2.1.1 Bridge Upgrades and Replacements
The bridges have been progressed to the detailed design stage and the design report and drawings have
informed this section of the project description. The construction Package-1 of the VCRTP will include:
• New construction of eleven bridges and minor repairs on three existing bridges: Sarakata Bridge,
Adsone Bridge and Wailapa Bridge along the project road in order to enhance climate resilience
and connectivity of the road especially during rainy seasons;
• Construction of two box culverts (existing Kere bridge and Tanovusvus) to accommodate for
forecasted volume and intensity of rainfall; and,
• Construction of footpath for all bridges including two pedestrian exclusive bridges, namely Adsone
and Wailapa pedestrian bridges
• Construction of other ancillary structures to improve traffic safety, climate resilience, such as rock
rip-rap, gabion for slope protection, etc. All these works include the strong climate resilient element
to provide climate resilient solutions on road infrastructure that are fit-for-purpose.
Based on a traffic survey and detailed site investigation, the Design and Supervision Consultant (DSC) the
detailed design for the 14 bridges is shown in Table 2.
Table 2: Detailed work scope of Package 1
The corrosion protection for all steelwork including pins, bolts, nuts and washers, shall be hot dip galvanizing.
USA, Noneban, Maniao and Loloviso bridges will be steel truss bridges.
BRIDGE TYPE 2: STEEL PLATE GIRDER
The bridge superstructure of steel plate girder shall consist of a standard prefabricated steel plate girder
bridging span as shown on the Drawings. The main steel girders are to be formed from standard steel
members that are pinned together. There are four lines of girders under of the deck. The main bridge deck
support elements are to span transversely between the lines of girders and the riding surface of the deck
shall be made from cast in-situ reinforced concrete with a suitably textured surface.
Venue and Venaus bridges will be steel plate girder bridges.
BRIDGE TYPE 3: CONCRETE MODULAR
The bridge superstructure of concrete modular shown on the Drawings shall consist of steel moulds for the
superstructure planks and abutment headstocks with pre-attached reinforcement into which in-situ concrete
shall be placed. All exposed steelwork including tie-bars, pins, bolts, nuts and washers, shall be Grade
304 stainless steel in accordance with ASTM A276. The steel forms shall be hot-dip galvanized in
accordance with AS/NZS 4680 for general ferrous articles.
Waialo, Navaka and Bouvo bridges will be concrete modular.
The proposed new alignment will improve the conditions for a new bridge, however it does result in the
need for significant land acquisition which is subject to an approved ARAP which will provide the measure
for settling the land acquisition at Navaka and will detail the inventory of losses. The ARAP will be
approved by the WB and will be implemented before any works can commence at the site.
MANIAO BRIDGE
Realignment (Figure 4: Proposed realignment for Maniao Bridge) is needed to sustain the bridge and
provide better climate resilience. It is proposed that the crossing will be aligned upstream from its current
site. It will be a single span 30m bridge with 100m long new approach roads on either side. The existing
bridge is scoured and tends to become a delta during flash floods making it unsuitable for bridge
construction.
LOLOVISO BRIDGE
Realignment (Figure 5) is needed to sustain the bridge and provide better climate resilience. It is proposed
that the crossing will be aligned upstream from its current site. It will be a single span 30m bridge with
100m long new approach roads on either side.
Temporary Approach
Bridge Location Direction Detour
Name of Bridge Bailey Road
No. (KP) (RHS, LHS) Road (m)
Bridge (m) (m)
BR-02 6.2 USA RHS 60 170 200
operating licenses and all necessary environmental approvals. The survey indicates that those five
commercial quarries can provide two to three times in quantity needed for the construction.
Since the aggregate from 5 quarries are suitable in quality and available for 2~3 times in quantity as
needed for the project, riverbed materials from Navaka River and other rivers will not be required for
Package-1.
It is anticipated that there will be no internationally sourced aggregates, however should any aggregates
need to be imported they will be from a preapproved country and will be required to comply with
Vanuatu biosecurity measures and any additional measures in the ESMP.
It is prohibited to use sand from any beaches on Vanuatu from this project unless approved by the DSC,
follows the environmental requirement of the Quarry Act, detailed in an approved Quarry Management
Plan and approved by the Department of Environmental Protection and Conservation.
they have been used in the recent past for housing workers during road maintenance works. The sites will
be made compliant with the necessary requirements of the IFC/WB Workers Accommodation: Process and
Standards Codes of Practice which includes GBV, HT, and CAE (Appendix F and I and Section 5.2.3 of the
VCRTP ESMP) should be followed. The location, size and design of any workers camps will be detailed in
the CESMP and approved by the DSC.
Potential locations for workers accommodation will be identified by the Contractor and included in their
ESMP (CESMP). Sites will be screened for environmental and social impacts by the Contractor which will be
verified by the VCRTP PIU. The PIU will only approve suitable sites for use by the Contractor which are
compliant with the requirements of this ESMP and have minimal environmental or social impacts.
A Workers Management and Training Plan (WMTP) is be required from the Contractor as an appendix to
the CESMP under the VCRTP Supplementary Specifications. Particular attention should be paid to visitor
management, sanitary water systems and waste management.
2.2.4 Haulage
Movement of aggregates, materials and equipment will take place along the South Santo Road. While the
road is suitable for haulage over short distances, the road condition means that longer distance journeys
would be time consuming, put the other road traffic at risk and impeded implementation.
Previous PWD works along the South Santo Road have avoided much of these impacts by transporting
heavy machinery and equipment via ro-ro barge from Luganville to two offloading sites along the
southern coast (Figure 6). Both sites are connected to the South Santo Road by existing feeder roads. These
sites are beach landings, but they have both been used in the past to offload heavy plant and this has
been achieved without constructing any wharfs or ramps.
Figure 6: Offloading beaches approved by PWD for offloading activities via beach landed ro-ro vessel
Figure 7: Viru offloading leach (left) and Nakere offloading beach (right)
3.1 Permits
Based on a comprehensive review of the legislation relevant to the project, a summary of the national
consents and permits required for the works package, including supporting documentation, is presented in
Table 5.
Table 5: Permitting Requirements for the VCRTP. Source: Distilled from review of existing legislation
The VCRTP ESIA and ESMP establishes a unified process for addressing all environmental and social
safeguard issues on potential activities from preparation, through review and approval, to implementation.
Effective implementation of the ESMP will ensure that the substantive concerns of all World Bank
safeguard policies will be satisfactorily addressed.
4 Stakeholder Engagement
An updated and approved SECP has been developed for the VCRTP and will be disclosed with the ESIA
and ESMP. This section summarises the contents of the updated SECP.
Stakeholders will require engagement across the VCRTP Project for the VCRTP works. The VCRTP ESIA has
identified the relevant stakeholder groups for VCRTP and community consultations have already been
undertaken with the project stakeholders and communities during the project planning and safeguard
assessment phases. Details of stakeholder identification, stakeholder groups and completed consultations can
be found in the ESIA.
A Stakeholder Engagement and Consultation Plan (SECP) has been developed as part of the ESIA for
implementation through the ESMP.
• Ministry of Infrastructure and Public Utilities will improve oversight and monitoring of road works.
• Works contractor(s) to implement a Workers Management Plan and observe required behaviour in
the community, to address issues including:
o Influx of Labour,
o Sexual Abuse and Exploitation (SAE),
o Gender-based Violence (GBV),
o Communicable Diseases.
• Grievance Redress Mechanism will be implemented to address any complaints and grievances,
which arise during the course of implementing the project.
• Increased access to regular/larger markets and improved economic development for village
communities.
• Improved road safety.
• Improved commerce for local businesses and women groups.
• Increase in job opportunities for locals.
• Improved climate resilience of road infrastructure.
Design Phase
Responsible Activity Objective Stakeholders Medium Timeframe
DSC NSSS with Consultation to Ensure APs are Affected -one on one Prior to the DSC
support from secure access fully informed Persons consultations or others
PST ISSS consent for further and give - focus group accessing any
design consent discussions with affected
family groups property
-access consent form
Consult on the Ensure -stakeholder & These
DSC NSSS with feasibility of design stakeholders All identified community meetings consultations will
support from and sites and feedback - focus group be done to
PST ISSS proposed informs project discussions inform the final
technologies decisions -one on one detailed design
consultations and completed
prior to
tendering
DSC NSSS with Initial consultation Enable -stakeholder & These
support from on the proposed stakeholders to All identified community meetings consultations will
PST ISSS GRM approach inform the - focus group inform the final
design of the discussions agreed GRM
GRM -one on one
Pre-Construction Phase
Responsible Activity Objective Stakeholders Medium Timeframe
PIU CLO with Disclose the GRM Ensure All identified -stakeholder & Prior to start of
support from stakeholders Particular focus community meetings civil works
PIU NSSS and can access the on vulnerable -focus group
PST ISSS GRM and the groups discussions
GCT. -project booklet
Community -GRM complaint form
representatives -website
selected.
PIU CLO & GRM Training Ensure Community Training workshop Prior to start of
CCLO with community Representatives civil works
support from representatives
PIU NSSS, GSS fully
and PST ISSS understand and
can support
community
members to
access the GRM
& GCT
DSC NSSS with Detailed Ensure fair and Affected -One on one Prior to start of
support from Measurement transparent Persons consultation civil works
PIU NSSS and Survey negotiation and -survey and inventory
PST ISSS cash or in-kind of losses
compensation
paid for
affected land
and non-land
assets
PIU NSSS with Disclose updates to Advise -Affected -community meetings Prior to
support from ARAP and ESMP stakeholders of Person -one on one tendering and
PIU GSS and designs and -Communities consultations prior to start of
PST ISSS updated -Executive Summary civil works
mitigation in the Project Booklet
measures and -website
management
plan
CCLO with Pre-construction Ensure -All identified, -stakeholder & Once contractor
support from updates stakeholders especially community meetings is on board and
PIU NSSS & are informed re Government & -one on one prior to start of
PIU CLO employment Community & consultations works
opportunities APs -emails, letters and
and works phone calls
start-up -newspaper
-notice boards
-text message
CCLO with Contractor(s) GAP Contractor and -GBV & HIV -one on one GAP approval
support from developed and community are service consultations prior to start of
PIU GSS & implemented clear on providers -emails, letters and civil works.
SCSS contractor -women’s phone calls GBV, HIV, SAE
responsibilities groups & Code of
and targets for -GCT Conduct training
gender action; ongoing.
GBV, SAE, HIV
CCLO with Contractor(s) ESMP Contractor and -government -one on one CESMP
support from developed and community are consultations approval prior
SCSS & PST disclosed clear on the -emails, letters and to start of civil
ISSS & IESS mitigation phone calls works and
measures for -notice boards ongoing.
social & -executive summary
environment
impacts
PIU GSS with Consultation and Increased -government, -one on one Continuous
support from engagement with gender equity donors, civil consultations throughout the
PST ISSS key decision makers within a range society groups -emails, letters and project.
of transport & PLTA phone calls
policies and -workshops
processes
Construction Phase
Responsible Activity Objective Stakeholders Medium Timeframe
CCLO with Commencement of Advise all -All identified, -community meetings At least 1-week
support from Works update and stakeholders of especially -one on one prior to start of
PIU NSSS on-going commencement Community & consultations civil works and
consultation for of works. APs & GRM - notice boards monthly update
notification of To review GRM Community -radio, newspaper meetings held in
works program processes and Rep’s -text message areas with
provide active works
ongoing
consultation.
CCLO with Contractor(s) GAP Ensure workers -all identified -community meetings Continuous
support from implemented adhere to code -GBV & HIV -one on one throughout the
Land Acquisition: Project activities will require permanent land access as well as loss of non-land assets,
therefore an Abbreviated Resettlement Action Plan (ARAP) has been developed. During project
implementation, the ARAP will be updated based on the detailed design, updated measurement and census
surveys, valuation of affected assets and consultations with affected persons. MIPU and the WB will endorse
the ARAP. Key activities to update the ARAP are described in the ARAP.
Works shall not proceed on any land until the WB approved ARAP has been implemented. This applies to
all lands subject to acquisition under Package 1 of the VCRTP
5.2.2 OHS
During construction and operation health and safety is to be managed through a Site Specific Contractor
Safety Plan (CSP) and application of international environmental and health and safety (EHS) standards
(WB/IFC EHS Guidelines). The Contractors health and safety documentation should incorporate all aspects
of the project including ancillary sites.
Civil works shall not commence until the DSC has approved the CSP, the Safety Officer is mobilized and on
site, and staff have undergone induction training.
The following are the requirements for OHS that are stipulated in the bidding documents:
Health and Safety: Funding for Occupational Health and Safety (OHS) training and activities is provided
in the bill-of-quantity as a provisional sum. The Contractor’s costs shall be financed from this on proof of
record (e.g. time sheets, material invoices etc.) for the following:
Civil works shall not commence until the DSC has approved the OHS plan, the Safety Officer is mobilized
and on site, and staff have undergone induction training.
The Contractor shall at all times take all reasonable precautions to maintain the health and safety of the
Contractor’s Personnel. In collaboration with local health authorities, the Contractor shall ensure that first
aid facilities and sick bays are available at all times at the Site, including having a site vehicle available
at all times that can be used to transport Contractor’s and Employer’s Personnel to medical facilities. The
Contractor shall ensure that suitable arrangements are made for all necessary welfare and hygiene
requirements and for the prevention of epidemics.
The Contractor shall appoint a certified Safety Officer at the Site, with qualifications acceptable to the
DSC, responsible for maintaining safety and protection against accidents. This person shall have the
authority to issue instructions and take protective measures to prevent accidents. Throughout the execution
of the Works, the Contractor shall provide whatever is required by this person to exercise this
responsibility and authority.
The Contractor shall post in clearly accessible places information on how to transport injured Contractor’s
and Employer’s Personnel to medical facilities, including the precise location and contact details of such
medical facilities, name and contract details of the site designated Safety Officer.
The Contractor shall ensure that all workers on the site have appropriate PPE of an appropriate standard
including: (i) impact resistant safety eyewear; (ii) safety footwear with steel toe, sole and heel; (iii) high
visibility clothing; (iv) long sleeves and long pants suitable for operating environment; (v) safety helmet
with provision of sun protection as necessary; (vi) gloves (carried and worn when manual handling); (vii)
hearing protection when working in close proximity to noisy equipment and in all underground
environments. For site visitors, the above equipment will be supplied as appropriate based on assessed
risks and depending on number of visitors and where they will be on site. See http://tinyurl.com/nzta-ppe-
requirements for additional information.
Within 5 working days of the end of the calendar month the Contractor will be required to report to the
DSC on their performance with the following OHS indicators using the project’s reporting tool:
• Number of fatal injuries (resulting is loss of life of someone associated with the project or the
public)
• Number of notifiable injuries (an incident which requires notification of a statutory authority under
health and safety legislation or the contractor’s health and safety management system)
• Number of lost time injuries (an injury or illness certified by a medical practitioner that results in
absence of work for at least one scheduled day or shift, following the day or shift when the
accident occurred)
• Number of medical treatment injuries (the management and care of a patient to effect medical
treatment or combat disease and disorder excluding: (i) visits solely for the purposes of
observation or counseling; (ii) diagnostic procedures (e.g. x-rays, blood tests); or, (iii) first aid
treatments as described below)
• Number of first aid injuries (minor treatments administered by a nurse or a trained first aid
attendant)
• Number of recordable strikes of services (contact with an above ground or below ground service
resulting in damage or potential damage to the service)
• Number of aggregate haulage truck movements (including variations from speed limits, prescribed
routes and vehicle breakdowns or accidents).
• Lost Time Injury Frequency Rate (the number of allowed lost time injury and illness claims per 100
full-time equivalent workers for the injury year specified)
• Total Recorded Frequency Rate (the number of recordable injuries [recordable/lost time/fatal]
per 100 full-time equivalent workers for the injury year specified)
OHS reporting will be coordinated with the CESMP reporting to ensure that all reporting requirements are
combined into a single monthly report which captures all requirements of the CESMP and CSP report
Reporting of accidents and injuries: Contractor shall include in its OHS Plan a set of procedures for
responding to and preventing workplace accidents, including vehicle accidents.
All workplace accidents shall be recorded and included in regular contract progress reports.
All serious workplace accidents, that is those accidents that involve serious injury requiring off site medical
treatment shall be recorded in detail including all aspects of the accident, including details of: the location
and type of work; those directly involved; any witnesses; and all other relevant matters including steps
taken to remedy the situation and treat the injured people.
All serious accidents shall be reported to the PIU within 48 hours of the accident taking place.
The Contractor, in conjunction with the DSC shall formally investigate the causes of all serious accidents and
set up preventative steps to avoid a repeat. The accident investigation and report shall be forwarded to
the PIU within 5 working days of the accident taking place.
PIU shall review the report within 5 working days of receipt and forward to the World Bank with
comments and the steps taken to avoid similar serious accidents in future.
The PIU will issue instructions to the DSC to instruct the Contractor amend all work practices and procedures
or implement such other safety or preventative measures as may be deemed necessary to help ensure
there are no repeat or similar accidents.
5.2.2.1 Covid-19
The GoV has a set of guidelines published for preventing Covid-19 in the workplace1. The latest guidance
was published in 2020 and may have changed. The Contractor is responsible for ensuring they are
adhering to the latest guidelines at the time of developing their CESMP. This will be advised by PWD
following the advice in https://covid19.gov.vu/
The guidance provides advice for the usual measures in the areas of: (i) simple ways to prevent the spread
of Covid-19 in the workplace; (ii) guidelines for conducting meetings and trainings; (iii) things to consider
when workers travel; (iv) getting the workplace ready for the arrival of Covid-19, and; (v) other
information and resources.
PIU will ensure that the Contractor has the latest Covid-19 information relating to quarantine, isolation
periods and testing requirements prior to mobilisation to site. The Contractor Safety Plan will full describe
the Contractors strategy for managing Covid-19.
1 https://covid19.gov.vu/index.php/resources/public-health-guidelines
Prior to contractor mobilization, the approved service provider shall prepare an action plan for the IEC
campaign based on the ‘Road to Good Health Toolkit’ (www.theroadtogoodhealth.org) which shall be
submitted to the DSC for approval.
The action plan will clearly indicate (i) the types and frequency of education activities to be done; (ii) the
target groups (as a minimum to all the Contractor's employees, all Sub-Contractors and Consultants'
employees, and all truck drivers and crew making deliveries to Site for construction activities as well as
immediate local communities); (iii) number of condoms provided; and (iv) referral locations for STI and
HIV/AIDS screening, diagnosis and counselling. The awareness and prevention program shall detail the
resources to be provided or utilized and any related sub-contracting proposed. The program shall also
include provision of a detailed cost estimate with supporting documentation. Payment to the Contractor for
preparation and implementation this program shall not exceed the Provisional Sum dedicated for this
purpose.
The IEC campaign shall be conducted while the Contractor is mobilized in accordance with the approved
approach. It shall be addressed to all target groups identified concerning the risks, dangers and impact,
and appropriate avoidance behaviour with respect to, of Sexually Transmitted Diseases (STD)—or
Sexually Transmitted Infections (STI) in general and HIV/AIDS in particular.
The HIV/AIDS Awareness and Prevention Program will be included as an annex to the Contractors ESMP
and reported against monthly.
Gender-Based Violence/SAE: As required in the bid documents, the Contractor will implement a gender
action plan to prevent gender-based violence (GBV) and sexual assault or exploitation (SAE). The gender
action plan will include an accountability and response framework and Codes of Conduct for all
employees. The Codes of Conduct should be based on, at a minimum, the code of conduct content in
Appendix E of this ESMP. The Contractor, through its Community Liaison Officer (CLO) and with support of
an external training provider, shall establish and implement the plan.
The DSC shall provide to the Contractor a list of approved service providers which shall include recognized
NGOs and others for conducting training on GBV. From the provided list, the Contractor shall enter into
agreement with one service provider to undertake the GBV IEC campaign. The cost of the campaign shall
be funded by the Contractor from the provisional sum provided in the bill-of-quantity.
All Contractor employees (including managers) will be required to attend an induction training prior to
commencing work to reinforce the understanding of gender-based violence (GBV), human trafficking (HT)
and sexual assault and exploitation (SAE). Subsequently, employees must attend a mandatory training
course at least every 3 months for the duration of mobilization and the contractor shall ensure that at least
one toolbox refresher is conducted each month to review IEC materials provided.
The Mitigation Table in Appendix A details the requirements for managing the influx of labour to minimise
the risks posed to the communities to these issues.
The gender action plan and codes of conduct will be included as an annex to the Contractors ESMP and
reported against monthly.
In addition to these requirements, the Contractor is to ensure that all overseas project staff undergo a
cultural familiarisation session as part of their induction training. The purpose of this induction will be to
introduce the project staff to the cultural sensitivities of the local communities, their concerns on previous
experience with outside workers cited during project consultations, and the expected behaviours of the
staff in their interactions with these communities. The VCRTP PIU shall provide to the Contractor the
approved service providers and others for conducting this training.
As the Vanuatu is a member of the International Labour Organisation which states that the minimum
age for hazardous work is 18 and given that construction work with heavy machinery can be classed
as hazardous work, the Contractor shall ensure that no children under the age of 18 are employed to
work in a construction or physically demanding role.
The WMTP will also provide detail of how the Contractor will provide for workers camp facilities,
workers camp operations and the management of off duty workers.
liability period). The EMP will also capture all additional planning as required in this ESMP such as the
erosion and sedimental control planning, site restoration and decommissioning planning and
contingency planning. The Plan shall meet all requirements under 1.16 of the Supplementary Specifications
as well as the project ESMP.
COMMUNITY LIAISON PLAN (CLP) – setting out the key community and other contacts required for
effective community stakeholder engagement and includes the results of early and interim consultations
and proposed meeting schedules with community representatives and stakeholders. CLP will set out the
rules, restrictions and requirements of surrounding communities regarding the work programme and
workforce. The CLP will also include the Contractor’s approach and commitment to; gender-based
violence prevention, protection of children, HIV&AIDS/ STD prevention, community and stakeholder
engagement, code of conduct. The CLP shall also specify how complaints are to be managed
(Grievance Redress Mechanism). Agreement and arrangements for the use of local resources will
require to be in writing and attached to the CESMP. This plan shall meet the requirements under 1.18.2
in the PWD Specifications and any other requirements included in the project ESMP.
GENDER ACTION PLAN (GAP) – setting out a program and plan for training and awareness in the
prevention of gender-based violence, human trafficking as well as sexual abuse and exploitation. The
plan will include Codes of Conduct and Action Plan. This plan will meet the requirements under 1.18.5 in
the PWD Specifications and 1.18.5 of the Supplementary Specifications as well as the project ESMP,
details of training will be included in the WMTP.
TRAFFIC MANAGEMENT PLAN (TMP) – setting out how the Contractor will meet the traffic management
requirements of the ESMP and manage traffic including signage and traffic management around
detours, physical works, camp sites, and haulage routes. The requirements of PWD Specification
Clause 1.11 Loading Limit on Public Roads are to be followed. The TMP shall meet all requirements
under 1.8.2 in the PWD Specifications and 1.8, 22.1 of the Supplementary Specifications as well as the
project ESMP.
WASTE MANAGEMENT PLAN (WMP) – setting out how wastes are to be managed and provisions for
waste disposal of all types of wastes (liquid and solid) generated by physical and all ancillary works.
This plan supersedes the requirement of Clauses under 3.4 in the PWD Specifications with significant
additional supplementary requirements set out in the project ESMP.
CONTRACTORS SAFETY PLAN (CSP) - is the Occupational Health and Safety plan and program for the
project and will cover all project related activities and work sites. This plan corresponds to and
supersedes 1.15.2 in the PWD Specifications and will meet the requirements of 1.15 of the Supplementary
Specifications and any supplementary requirements in the project ESMP.
HIV/AIDS AWARENESS AND PREVENTION PROGRAM – setting out the Contractor’s approach and
timeframe to meet the requirements of 1.14 in the PWD Specifications and 1.14 of the Supplementary
Specifications as well as the project ESMP.
WORK CAMP PLAN (WCP) – setting out the rules for and approach to securing and managing the
accommodation camp, the location of all materials and equipment storage areas, including staging areas
for the project.
The CESMP will be provided to the Construction Supervisor (or delegate) for review as a complete set
of documents insofar as possible and will provide with sufficient time for review (minimum 21 days
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prior to mobilisation or deployment). The Contractor is also required to produce the above
management plans as part of their CESMP. These management plans are referred to throughout the
Specification and also the VCRTP ESMP.
As well as the standard content associated with professional reporting, the CESMP shall also contain, at
a minimum, the following information. The CESMP must use the below listed items to be consistent with,
and respond to, the ESMP and bid document, the conditions of permits and approvals from the
relevant ministry departments. The document should reflect contemporary good practice; be balanced,
objective and concise; and be written in a way that is easily understood by other parties. All
commitments must be specific and auditable with measurable outcomes and clear timeframes. The
CESMP must cover all activities within the project’s area of influence. The area of influence includes the
active worksites, laydown areas, construction camps, production facilities (concrete, asphalt etc.) and
materials sources.
DECLARATION AND DOCUMENT VERSION CONTROL: person accepting responsibility for the
environmental management plan – signed declaration; the document version control should be a simple
system that ensures that details of all key changes to the document over time are properly recorded.
PERMITS, AGREEMENTS AND PLANS: copies of all plans, licenses and agreements for materials supply,
land use, restoration quarry management plans etc as may be required by the Contractor to meet legal
obligations and the requirements of this ESMP. Agreements and arrangements for the use of any and all
local resources will require to be in writing and attached to the CESMP.
ENVIRONMENTAL MANAGEMENT ROLES AND RESPONSIBILITIES : The CESMP should define the roles and
responsibilities of personnel in charge of the environmental management of the project to reflect the
requirements in the ESMP including a mandatory full-time Community Liaison Officer (CLO) fluent in a
minimum of English and Bislama. The roles and responsibilities of each relevant position should be
documented, including the responsibilities of subcontractors. The names of the responsible personnel do
not need to be included. Identification of the position titles, roles and responsibilities is sufficient. If the
roles and responsibilities are expected to change over time the long-term variations should also be
documented.
CONTRACTOR’S CODE OF CONDUCT ON ENVIRONMENTAL, SOCIAL, HEALTH AND SAFETY: This code of
conduct or statement, also required as part of the Contractor’s bid for the works, shall clearly set out
the Contractor’s intent and commitment to apply good international and industry practice as well as
implementing all contractual safeguards requirements to ensure all environmental and social impacts
arising from the activities of the Contractor, the contractor’s employees, subcontractors, suppliers or
associates are to be avoided, minimised or mitigated at all times. They are required to include, at a
minimum, the content of Code of Conduct in Appendix E of this ESMP. The contractor’s employees, other
contractors, subcontractors, suppliers or associates will confirm their agreement to respect and follow
the Code of Conduct in writing through a declaration or similar, enforceable arrangement that is in a
language(s) comprehensible to them.
REPORTING : The description of reporting requirements should include: a list of required reports
including where appropriate monitoring, environmental incidents, non-compliance, corrective action and
auditing; a description of the standard report content; the schedule or triggers for preparing a report;
who the report is provided to; and document control procedures. This will also include the requirement
for the CESMP monthly reporting to be combined with the required OHS reporting.
ENVIRONMENTAL SAFEGUARDS TRAINING : All people involved with the project should receive relevant
environmental training to ensure they understand their responsibilities when implementing the CESMP.
People to be trained include those at the site/s of all project activities and operations, including
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contractors, subcontractors and visitors. The training should be tailored to the role of the individual in
the project. The CESMP will include a list of the training needed and the plan for undertaking this
training. The CESMP will also identify the resources to conduct this training (internal/external).
EMERGENCY CONTACTS AND PROCEDURES : The CESMP should identify the key emergency contacts
responsible for managing environmental and social emergencies associated with the project and their
contact details. These personnel should have the power to stop and direct works so that they can
manage emergencies effectively. In addition, the plan should establish procedures for managing
environmental emergencies and ensure that those procedures are implemented and maintained.
POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS: The potential impacts section of the CESMP should
include a tabulated summary of any relevant information previously provided in the ESMP, it should
also identify the km marker/chainage of the identified (an any additional) sensitive receptors. Impacts
from relevant stages of the contractor works should be defined in this section and should reflect the
relevant conditions of approval.
MANAGEMENT MEASURES: The CESMP should clearly state how the potential impacts of the works will
be specifically managed based on the content of the ESMP and the measures that the contractor will
undertake to implement these mitigations. The CESMP will propose management measures on the issues
identified and will identify the cost involved and the party responsible for the management measures.
MONITORING PLAN: The CESMP must detail how the CESMP will be monitored and shall include a
weekly monitoring checklist. An example monitoring checklist is provided in Appendix D as a guide.
The monitoring plan will include: what is to be monitored, how it will be monitored, the parameters
(standards) that it will be monitored against, who will monitor, where will be monitored and the cost of
the monitoring plan.
REVIEW: CESMP review: The CESMP should specify the schedule or triggers for reviews of the plan and
identify the party responsible for this.
CESMP PREPARATION AND IMPLEMENTATION : The CESMP must ensure that the person taking the action
takes full responsibility for the content and commitments contained in the plan. The CESMP must be
prepared and implemented by a qualified environmental practitioner with at least 10 years-experience.
Field audits of CESMP implementation must be undertaken on at least a monthly basis by the
Environmental Representative with associated audit reports certified and submitted to the Engineer.
CESMP COMPLIANCE : Identify the internal procedure that the Contractor will follow when a non-
compliance has been identified during the daily monitoring. Procedure will include notification
responsibilities, rectification timeframe and reporting obligations. Procedure will also cover the process
the Contractor will follow when non-compliances are reported by the DSC. Procedure will also identify
how the Contractor will action any disciplinary or training requirements following the non-compliance.
CESMP REVIEW AND AMENDMENT : The CESMP must be reviewed, updated and resubmitted to the
Engineer for approval every six months during the contract period or in response to an anticipated
change of circumstances before any changes are permitted at the work sites. These circumstances include
substantial design changes with environmental or social implications, changes to specific approved plans,
new activities not contemplated in the Project ESMP, or additions to the Project’s area of influence. No
changes will be made to the Project or the project areas until it has either been confirmed by the DSC
that an update to the CESMP is not needed, or the update has been made and approved by the DSC.
The CESMP must also be updated where it is deemed that the mitigation measures are not adequate to
mitigate the environmental and social risks.
CESMP MANAGEMENT SUB-PLANS: The Contractor must provide all sub-plans required in the ESMP as
annexes to the CESMP.
6 ESMP Implementation
6.1 Integration of ESMP into Project Management
This ESMP will be included in the bid document package.
The safeguard requirements of this ESMP will be referenced in appropriate parts of the technical
specifications, Contractors contract and any TORs for supervision or issued under the VCRTP Project.
The PIU Safeguards Specialist will be required to review all bid documents prior to approval.
Prior to commencement of works, the Contractor will be required to attend a half day pre-construction
safeguards workshop with the PIU Safeguards Specialist to ensure that all parties understand their
obligations under the terms of the Contract.
o Sources suitably qualified consultants to develop the safeguard instruments based on the
requirements of the ESMP and the ToR.
o Acts on behalf of the client and works closely with MIPU and all contracted parties to ensure that
VCRTP objectives are delivered in a compliant manner consistent with client, MIPU and DEPC
requirements.
o During the construction phase, PIU receives reporting from the DSC and shares these reports with
the MIPU, DEPC (to comply with permit monitoring requirements) and WB.
o PIU is responsible for managing recurring instances of non-compliance by the contractor as they
are reported by the DSC and all instances of non-compliance by the DSC. PIU will conduct their
own quarterly on-site audit of construction works, to supervise CESMP and ESMP implementation.
International Safeguard Specialist: When required by the project, the ISS provides technical
assistance with project implementation to PIU and the NSS with their safeguard related tasks.
Design and Supervision Consultant (DSC): is responsible for the development of the detailed design
and final bid package for the civil works under VCRTP. The DSC is responsible for:
1. Reviewing the ESMP for any specific instructions relating to the design of the civil works and
capture these requirements in the design.
2. Undertaken additional studies as required by the ESMP and / or ESIA to complete the
environmental and/or social impact assessment and management planning for any identified
gaps in the data or for any new project footprints that may arise during the design process.
3. Updating the ESMP and/or ESIA with the outcomes of the additional studies and any
additional impacts relating to the final designs. Approval of updated ESMP and/or ESIA will
be sought from the WB.
4. Include all required safeguards parameters in the final bid document for the Contractor as
specific in the Standard Bid Document template and this ESMP.
The DSC is also responsible for the day to day supervision of the construction works for the project,
including safeguard compliance. The DSC is the only party who is contractually able to provide
instruction to the Contractor. The DSC will work closely with the Contractor, and the project safeguards
team, on a daily basis to ensure that Santo works are implemented in a compliant manner consistent
with the detailed designs provided and the ESMP. They are responsible for:
1. Daily monitoring the Contractors work for compliance with the CESMP and ESMP and providing
safeguard monitoring results in their monthly reporting to PIU. As part of their CESMP monitoring
responsibilities, the DSC will ensure that a suitably qualified and experience safeguard specialist
is resourced to provide at least quarterly site inspections to Santo and available for support at
other times to respond to incidents, non-compliances, review of CESMP, update of the ESMP and
other tasks.
2. Managing the review process of CESMPs for approval. The DSC must ensure that all current
safeguard instruments have been reviewed internally as well as by PIU, WB and final approval
from WB has been secured before disclosure.
3. Updating the ESMP as necessary to reflect changes in the designs.
4. Working with PIU NSS to provide meaningful input and direction into community consultations on
the draft updated versions of the ESMP.
5. Managing instances of non-compliance by the Contractor and reporting all instances to PIU. They
are also responsible for escalating recurring instances of non-compliance by the Contractor to
PIU for action.
6. Managing and responding to all direct complaints/incidents received by their representatives
as per the GRM process in Section 4.4 and reporting all instances to PIU for inclusion into
statistical database.
7. A template Terms of Reference for a Supervision Safeguard Specialist (SSS) is provided in the
VCRTP ESIA and should be used as a basis the procurement of the SSS within the DSC bid
documents.
ESMP Technical Training PWD & PIU Field Staff. Training to be given by
3,000
NSS in Santo.
ESMP awareness raising and With key Santo stakeholders and communities (one
3,000
sensitisation session for subproject).
Community outreach along School road safety program (using local service
10,000
sealed road sections provider), travel cost, printed materials
7.2 Training
The VCRTP PIU shall undertake training for key stakeholders and project team members to ensure
effective implementation and technical understanding of the ESMP requirements. Key stakeholders will
include PWD staff on Santo, Santo Vanuatu Women’s Centre, VCRTP NSS, DEPC representatives on
Santo.
Areas recommended for training include the following –
• World Bank’s Safeguards Policies, in particular those triggered and relevant to the
Project;
• Project responsibilities to GBV prevention and training;
• Roles and responsibilities of different key agencies in safeguards implementation;
• How to effectively integrate the ESMP into project management, implementation,
monitoring and reporting;
• Management of the GRM;
• How to facilitate meaningful community consultations;
• Monitoring for ESMP compliance;
• Safeguard reporting requirements.
Training in the above areas is recommended to be held within three (3) months of project effectiveness.
8 Contingency Planning
The VCRTP Project Coordinator is the contact person for emergency situations that may arise during
the implementation of the VCRTP works. The VCRTP Project Coordinator will be available 24 hours a
day, seven days a week, and has delegated authority to stop or direct works. In the event of an
environmental emergency, the procedures outlined below are recommended for VCRTP to consider for
implementation.
As part of the EMP in their CESMP, the Contractors are required to provide contingency planning
measures encompassing cyclone and storm events. The purpose of the plan is to ensure all staff are
fully aware of their responsibilities in respect to human safety and environmental risk reduction.
Procedures should clearly delineate the roles and responsibilities of staff; define the functions to be
performed by them, the process to be followed in the performance of these functions including tools
and equipment to be kept in readiness, and an emergency medical plan. All of the Contractor’s staff
should undergo training/induction to the plan.
While it is preferable to undertake construction works outside of the wet season, it is probable that
storm and heavy rain events will occur while works are underway.
The Contractors are responsible for monitoring weather forecasts, inspecting all erosion and sediment
control measures and undertaking any remedial works required prior to the forecast rain or storm
event.
In general, the Contractors will:
• Inspect daily weather patterns to anticipate periods of risk and be prepared to undertake
remedial works on erosion and sediment control measures to suit the climatic conditions.
• Monitor the effectiveness of such measures after storms and incorporate improvements where
possible in accordance with best management practice.
• Ensure appropriate resources are available to deal with the installation of additional controls
as and when needed.
• Inform DSC if there are any concerns associated with the measures in place.
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DETAILED DESIGN/ PRE-CONSTRUCTION MOBILISATION STAGE
General CESMP CESMP and all sub-plans required under the projects supplementary specifications will be Minimal, part Contractor DSC
submitted and approved prior to commencement of works. of usual costs
All required permits (DEPC, DoWR, Quarry Permit) and will be in place and conditions
integrated into CESMP and subplans prior to commencement of works.
Water quality baselines are established as per requirements of the DoWR permit and ESMP
and results integrated into CESMP. It is expected that this will include sites downstream from
the bridges and also at ancillary project sites.
The commencement of road works prior to notifying the Department and PWD Environment
and Social Safeguards Team of your intention to start work is prohibited.
The commencement of road works prior to visiting all communities likely to be affected by the
road works to advise them of the scope of the project is prohibited.
The commencement of road works prior to erecting signs at each end of the project site is
prohibited. Signs must show: name of the project, name and contact details of the community
liaison officer and PWD divisional manager; and, how to make a complaint.
Employees and contractors must be made aware of the importance of environmental
protection and must receive appropriate training prior to commencing work on site.
River Hydrology Design Hydrographic and Geological studies have been completed on the Navaka River as part of Included in DSC PIU
Documents the design process to determine the most appropriate location to site the Navaka Bridge Design TOR
given the vulnerability of constructing a bridge on a dynamic alluvial flood plain.
All bridges will be designed to minimize post-development impacts.
Design of bridges and river crossing will be climate resilient, protect the footings from scour
and respond to the seasonal changes of the river characteristics.
Design of Navaka western landing site will avoid any impacts on the identified ‘taboo’ stone.
2 Costs are estimates only and will be calculated during the detailed engineering design.
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Current scour trends and the rivers behaviour during extreme rainfall events are incorporated
in all relevant design elements.
Where a culvert is placed within a watercourse, the:
a) culvert must be aligned with the channel of the watercourse;
b) opening under the carriageway must be placed as close to the centre of the channel
as practical;
c) invert of the culvert must be placed at or below bed level; and
The use of culverts with the following is prohibited:
For a pipe culvert, a pipe diameter of less than 600mm; and
For a box culvert, a box area of less than 600mm x 600mm.
Natural Habitats EMP Machinery will only in rivers within a set agreed conservative working area along and in the Minimal, part Contractor DSC
river. No machinery works outside these areas. of standard
design
Culvert footings will always be set below the existing riverbed level to ensure unimpeded
process
low flows, fish passage and minimise the occurrence of blockage caused by flood-borne
and/or
debris
already
As part of establishing baseline data, PIU to support the Contractor to derive baseline included in
sedimentation levels downstream from Naoneban and Venaus bridges during both wet and Design TOR
dry conditions. Monitoring will be carried out during construction and after demobilisation.
Road traffic Design Road safety audit conducted to inform designer. Additional DSC PIU
safety Docs cost
Project design will include solutions for pedestrian safety/management on all bridges.
Solutions to include methods of separating pedestrians and traffic on current narrow spans.
Solutions may include provision of separate walkways fixed to existing structures.
Existing roadside furniture that is required to be moved in order to undertake the road works Contractor DSC
TMP must be: Minimal
(requirement
• dismantled with due care to avoid unnecessary damage; and of bidding
documents)
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• reinstated at the location, and in the manner, directed by the construction supervisor;
or
• otherwise replaced.
The bid documents Supplementary Specifications require the Contractor to develop a Traffic
Management Plan (TMP) which will set out how the Contractor will meet the traffic
management requirements of the ESMP and manage traffic including signage and traffic
management around detours, physical works, camp sites, and haulage routes. The
requirements of PWD Specification Clause 1.11 Loading Limit on Public Roads are to be
followed. The TMP shall meet all requirements under 1.8.2 in the PWD Specifications and
1.8, 22.1 of the Supplementary Specifications as well as the project ESMP. ESMP
requirements (incorporating COEP) requirements are:
• For each haul route, the TMP will need to include measure to address: Layout plans; Vehicle
traffic (including any diversions around river crossings); Pedestrian traffic (particularly on
bridges that construction traffic will use); Commercial marine traffic; Sensitive receptors
(management near and consultation with) such as schools, residential dwellings, markets,
churches, etc.); Management of increased heavy load traffic associated with transportation
from the port. The TMP should follow the guidelines set in the Safe Traffic Controls for Road
Works Field Guide (www.works.gov.pg/files/roads-bridges/IF003_PNGFieldGuide.pdf) and
adapted for the VCRTP works.
• Minimized time of diversions or disruptions
• Speed monitoring system will be used
• A Community Liaison Officer be appointed prior to mobilization of machinery to site
and commencement of works.
• Road works must be planned to ensure the least obstruction and inconvenience to
vehicular and pedestrian traffic.
• For road closures of this scope a diversion safe for vehicular and pedestrian traffic
must be established.
• Local Authorities and the police must be informed, in writing 7 days in advance, of
any road works which may cause, or have the potential to cause, any significant
interruptions or changes to normal traffic patterns. This includes any diversions.
• Temporary traffic warning signs must be erected and maintained in advance of any
place on the road where operations interfere with road traffic, and at all
intermediate points where the work crosses or coincides with an existing road.
• Temporary traffic warning signs must be adequately illuminated during the hours of
darkness.
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• Barricades must be erected and maintained in front of all obstructions.
• Temporary detours, approaches, crossings and intersections must be clearly indicated
and delineated by guide markers.
• Temporary detours, approaches, crossings and intersections must be maintained in a
safe and passable condition.
• Reduced speed limits through construction sites must be imposed and signposted.
• When traffic is limited to one operational lane or these are workers or machinery
operating in the road, traffic control measures must include traffic controllers with
“SLOW” and “STOP” signs at both ends of sections of work in progress.
• Pedestrian diversion routes must be clearly marked.
• Road signs must be clearly visible, unobscured by vegetation and have a surface
clean from any excessive dust or dirt.
• Drifts and vented drifts must be marked with permanent guideposts and flood gauges.
• Laden trucks must not exceed 20 km/hour in areas close to schools or along the
pedestrian access routes usually taken by children on their way to school.
Establishing WCP VCRTP PIU will assess the suitability of laydown site proposed by the Contractor and will only Part of Contractor DSC
Laydown and approved sites which are in compliance of ESMP (including COEP standards) and which have minimal contract costs
Stockpile Sites E&S impacts.
Establishment and management of laydown, stockpile and staging areas will be described in
the Work Camp Plan (WCP) within the CESMP.
Laydown and stockpile sites will be located on any available PWD land or quarries
wherever feasible. Sites not on PWD lands or quarries shall be subject to review and
approval by PWD. Sites will not be located inside any Community Conservation Areas.
No runoff from laydown sites, construction works or other project activities will enter any
waterways or CCAs either from direct run off or via discharge into a river.
Short term rental or use of private land for lay down or stockpile sites will follow the process
in 5.2.1 of the ESMP
Sites which have the following activities must be located at least 30m from a watercourse,
mean high water mark or known groundwater source:
• Storage of fuels, lubricants or other hazardous materials
• Refueling of machinery
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• Overnight storage of machinery
• Discharge of waste
• Soakaways for sanitation facilities
Stockpiles (excluding excavated materials for immediate reuse in project site) must be located:
• on clear, even, firm, well-drained ground and in locations where they can be clearly
identified;
• away from drainage lines; and
• at least 30 m from a watercourse or mean high water mark.
Long term or permanent stockpiles must be located at least 100m from the nearest waterway.
All sites must be securely fenced to prevent unauthorised access. Additional fencing may be
required around specific stores (e.g. hazardous substances) to prevent access by
unauthorised personnel.
Secure, well-constructed areas at work sites must be clearly marked for solid waste
collection, machinery maintenance, hazardous substance storage and toilet facilities for
workers.
The laydown site(s) will include hard stand areas which have protection from wind and
(where appropriate) rain, bunding (hazardous substances), clean water diversion drains,
and allow for complete containment, collection and treatment of wastewater from asphalt
and concrete production and machinery maintenance.
The ground of the construction lay down area will likely be compacted by the end of its use
and so restoration will require scarification of the soil, application of topsoil and re-
vegetation.
Land Acquisition / ARAP An updated Abbreviated Resettlement Action Plan has or will been developed for all design Potential PIU WB
Loss of Access to packages. For any parcels of land subject to acquisition, works cannot take place on affected additional
Assets and Land land until an approved ARAP, agreed by the WB, has been fully implemented. compensatio
n costs for
Works at the Navaka River site cannot commence until any legacy issues have been resolved PWD
in accordance with the updated approved ARAP
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Quarry Part of usual
Permit project costs
Rights to extract aggregates from quarries will be established by the Contractor using
process
government processes.
CLP Short term rental of land for lay down or stockpile sites will follow the process in 5.2.1 of the
ESMP.
Influx of Labour / WMTP Contractor will be required to produce a Workers Management and Training Plan (WMTP) Part of Contractor DSC
Worker for the VCRTP works to describe: standard
Management contract costs
• Local and International recruitment strategy
• Worker training program
• Worker Orientation and Induction details
• cultural protocols and expectations
• workers accommodations standards and procedures
The Contractor is required to maximise the number of local workers from the Santo
communities. Preference should be given to a local recruitment process, only relying on
workers from other islands or from overseas for vacancies which cannot be filled locally.
As part of the WMTP, the Contractor will be required to submit a list of roles along with
required qualifications or experience and the planned recruitment strategy for that role (i.e.
local or regional/overseas). The WMTP will adhere to Vanuatu legislation, with particular
respect to the list of reserved occupations, which form part of the Labour (work permits) Act
[CAP 186]. Under the act, the declared list of occupations reserved for ni-Vanuatu include;
typist, clerical supervisor, receptionist, dock worker, freight handler, driver, bus driver, lorry
and van driver, boatswain, carpenter, joiner, general plumber, engineer, assistant accountant,
assistant manager, assistant project manager, carving designer.
The Contractor will be required to provide justification for any roles not filled locally. Work
permits will only be granted for workers with skills unavailable in Vanuatu. Should
international workers be found to be performing jobs that can be done by locals (e.g. driving
vehicles), the DSC will notify the contractor and the GoV who will cancel the work permits.
The contractor will be required to return them home within 48 h of notification by the DSC.
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For recruitment of ni-Vanuatu which cannot be fulfilled by the local community, it is preferred
that it is undertaken through a formal recruitment process which ensures that only people who
are already employed are travelling to the project site. Ad hoc employment of casual labour
is not permitted.
Any project staff who are recruited from overseas are subject to visa approval. As part of
the visa application process, all workers are required to submit a medical report, an element
of which is a HIV test. All oversea workers must complete this test and submit their medical
report to the immigration department before appropriate visas can be issued. As part of the
visa application process all overseas workers will also be required to provide a police
background check from their home country. It is also contractual requirement for all overseas
VCRTP project works to provide VCRTP PIU with police background clearances prior to
arrival in country, regardless of the visa application process.
In accordance with the World Bank’s Standard Procurement Documents (SPDs), Contractors
shall submit a satisfactory code of conduct to address the responsibilities of the individual, the
management and the company towards the ESHS requirements of the Project, the prevention
of GBV and the adherence to OHS requirements of the Project. The required Codes of
Conduct can be found in Appendix E of the VCRTP ESMP.
All Project workers will be required to undertake HIV, GBV and SEA prevention training and
sign the associated Code of Conduct prior to commencement of works.
In addition to the Codes of Conduct for GBV & SEA, the Contractor will also prepare a
Codes of Conduct to describe the expected behaviours of their project worker in relation to
the local communities and their social sensitivities. The Codes of Conduct will contain
obligations on all Contractor’s Personnel (including sub-contractors and day workers) that
contain acceptable measures to address the social impacts of the project.
The Codes of Conduct should be written in plain language and signed by each worker to
indicate that they have:
• received a copy of the code;
• had the code explained to them;
• acknowledged that adherence to this Code of Conduct is a condition of employment;
and
• understood that violations of the Code can result in serious consequences, up to and
including dismissal, or referral to legal authorities.
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A copy of the codes shall be displayed in a location easily accessible to the community and
project affected people. It shall be provided in languages comprehensible to the local
community, Contractor’s Personnel, Employer’s Personnel and affected persons.
Project workers will be housed at predetermined locations at existing PWD sites. Temporary
use of private lands for project ancillary sites will first be approved by PIU and will be
leased following the procedure in section 5.2.1 of the ESMP.
Potential locations for workers accommodations will be identified by the Contractor and
included in their ESMP (CESMP). Sites will be screened for environmental and social impacts
by the Contractor which will be verified by the VCRTP PIU. The PIU will only approve suitable
sites for use by the Contractor which are compliant with the requirements of this ESMP and
have minimal environmental or social impacts.
Worker accommodations, accommodation facilities and management of off duty workers will
follow requirements of the VCRTP ESMP and the IFC Workers Accommodation Standards and
Guidelines
https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sust
ainability-at-ifc/publications/publications_gpn_workersaccommodation
Management of workers within camps is expected to include: including appropriate clothing
and no work on a Sunday or Saturday for LDS Church members, management and restricting
of visitors to the camp, visitor curfews, expected behaviour (noise, alcohol, within community
areas), gift giving and receiving, disciplinary actions, etc.)
Soil erosion Design Drifts, vented drifts and culverts placed within a watercourse must be provided with a scour Minimal DSC PIU
documents apron and cut off wall or equivalent on the downstream side sufficient to prevent bed (part of
erosion. standard
design
A scour apron and cut off wall or must not extend more than 10m upstream or downstream
practices)
of the centre line of the road.
DSC should consider elevating road through areas with high water table which impacts the
drainage and the volume of standing water.
Contractor DSC
EMP
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Wherever possible, road works and associated ancillary sites must be located on previously
cleared areas and vegetation removal and clearance minimised.
Minimize erosion and design erosion protection measures according to international good
practice standards, including incorporation of effective climate resilient drainage systems
(soakage pits) and consideration of surface flow paths.
Sediment curtains and coffers to dams to be used at all sites to minimise sedimentation.
Contingency planning in the EMP must detail soil erosion prevention measures in event of
storm or heavy rain event.
Air Quality WCP Identify and locate waste storage sites, stockpile sites and equipment (e.g. crushing plant) at Minimal Contractor DSC
least 100 m away from any residential settlements, water bodies, streams or rivers, to (part of
minimize impacts on the environment and nearby population. Preference is given to existing standard
PWD Quarry sites. design
practices)
The QMP should include a provision for quarry dust control; all equipment including crushers,
aggregate processors, generators etc. should, if possible, be located in the quarry pit to
QMP
minimize dust emissions.
Ensure all equipment is serviced and issued with warrant of fitness (as required). Any
EMP machinery deemed to be polluting the air must be replaced (or fixed) on instruction by the
DSC and/or the DEPC.
Riverbank and EMP Agree conservative working areas along the rivers and ensure that the areas are clearly Minimal Contractor DSC
Riverbed marked at all times. (part of
Degradation standard
Taboo stone (riverbank cliff) 10m from western bridge abutment on western bank of Navaka design
River is clearly marked on all drawings and fence is constructed prior to commencement of practice)
works to ensure the cliff is protected from Construction related damage at all times.
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Contractor to include replanting of native species along riverbank on completion of work as
part of the CESMP.
Minimize amount of vegetation clearance required for the works.
3 https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainability-at-ifc/policies-standards/ehs-guidelines
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The Contractors will need to ensure adequate supply of water for construction and personnel
which does not adversely affect local community’s water supply.
Sourcing QMP Ensure locally sourced aggregate is sourced under appropriate permit from approved Minimal Contractor DSC
aggregate licensed quarry sources and are operating in accordance with GoV law. Prior to any quarries (part of
material being selected for the VCRTP, public consultation will be completed with any affected parties standard
relating to re-opened quarry sites. design and
construction
Other than necessary excavation for bridge upgrades, aggregates will not be extracted
practices)
from rivers for the project works.
The contractor will be required to produce a Quarry Management Plan as per the
requirements of Quarry Act and the project ESMP and the conditions of permit. The QMP
will use the PWD QMP Template and, at a minimum, include:
i. Consent for access by landowner(s) for PWD.
ii. Site Plan for the quarry (with drawings of how the operation will move within the site and
the depth of the extraction.
iii. An environmental management plan of the site complying with the requirements of the
ESMP including (from COEP):
a. collection of vegetation (grass, shrubs and, where possible, trees) on the site prior
to excavation;
b. stockpiling of collected vegetation;
c. stripping and stockpiling of topsoil; and
d. rehabilitation of the borrow pit or quarry, including the reuse of the collected
vegetation and stockpiled topsoil.
iv. A Rehabilitation Plan.
v. A list of all machinery to be used on site for extraction process.
vi. Health and Safety Plan.
vii.
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The contractor will be required to present specific management plans for the sea and land
transportation of these materials from the origin to the project site, especially the landing
facility. These plans will be approved by the DSC.
It is prohibited to use sand from any beaches on Vanuatu from this project unless approved
by the DSC, follows the environmental requirement of the Quarry Act, detailed in an
approved Quarry Management Plan and approved by the Department of Environmental
Protection and Conservation.
Solid waste WMP Waste Management Plan (WMP) to be developed following requirements of the Minimal Contractor DSC
generation Supplementary Specifications ESMP (which include COEP) and adopting the principles of the (part of
WBG EHS Guidelines Section 1.6 Waste Management 4. The WMP will be included in the standard
CESMP for clearance by the DSC. design and
construction
At all times, the Contractor is responsible for the safe and sound disposal of all solid waste practices)
generated by the Works.
Solid waste includes:
• General waste (i.e. office type waste, household waste (from any workers camps),
lightweight packaging materials).
• Recyclable waste (i.e. certain plastics, metals, rubber etc. that can be recycled).
• Organic biodegradable waste (i.e. waste that will decay / break down in a reasonable
amount of time, such as green waste, food waste).
• Inorganic non-recyclable waste (i.e. waste that cannot decompose / break down and which
cannot be recycled).
• Hazardous waste (i.e. asbestos, waste oil etc.)
• Construction rubble (from demolition of old bridges)
No bulky construction waste will be disposed of on Santo and will instead be exported to a
permitted landfill site which can accommodate the project waste. The Port Vila Municipal
Council should be consulted on their willingness and ability to receive the VCRTP waste at the
Bouffa Landfill.
4 https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainability-at-ifc/policies-standards/ehs-guidelines
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• General waste (including only small quantities of lightweight packaging waste) can
be disposed of at the Luganville landfill, subject to LMC approval. In addition to this
and with the approval of the DSC:
• Organic biodegradable waste may be deposited in designated dumping areas in
reasonable quantities.
• Recyclable waste may be supplied to a local receiver licensed to process such waste.
The WMP shall describe solid waste streams generated by the works and detail the
approved disposal methods along with permissions. At all times, the Contractor is responsible
for solid waste generated by the Works in accordance with the Environmental Health Act.
The WMP should adhere to the GoV Environmental Health Act and follow the requirements in
this ESMP. As a minimum the WMP will make provisions for the following:
• Describe the solid waste streams generated by the works along with estimated
quantities.
• Develop a plan for safe storage and handling of waste stored on the project site as
per the stipulations in this ESMP.
• Identify approved service providers for collection and disposal of waste and
stipulate conditions of carriage.
• Detail the approved disposal methods along with appropriate permissions.
• Confirm with PVMC the process and permissions for using Bouffa Landfill for
handling general project waste and septic waste.
• Contractor shall contact PVMC to determine whether any quantities of the projects
hazardous waste materials generated by the project are suitable to be handled at
the Bouffa Landfill and obtain any permissions necessary.
• Contractor shall seek permission from PVMC to disposal of organic biodegradable
waste in their designated managed area.
• Recyclable waste may be supplied to a local receiver licensed to process such waste.
• Determine the most suitable way to dispose of or reuse demolition waste from bridges.
• Contractor to identify shipping route and licensed disposal facilities for all exported
waste.
• Contractor to identify any export permits or conditions for export of waste.
• Identify those persons responsible for implementing and monitoring the SWMP.
Any waste which cannot be safely and correctly disposed of in Vanuatu is to be disposed of
OFFSHORE in permitted or licensed facilities. It is the Contractor’s responsibility to obtain all
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necessary permissions for transport and safe disposal of hazardous waste from the project
site in a legally designated hazardous waste management site within the country or in
another country, and to ensure compliance with all relevant laws. Evidence will need to be
supplied to the DSC of proper disposal of waste at the final location.
The export of any hazardous waste must be in compliance with the Basel and Waigani
Conventions and any relevant laws enacted by source and the recipient countries.
Disused material may be generated in the form of surplus aggregates or surplus materials
from excavations. Most of the clean fill material can either be used to backfill areas where
old equipment or infrastructure has been removed or as a resource for general use by PWD
and the community. Clean fill materials which are not able to be reused within the timeframe
of the project implementation shall be transported to a location approved by PWD to be
stored for future use by the Ministry. This location shall also be subject to approval by the
DSC.
Unless otherwise instructed by the DSC, other surplus materials not needed during the defects
liability period shall be removed from the site and the country.
Hazardous EMP, CSP Where possible fuel shall be obtained from local commercially available sources. Prior Minimal Contractors DSC
substances and WCP arrangement regarding quantity and type will need to be provided by the contractor. All (part of
fuel to be stored in self-bunded containers mobilisation
and
In all VCRTP project locations, fuel should only be stored in self bunded containers within
construction
designated areas that are designed to store and facilitate operations associated with it (e.g.
planning)
re-fueling).
Spill Response Plan to be developed by Contractor and workers trained. The response plan
should include details on the use of spill kits and absorbent items to prevent spills entering the
receiving sensitive environment (ground, surface water). This spill response plan should be
applicable to all VCRTP project works areas. A spill response plan should be in place for
both the construction phase and operational phase.
Bitumen will be stored at the construction laydown area.
Any empty asphalt or bitumen drums will either be disposed of at Bouffa Landfill on Efate or
will be removed offshore and either returned to supplier or disposed of in a legally
approved facility outside Vanuatu.
Biosecurity EMP The Contractor is to arrange for their vehicles and machinery to be thoroughly cleaned of all Minimal Contractor DSC
contamination prior to shipping (e.g. soil, rocks, plant material, seeds, etc.). Items shipped (part of
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inside containers must also have the inside of the container thoroughly cleaned of all previous mobilisation
cargo residues, including dunnage. and
construction
Obtain import permits and quarantine certification prior to export from country of origin.
planning)
Certificate of fumigation and verification of source (as per national requirements) to be
submitted to Quarantine Inspectors and approved by the DSC prior to delivery to site.
Any machinery or equipment originating outside of Santo and being transported within the
Vanuatu islands to Santo will need to be thoroughly cleaned before its arrival into Santo.
Any imported aggregates being transshipped through Efate will need to be held in a secure
site to act as a ‘quarantine holding area’.
Any locally supplied aggregates from Efate for this project will need to be sourced from an
area which is known to be free of GAS and Rhinoceros Beetle.
All materials or equipment shipped into Santo will, in the first instance, be landed at the Port
in Luganville to allow GoV Biosecurity and Quarantine Officers to inspect the shipments for
invasive pest.
All machinery must be thoroughly cleaned on site prior to demobilisation at the completion of
road works.
Community CLP Contractor will develop a Community Liaison Plan (CLP) as required in the VCRTP Minimal Contractor DSC
grievances Supplementary Specifications setting out the key community and other contacts required for (part of
effective community stakeholder engagement and includes the results of early and interim mobilisation
consultations and proposed meeting schedules with community representatives and and
stakeholders. CLP will set out the rules, restrictions and requirements of surrounding construction
communities regarding the work programme and workforce. The Contractor shall provide a planning)
full time, suitably qualified and experienced Community Liaison Officer (CLO) for the
implementation of the CLP and the projects’ Grievance Redress Mechanism (GRM). The
Contractor’s CLO will be fluent in English and Bislama and will live or have lived in the South
Santo area or have extensive experience working in South Santo at the community level.
Ensure that public consultation and disclosure communication is completed at regular intervals
with full involvement of the CLO to ensure that the public are fully aware of the VCRTP
works. Consultation should include all aspects of the project including the road works site,
quarries and transport routes. Consultation shall include raising awareness of the project
GRM, how to complain and how complaints will be managed.
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Advertise, maintain and operate a grievance response mechanism, including publishing
statistics on resolutions.
Works can only take place on affected land subject to acquisition after an approved WB
updated ARAP, agreed to by the World Bank, has been fully implemented PIU
Local business CLP Ensure that local businesses/roadside vendors and are included in the public consultation and Minimal Contractor DSC
grievances disclosure communication process. Regular communication should be made with affected (part of
parties to ensure that they are fully aware of the proposed program of works and how to mobilisation
complain and how complaints will be managed. and
construction
planning)
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CONSTRUCTION STAGE
River Hydrology EMP The volume of material excavated for the bridge works: Minimal (part Contractor DSC
a) must not exceed 250m3 (unless approved as part of the final design); and of standard
b) must be limited to the minimum area necessary to reasonably carry out the road works. construction
practice)
Where material is excavated from within a watercourse, the excavation must be limited to the area
inside the carriageway. The excavation of material outside the carriageway is prohibited.
Where material is excavated from within a watercourse, any excavated material that is not removed
as waste must be spread evenly within the bed and banks of the watercourse so that it does not
interfere with the flow of water.
5 Costs are estimates only and will be calculated during the detailed engineering design.
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Excavated material or fill placed in the bed of the watercourse must not redirect flow into an adjacent
bank.
Natural watercourse bed controls or features that create natural waterholes (e.g., riffles, logs, sediment
or rock bars) must not be lowered or removed.
Traffic (vehicle and TMP Implement the approved Traffic Management Plan (TMP) to ensure smooth traffic flow and safety for Included in Contractors DSC
pedestrian) and workers, passing vehicles and pedestrian traffic. construction
construction safety Where appropriate, employ flag operators on the road to prevent traffic accidents. The workers shall cost
have relevant safety equipment and training.
Effectively monitor TMP measures on a weekly basis and update TMP where necessary.
Contractor to report on adherence to speed limits and use of haulage routes in monthly reports.
Offloading EMP Machinery and plant will need to be moved from Luganville along the South Santo Road as construction Included in Contractors DSC
equipment at moved. To ensure biosecurity and quarantine processes can be followed, no offloading directly from construction
beaches overseas will take place at these beaches. cost
For any proposed movement of machinery and equipment along the South Santo Road by boat, only
offloading sites previously used by PWD for road maintenance works will be used for VCRTP.
Offloading will be undertaken by ro-ro barge with a shallow enough draught to land at the beach, as
per previous PWD maintenance works on the South Santo Road.
High Quality beach protection mats or locally available stone will be used for forming a roadway on
the beach to provide traction to the vehicles.
All stones or mats added to the beach will be removed at the completion of offloading activities.
Agreed conservative working areas will be set on the beaches to minimize the footprint.
Only existing tracks between the offloading sites and the South Santo Road will be used.
Offloading activities will be detailed in the CESMP for approval.
Soil Erosion and EMP Use of heavy machinery to clear areas prone to erosion is prohibited. Included in Contractors DSC
Sediment Control Earthworks during heavy rainfall or when the ground is waterlogged are prohibited. construction
cost
Where clearing is undertaken you must:
a) clearly mark the areas to be cleared prior to commencing clearing;
b) chip or otherwise process cleared trees etc. for use as mulch on site.
c) progressively clear the site as works progress;
d) strip the topsoil immediately after clearing and stockpile onsite;
e) cover the stockpiles when not in use;
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f) install temporary erosion control measures and runoff/sediment control structures around
cleared areas immediately after clearing;
g) reinstate cleared areas as soon as possible;
h) return cleared topsoil and mulch to approximately the same area of the road it came from;
and
i) mulch batter slopes before planting
j) plant slopes with grasses and other plants suitable for preventing erosion.
Minimise time and size of ground disturbing activities to workable size at any one time. Where clearing
is undertaken you must not:
a) clear outside the marked area;
b) clear beyond 5m of the outer edge of the shoulder; and
c) fell trees etc. into undisturbed vegetation. Trees etc. must be felled into the reserved road
width.
Unless otherwise agreed, stripping of topsoil outside the reserved road width is prohibited.
Stripping of topsoil within the reserved road width must be limited to a depth of 150mm.
Topsoil stripped from within the reserved road width must be salvaged and stockpiled for future use.
Wherever possible, road works and associated ancillary sites must be located on previously cleared
areas.
Ensure sediment traps are in place prior to works commencing. Division bunding or other similar methods
to be used for large areas of vegetation clearance and around excavations.
Keep construction vehicles on defined tracks.
Set agreed conservative working areas around all worksites including on beaches.
Re-vegetate disturbed areas that are not being paved as soon as practicable (loosen ground; apply
topsoil; seed or plant as necessary) in accordance with the decommissioning plan in the EMP.
Stockpiles (excluding excavated materials for immediate reuse in project site) must have temporary
runoff/sediment control structures installed and must be located:
• on clear, even, firm, well-drained ground and in locations where they can be clearly identified;
• away from drainage lines; and
• at least 30 m from a watercourse or mean high water mark.
• A distance of at least 2m must be maintained between stockpiles.
Long term or permanent stockpiles must be located at least 100m from the nearest waterway.
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Vegetation EMP Unless previously agreed and necessary under the final design, clearing mangroves is prohibited and Included in Contractors DSC
Clearance cutting or removing any individual mangrove is prohibited. construction
The Contractor will limit any areas to be cleared to the minimum agreed workable area or new project cost
footprint for realignments.
Vegetation to be removed manually, strictly no use of herbicides/ pesticides.
Extent of permanent vegetation clearance will be described in CESMP and approved by the DSC
Any vegetation (crop trees, important shade trees, boundary marker species, etc.) will be
surveyed and captured in the Inventory of Losses prior to any clearance and appropriate
compensation or avoidance measures will be secured (consultations facilitated by the
National Safeguards Specialists) prior to commencement of works under the updated and
approved ARAP.
Any additional trees that may be required to be removed can only be removed after
agreement of the owner and payment of relevant compensation amount by the Contractor
100m buffer zone established between any laydown or long-term stockpiles around watercourses,
coastline and CCA coastal areas.
Contractors machinery operators to understand boundaries and boundaries to be clearly marked.
Cleared vegetative material to be left by the road for use by communities for fuel wood.
Re-establishment of vegetation line to a functional level at beach, coastline or riverbank will happen
immediately on completion of associated works.
Scoring and revegetation of any compacted soils will be undertaken immediately after completion of
sections of works along road corridor.
Waste disposal WMP Implement approved Waste Management Plan. Included in Contractors DSC
No bulky construction waste is to be disposed of on Santo. construction
cost
Ensure areas for waste collection, recycling and off-site disposal are clearly marked/sign posted.
Segregate waste to avoid cross contamination, such as with contaminated material (hazardous
substance).
Install waste collection facilities at construction lay down area to allow for collection and packing of
waste. Strictly no dumping of rubbish. Include awareness training in general environmental training.
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If access to existing facilities is not available, workers must be provided with a sanitary system to
prevent fouling of surrounding soils. Sanitary system must be of sufficient size for the number of workers
and must take into account the disposal situation at the local landfill.
Clean fill materials which are not able to be reused within the timeframe of the project implementation
shall be transported to a location approved by the MID to be stored for future use by the Ministry.
Unless otherwise instructed by the DSC, other surplus materials not needed during the defects liability
period shall be removed from the site and the country.
Water and soil EMP Storage of machinery within 30m of a watercourse or mean high water mark overnight or when not in Included in Contractors DSC
pollution use is prohibited. construction
Where road works occur within a watercourse, machinery used for the works must not be positioned cost
outside the agreed extent of works within the watercourse.
Natural runoff from undisturbed areas must be diverted around the site prior to site disturbance.
Protect drainage lines likely to be affected by road works with runoff/sediment control structures.
The direct discharge of stormwater from drainage structures, cuttings and embankments is prohibited
unless sediment control structures have been installed on the drainage structures, cuttings and
embankments.
Runoff/sediment control structures must be maintained so that they continue to control sediment loads.
Stormwater discharge from road drainage must not cause:
a. erosion of the banks of a watercourse; or
b. sedimentation of the receiving watercourse.
The following activities are prohibited within 30m from a watercourse, mean high water mark or known
groundwater source:
• Storage of fuels, lubricants or other hazardous materials
• Refueling of machinery
• Overnight storage of machinery
• Discharge of waste
• Soakaways for sanitation facilities
Machinery must be serviced and maintained to a standard that prevents the leakage and spillage of
oil, fuel, lubricants and other contaminants.
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Spill response kits available at all locations where fuel is stored. Spill response plan developed and
training completed for all construction workers.
All project vessels are to be equipped with spill kit including oils booms and absorbent pads. All staff
are to be trained on the use of marine spill kits and kits are to be stored in easily accessible locations
Concrete production should only take place when there is no rain forecast. Sandbags or diversion drains
must be used to divert runoff from concrete cutting or setting areas. Concrete production is to be
equipped with settlement tanks/ponds for treatment of slurry and process water. Treatment shall
include settling of suspended solids and decreasing the pH of the water. Waste concrete should be
allowed to harden before reuse as clean fill. All equipment used in concrete production must be cleaned
in designated wash down areas in the construction laydown area, away from surface water, in a
bunded impermeable area and shall not be allowed to permeate to ground. Wastewater from
concrete cutting, washing equipment or production must be collected and treated (settling and
neutralisation through pH adjustment).
Excavations are bunded to prevent ingress of water runoff and clean water diversion (e.g. sand bags,
clay bund, or shallow trenches) are used to direct overland flow away from active work and storage
areas. Soakage pits should not be installed directly into a shallow aquifer.
Control overland drainage to prevent channeling and sediment transport by diverting flows away from
exposed areas. Sediment laden runoff from excavations or stockpiles must be directed to a settling
area or collected for dust suppression provided the runoff is not contaminated with any chemicals (e.g.
fuel).
Treatment and disposal of all Contractor generated sanitation wastewater is in accordance with DEPC
and approved by DSC. The direct discharge of waste into water is prohibited.
Zones for preliminary accumulation of waste should be designated in areas that will cause no damage
to the vegetation cover or leach into groundwater or surface water (e.g. within construction lay down
area on hard surface).
Discharges of treated wash water are to occur to land only, at least 500m from any bore used for
potable water at a rate not exceeding 20mm/day or the infiltration rate of the ground (i.e. no ponding
or runoff).
A separate washdown area is required for machinery or material with oil or fuel residue and treated
through an oil water separator.
Throughout construction and on completion of works (prior to site handover) ensure drains are cleared
of sediment and detritus build up on a regular basis and after significant rain events.
ESTIMATED
POTENTIAL ADRESSED RESPONSIBLE SUPERVISING
ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES MITIGATION
NEGATIVE IMPACT IN: PARTY PARTY
COSTS5
Air Quality EMP & CLP Building materials and pavement materials must be covered during transport Included in Contractors DSC
Cover or wet down stockpiles containing fine material (e.g. sand and topsoil) when not actively being construction
used. cost
All surfaces should be constructed to their final design solution as quickly as practicable.
Keep work areas clean with regular sweeping.
Aggregate crushing shall only be undertaken with a wet crushing plant or in quarries and shall not
be within 300m of any sensitive receptors.
Dust masks and personnel protective equipment must be available for workers during dust generating
activities (e.g. pavement milling).
Manage speed of transportation trucks on unsealed roads, particularly when passing through
settlements.
Where the road works are in urban areas the site must be watered regularly so that dust is always
suppressed.
The use of hydrocarbons or other hazardous substances for dust suppression is prohibited
Burning of cleared trees, any plastics or other persistent organic pollutant etc. is prohibited.
Noise and vibration ELP & CLP Crushing plant to be located at least 300m away from residences and communities. Plant will be Included in Contractors DSC
disturbances located so within quarries or screened behind bunds and/or landforms to act as a noise barrier. construction
Minimise nuisance from noise, especially closer to residential areas and sensitive receptors, through cost
establishment and communication to affected parties of working hours and avoid increase of noise and
number of work equipment at outside of advertised hours. Advertise working hours at the site entrance.
If possible, use noise barriers / screens or mounds to shield sensitive receptors.
Road works on Sundays or such other times as the community adjacent to the road works requires is
prohibited. However, road works between 1800 and 0700 hours are permitted during business days
where the community adjacent to the road works has agreed in writing.
Regularly check and maintain machinery, equipment and vehicle conditions to ensure appropriate use of
mufflers, etc.
Workers in the vicinity of sources of high noise shall wear necessary protection gear rated for the
situation they are being used.
Signage to outline complaints procedure (GRM) and contact details of recipient of complaints (e.g.
phone number, physical address and email).
ESTIMATED
POTENTIAL ADRESSED RESPONSIBLE SUPERVISING
ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES MITIGATION
NEGATIVE IMPACT IN: PARTY PARTY
COSTS5
The GoV COEP noise standards stall apply. Noise impacts should not exceed 45 dBA at the closest
residential or other sensitive social receptors. The nearest sensitive receptors are expected to change as
the work moves along the roads and will be determined the closest residences to the active works and
to the construction camps and/or crushing plant.
Relevant safety elements such as guardrails, road signs and delineators, pavement markings,
barricades and beams, warning lights shall be installed. In some cases a flag operator or traffic control
supervisor could be engaged around the specific work site.
Consultations with chiefs to inform of community risks and management of the beach areas during
offloading activities.
Contractor to report on adherence to speed limits and use of haulage routes in monthly reports.
DSC PIU
Conduct road safety audit prior to completion of construction to ensure road safety designs properly
implemented.
Physical Cultural EMP Taboo stone (riverbank cliff) 10m from western bridge abutment on western bank of Navaka River is Included in Contractors DSC &PIU
Heritage clearly marked on all drawings and fence is to be constructed prior to commencement of works to construction
ensure the cliff is protected from Construction related damage at all times. cost
Conservative working areas are to be clearly demarked around erected fencing to protect the cliff
from accidental damage.
Toolbox meetings at Navaka River will regularly include protective measures for taboo site.
Chance find of EMP Work to stop in specific location of unearthed artefacts or site. Fence the area to limit access and notify Included in Contractors DSC
objects and loss of VCRTP PIU and DSC immediately for instruction to proceed. construction
archaeological cost
artefacts or sites
Riverbank EMP Excavation of the banks of a watercourse to form access ramps into the watercourse is prohibited. Included in Contractors DSC
Degradation If access ramps into a watercourse are required, they must be pre-approved and formed by ramping construction
excavated river gravel or fill against the bank of the watercourse. cost
ESTIMATED
POTENTIAL ADRESSED RESPONSIBLE SUPERVISING
ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES MITIGATION
NEGATIVE IMPACT IN: PARTY PARTY
COSTS5
The bed and banks of a watercourse disturbed by road works must be returned to a profile similar to
the pre-disturbance condition.
Banks of a watercourse disturbed by road works must be stabilised and revegetated with trees, shrub
and grasses endemic to the area, sufficient to re-establish a riparian environment and protect bed
and banks from erosion.
Landscape EMP Contractor is required to include a Site Decommissioning and Restoration Plan in the EMP. The plan will Included in Contractors DSC
degradation describe all activities with regard to site restoration and landscaping at all project sites including construction
ancillary sites. All camps, machinery, building materials, wastes, diversions and temporary works etc. cost
must be removed from the site and the site restored to a condition in no way inferior to that that existed
prior to the commencement of the project. The plan will be approved by the DSC
Restoration of quarries to be completed in accordance with ESMP and QMP and approved by the
custom owner.
Construction materials will be sourced commercially and use of wood from natural forests will not be
permitted.
Restoration of landscape after completion of rehabilitation works (this will include scoring of compacted
ground); restore the vegetation cover in accordance with the surrounding landscape and any required
design (e.g. grass land or shrubs).
Use plant species characteristic for the landscape in the course of restoration of the vegetation cover.
Photographs will be taken of any laydown and stockpiling sites prior to establishment and provided to
DSC. Photos will be used as a guide during restoration and post-restoration photographs are required
to be submitted to the DSC.
Hazardous CSP Store and handle hazardous substances self-bunded tanks or drums. With the DSC’s permission may Included in Contractors DSC
substances and alternatively be store in bunded, hard stand or designated areas only. Bunded areas to drain to an oil construction
safety and pollution water separator which will need to be constructed or a mobile proprietary unit imported specifically for cost
use on the VCRTP. Bunds to contain 110% of total volume required to be stored or 25% of total volume
if total volume is over 1,000 L.
Provide hazard specific personnel protective equipment to workers directly involved in handling
hazardous substances (e.g. chemical or heat resistant clothing, gloves).
Complete list, including safety data sheets (SDS) for each hazardous substances stored or used shall
always be accessible. All fuels, lubricants, chemicals and hazardous substances must be clearly labelled.
Signage to be posted in storage areas identifying all chemicals present.
ESTIMATED
POTENTIAL ADRESSED RESPONSIBLE SUPERVISING
ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES MITIGATION
NEGATIVE IMPACT IN: PARTY PARTY
COSTS5
Precautions should be in place to prevent wastewater and hazardous substances / materials entering
the environment (e.g. fuel spillage, wastewater containing fire retardant during firefighting), however
should an incident occur, the Contractors spill response plan must be in place. The response plan should
include details on the use of spill kits and absorbent items to prevent spills entering the receiving
sensitive environment (ground, surface water). This spill response plan should be applicable to all VCRTP
project works areas. A spill response plan should be in place for both the construction phase and
operational phase.
Spill kits and training of use to be provided to all workers during toolbox meetings. Spill kits to contain
PPE for the spill clean-up (e.g. appropriate gloves [nitrile] and overalls), material to contain the spill
and absorbent pads, and a heavy duty rubbish bag to collect absorbent pads or material.
Waste oil to be collected and removed abroad to an approved facility (for disposal or cleaning) at
completion of works.
The surfaces of structures and trees adjacent to an area being treated with bitumen must be protected
in such a manner as to prevent their being spattered or marred.
Bitumen spraying during winds over 50km/hr is prohibited.
All fill or materials being replaced must be free from contamination (e.g., weeds, seeds, oils, chemicals
and other contaminants).
Health and safety CSP Fully implement approved Contractor Safety Plan. Included in Contractors DSC
Always have safety officer with suitable qualifications available during construction. construction
cost
Ensure all workers have undergone suitable induction training on OHS with regular training over course
of project.
Prepare site specific safety plans specifying responsibilities and authorities. Health and safety
documentation to include all areas of the project (e.g. quarries and transport routes). Ensure all
occupational health and safety requirements are in place on construction sites and in work camps.
OHS Plan will include Covid-19 infection prevention measures as well as procedures for responding to
instances of infection within the workforce. These will be in line with the most up to date guidance from
WHO and the latest GoV requirements. This will be advised by PWD following the advice in
https://covid19.gov.vu/
First aid training to be provided as required to site workers with basic first aid services to be provided
by Contractor e.g. stretcher, vehicle transport to hospital. First aid kits to be in communal areas or
marked areas in the unlikely event of an incident occurring.
Provide education on basic hygiene practices to minimize spread of diseases including the Covid-19
health measures prescribed by the Ministry of Health at https://covid19.gov.vu/.
ESTIMATED
POTENTIAL ADRESSED RESPONSIBLE SUPERVISING
ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES MITIGATION
NEGATIVE IMPACT IN: PARTY PARTY
COSTS5
Increase workers’ HIV/AIDS and sexually transmitted disease (STD) awareness, including information on
methods of transmission and protection measures.
Prohibit usage of drugs and alcohol on construction sites and undertake regular alcohol testing.
Install lights and cautionary signs in hazardous areas.
Enhance safety and inspection procedures.
Ensure use of PPE and consider providing for on-site storage of workers allocated PPE.
If a worker has been tested positive or have been in contact with a positive COVID-19 case, the worker
will be required to undergo the GoV required quarantine isolation period.
Damage to assets EMP & CLP Maintain high standard of site supervision and vehicle and plant operation to reduce risks of damage Dependent on Contractors DSC & PIU
and infrastructure to water, power and telecommunication lines. asset/
Prepare procedures for rapid notification to the responsible authority (PWD and service providers). infrastructure
and level of
As a result of VCRTP construction activities any damage to assets or infrastructure (including public damage
roads) must be reported to PWD and rectified at the expense of the Contractors.
Aid with reinstatement, in the event of any disruption.
Accidental damage to community assets including crop trees or agricultural will be compensated by the
Contractor under the national valuation guidelines.
Community CLP Implement the CLP. Included in Contractors DSC
engagement and Maintain a grievance response mechanism at the VCRTP PIU. construction
grievances cost
Ensure that public consultation and disclosure communication is completed at regular intervals as
specified in the VCRTP ESIA Stakeholder Engagement and Consultation Plan to ensure that the public
are fully aware of the VCRTP activities and the GRM process. Consultation should include all aspects of
the project including the road works, quarries and transport routes.
Ensure that the piped potable water supply to the tank at Maniao is well maintained, well supplied and
available 24 hours a day.
Contractor will recruit community liaison officer from South Santo to assist in developing relationships
with communities.
VCRTP PIU will be the Contractors key facilitator for all consultations.
Signage should be used in public areas around the VCRTP project sites advising the complaints
procedure and contact details of key project individuals responsible for responding to issues raised.
ESTIMATED
POTENTIAL ADRESSED RESPONSIBLE SUPERVISING
ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES MITIGATION
NEGATIVE IMPACT IN: PARTY PARTY
COSTS5
Local business CLP Ensure that local businesses are included in the public consultation and disclosure communication process Included in Contractors DSC
grievances throughout the construction phase. Regular communication should be made with affected parties to construction
ensure that they are fully aware of the proposed program of works and the GRM. cost
Signage should be used in public areas around the vicinity of works advising the complaints procedure
and contact details of key project individuals responsible for responding to issues raised.
ESTIMATED
POTENTIAL ADRESSED RESPONSIBLE SUPERVISING
ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES MITIGATION
NEGATIVE IMPACT IN: PARTY PARTY
COSTS6
OPERATIONAL STAGE
Road Safety Ongoing program by MIPU to raise awareness of road and pedestrian safety through encouraging Additional to PWD MIPU
safe driving and safe use of roads by pedestrians Project Costs
6 Costs are estimates only and will be calculated during the detailed engineering design.
Version A, June 2022 73
Prepared for Ministry of Infrastructure and Public Utilities, Public Works Department
Vanuatu Climate Resilient Transport Project
Environmental and Social Management Plan: Bridge Improvement Works
South Santo Road
South Santo Road Design Checklist – PRIOR TO APPROVAL OF FINAL DESIGN PACKAGES
Frequency /
Impact Area: Monitoring Parameter:
Responsibility
River Hydrology • Location of bridge over Navaka River is selected based Once prior to
on recommendations of DSC expert reports and approval of final
approved by PIU. design / PWD
• Hydrological modelling demonstrates minimal impact
post development impacts at all bridges.
• Navaka River bridge design allows for the protection of
the taboo stone on the western bank by clearly
demarcating the stone on drawings and by ensuring at
least 10m between the stone and the bridge bank
footings.
• Climate resilience of bridge design incorporates
recommendations from DSC hydrologists findings.
• Footing of culverts are designed to sit lower than the
existing riverbed to allow unimpeded water flow.
Coastal and Riverbank • Gabion cages for riverbanks are designed to minimise Once prior to
Erosion Control impacts on river hydrology. approval of final
• Gabion cages for riverbeds are designed flush with the designs / PWD
existing riverbed.
• No largescale re-contouring of riverbed is required.
General Design • Replacement of Tasiriki Primary School fence included in Once prior to
final design. approval of final
designs / PWD
Soil and water • Contractors EMP contains all soli erosion and
pollution sediment prevention measures stipulated in the
ESMP and DEPC permit.
• Sediment containment measures listed in the ESMP
such as curtains, silt fences, bunding, coffer dams
are in correct places (as described in Contractor
EMP and well-constructed.
Once prior to
• Appropriate spill response plan in place commencement of
• Staff are trained on spill response plan works / DSC
• Overland drainage diverts water flow away from
exposed areas.
• Sediment laden runoff from excavations or
stockpiles directed to a settling area.
• Discharges of treated wash water are to occur to
land.
Occupational Health • Contractor Safety Plan contains all relevant Ongoing prior to
and Safety elements and is approved. commencement of
• All workers have undergone appropriate OHS construction in new
training project sites / DSC
Materials Supply • Quarry Management Plan is compliant with the
ESMP and is approved in the CESMP
• All imported materials have appropriate
biosecurity clearances issued and sighted by DSC
prior to transport to site. Once prior to
• Bio secure transhipment area is established on commencement of
Efate (if relevant). works / DSC
• No materials being sourced from Rhinoceros Beetle
infected areas on Efate (if relevant).
• Materials and equipment sourced internationally
are landed at Luganville Port in the first instance.
South Santo Road Construction Phase Monitoring Plan – THROUGHT CONSTRUCTION PHASE
Impact Area: Frequency /
Monitoring Parameter:
Responsibility
General • Contractor is undertaking weekly monitoring and
reporting using monitoring form approved by PIU
Safeguards Team and DSC in CESMP.
• Community consultation is ongoing as per VCRTP
ESMP
Weekly / DSC
• Contractor CLO is on site and undertaking weekly
engagements with the communities affected by
works. Weekly / PIU
Safeguards Team
• DSC is undertaking daily monitoring and reporting.
• GRM is in use and any complaints being progressed
to resolution.
• Non-compliances are being addressed to DSC
satisfaction in timely manner.
• Waste collection at laydown area is secure, well
signed and clean
• Hazardous waste is stored according to WMP Daily / DSC
• Good housekeeping around project sites and
Solid and hazardous workers accommodation
waste
• Approved Waste Management Plan effectively
implemented
• All hazardous waste is disposed of offshore Weekly / DSC
• Contaminants of Concern (COC) documentation in
place and reviewed
Occupational Health • Workers have access to, and are using appropriate,
and Safety PPE for the task.
• All workers have undergone appropriate OHS
training
• Proper briefing of staff before undertaking work
activities Weekly / DSC
• Contractor is undertaking weekly OHS monitoring
and reporting as described in the approved
Contractor Safety Plan in the CESMP.
• Contractors is reporting serious accidents as per the
requirements of the ESMP
Laydown and • Laydown areas established on pre-approved sites
Stockpiles Site
• Laydown areas dust levels managed efficiently
• Traffic management plan correctly implemented at
laydown site
• Water run off management systems operating
correctly
• Dust management effectively implemented Daily / DSC
• PPE present and correctly used
• Refueling occurring over drip trays in dedicated
areas
• No long term stockpiling within 100m of waterways
• Bunding is functional at stockpile site
Frequency /
Impact Area: Monitoring Parameter:
Responsibility
Drainage system • Drains are clear of debris and functional Monthly and after
storm events /
PWD
DATE: CONTRACTOR:
SUPERVISION
PREPARED BY:
CONSULTANT
DISTRIBUTION LIST:
Compliant, Minor Non-Compliance, Significant Non-Compliance Status: (R) Resolved Issues, (O) Ongoing Issues
Notes:
Required Actions:
Link to: Safe Traffic Controls for Road Works Field Guide
Background
The purpose of these Codes of Conduct and Action Plan for Implementing ESHS and OHS Standards,
and Preventing Gender Based Violence is to introduce a set of key definitions, core Codes of
Conduct, and guidelines for application on World Bank financed transport projects in Pacific Island
Countries (PICs) that:
i. clearly define obligations on all project staff (including sub-contractors and day workers) with
regard to implementing the project’s environmental, social, health and safety (ESHS) and
occupational health and safety (OHS) requirements, and;
ii. help prevent, report and address Gender Based Violence (GBV) within the work site and in its
immediate surrounding communities.
The application of these Codes of Conduct will help ensure the project meets its ESHS and OHS
objectives, as well as preventing and/or mitigating the risks of GBV on the project and in the local
communities.
These Codes of Conduct are to be adopted by all those working on the project—including
subcontractors—and are meant to:
i. create awareness of the ESHS and OHS expectations on the project;
ii. create common awareness about GBV and:
(a) ensure a shared understanding that GBV has no place on the project; and,
(b) create a clear system for identifying, responding to, and sanctioning GBV incidents.
Ensuring that all project staff understand the values of the project, understanding expectations for all
employees, and acknowledging the consequences for violations of these values, will help to create
smoother, more respectful and productive project implementation thereby helping ensure that the
project’s development objectives will be achieved.
Definitions
The following definitions apply:
ESHS and General Project
• Environmental, Social, Health and Safety (ESHS): an umbrella term covering issues
related to the impact of the project on the environment, communities and workers.
• Occupational Health and Safety (OHS): Occupational health and safety is concerned with
protecting the safety, health and welfare of people engaged in work or employment, and the
surrounding communities. The enjoyment of these standards at the highest levels is a basic
human right that should be accessible by each worker.
• Key Documents:
o Codes of Conduct: the Codes of Conduct adopted for the project (or individual
companies) covering the commitment of the company, and the responsibilities of
managers and individuals with regards to ESHS, OHS and GBV.
o Consultant: is as any firm, company, organization or other institution that has been
awarded a contract to provide consulting services to the project, and has hired
managers and/or employees to conduct this work.
o Contractor: is any firm, company, organization or other institution that has been
awarded a contract to conduct infrastructure development works for the project and
has hired managers and/or employees to conduct this work. This also includes sub-
contractors hired to undertake activities on behalf of the contractor.
• Work Site: is the area in which infrastructure development works are being conducted, as
part of the project. Consulting assignments are considered to have the areas in which they are
active as their work sites.
• Work Site Surroundings: is the ‘Project Area of Influence’ which are any area, urban or
rural, directly affected by the project, including all human settlements found in it.
GBV
Key definitions: With reference to the focus areas for in Figure 1, there are a number of key definitions
for understanding GBV:
These Codes of Conduct specifically focus on the following forms of GBV - Sexual Exploitation
and Abuse (SEA) and Sexual Harassment as they represent high risk areas in the context of
investment operations.
• Gender Based Violence (GBV): is an umbrella term for any harmful act that is perpetrated
against a person’s will and that is based on socially ascribed (that is, gender) differences
between male and female individuals. GBV includes acts that inflict physical, mental, or sexual
harm or suffering; threats of such acts; and coercion and other deprivations of liberty, whether
occurring in public or in private life.
• Sexual Exploitation and Abuse (SEA): Sexual exploitation is a facet of GBV that is defined
as any actual or attempted abuse of a position of vulnerability, differential power, or trust for
sexual purposes, including but not limited to, profiting monetarily, socially or politically from
the sexual exploitation of another. In the context of World Bank supported projects, SEA
occurs against a beneficiary or member of the community.
o Child sexual abuse: is defined by the age of the survivor. It includes different forms
of sexual violence, involves either explicit force or coercion or cases in which the
survivor cannot consent because of his or her age. Sexual activity with anyone below
the age of 18, except in cases of pre-existing marriage, constitutes child sexual abuse.
Mistaken belief regarding the age of the child and/or receipt of consent from the child
is not a defense.
• Sexual harassment: occurs between personnel and staff on the project, and involves any
unwelcome sexual advance or unwanted verbal or physical conduct of a sexual nature. (e.g.
looking somebody up and down; kissing; whistling and catcalls; in some instances, giving
personal gifts). The distinction between the SEA and sexual harassment is important so that
agency policies and staff trainings can include specific instruction on the procedures to report
each.
• Child protection (CP): Is an activity or initiative designed to protect children from any form
of harm, particularly arising from child abuse and exploitation.
o Child: is used interchangeably with the term ‘minor’ and refers to a person under the
age of 18. This is in accordance with Article 1 of the United Nations Convention on
the Rights of the Child.
o Child Abuse and Exploitation (CAE): the physical, sexual or psychological harm
of children including using for profit, labour, sexual gratification, or some other
personal or financial advantage. This also includes other activities such as using
computers, mobile phones, or video and digital cameras appropriately, and never to
exploit or harass children or to access child pornography through any mediums
o Grooming: are behaviors that make it easier for a perpetrator to procure a child for
sexual activity. For example, an offender might build a relationship of trust with the
child, and then seek to sexualize that relationship (for example by encouraging
romantic feelings or exposing the child to sexual concepts through pornography).
o Online Grooming: is the act of sending an electronic message to a recipient who the
sender believes to be a minor, with the intention of developing a relationship of trust
that can be abused by procuring the recipient to engage in or submit to sexual activity
with another person, including but not necessarily limited to the sender. This includes
engaging in online sexual activities, such as messages, videos and photos with sexual
content either sent to or procured from a child.
Other definitions: In addressing the issues raised above related to GBV there are a number of
considerations which need to be clearly defined:
• Rape: non-consensual penetration (however slight) of the vagina, anus or mouth with a penis,
other body part, or an object.
• Consent: refers to when an adult makes an informed choice to agree freely and voluntarily to
do something. In accordance with the United Nations Convention on the Rights of the Child,
the World Bank considers that consent cannot be given by children under the age of 18, even
if national legislation of the country into which the CoC is introduced has a lower age.
Mistaken belief regarding the age of the child and consent from the child is not a defense.
There is no consent when agreement is obtained through:
o The use of threats, force or other forms of coercion, abduction, fraud, manipulation,
deception, or misrepresentation,
o The use of a threat to withhold a benefit to which the person is already entitled, or,
• Perpetrator: the person(s) who commit(s) or threaten(s) to commit an act or acts of GBV.
• Survivor/Survivors: the person(s) adversely affected by GBV. Women, men and children
can be survivors of GBV.
• GBV Service Provider: is an independent organization trusted by the local communities with
the skills and resources to provide support to survivors of GBV, as well as training to reduce
the risks of GBV.
o Accountability Measures: are the measures put in place to ensure the confidentiality
of survivors and to hold contractors, consultants and the client responsible for
instituting a fair system of addressing cases of GBV.
o Response Protocol: are the mechanisms set in place to respond to cases of GBV.
o GBV Complaints Team (GCT): a team established by the project to address GBV
issues.
CODES OF CONDUCT
This chapter presents three Codes of Conduct for use:
i. Company Code of Conduct: Commits the company to addressing EHSH, OHS and GBV issues;
ii. Manager’s Code of Conduct: Commits managers to implementing the Company Code of
Conduct, as well as those signed by individuals; and,
iii. Individual Code of Conduct: Code of Conduct for everyone working on the project, including
managers.
appropriate occupational health and safety (OHS) standards are met. The company is also committed
to creating and maintaining an environment where children under the age of 18 will be protected, and
where Sexual Exploitation and Abuse (SEA) and sexual harassment have no place. Improper actions
towards children, SEA and sexual harassment are acts of Gender Based Violence (GBV) and as such
will not be tolerated by any employee, sub-contractors, supplier, associate, or representative of the
company.
Therefore, to ensure that all those engaged in the project are aware of this commitment, the company
commits to the following core principles and minimum standards of behavior that will apply to all
company employees, associates, and representatives, including sub-contractors and suppliers, without
exception:
General
8. The company will ensure that the project’s OHS Management Plan is effectively implemented by
company’s staff, as well as sub-contractors and suppliers.
9. The company will ensure that all persons on-site wear prescribed and appropriate personal
protective equipment, preventing avoidable accidents, and reporting conditions or practices that
pose a safety hazard or threaten the environment.
10. The company will:
i. prohibit the use of alcohol during work activities.
ii. prohibit the use of narcotics or other substances which can impair faculties at all times.
11. The company will ensure that adequate sanitation facilities are available on site and at any worker
accommodations provided to those working on the project.
12. The company will not hire children under the age of 18 for construction work, or allow them on
the work site, due to the hazardous nature of construction sites.
13. Acts of GBV constitute gross misconduct and are therefore grounds for sanctions, which may
include penalties and/or termination of employment and, if appropriate, referral to the Police for
further action.
14. All forms of GBV, are unacceptable, regardless of whether they take place on the work site, the
work site surroundings, at worker’s camps or within the local community.
15. Sexual harassment of work personnel and staff (e.g. making unwelcome sexual advances, requests
for sexual favors, and other verbal or physical conduct of a sexual nature) are acts of GBV and are
prohibited.
16. Sexual favors (e.g. making promises of favorable treatment such as promotions, threats of
unfavorable treatment such as losing a job, payments in kind or in cash dependent on sexual acts)
and any form of humiliating, degrading or exploitative behavior are prohibited.
17. The use of prostitution in any form at any time is strictly prohibited.
18. Sexual contact or activity with children under 18—including through digital media—is prohibited.
Mistaken belief regarding the age of a child is not a defense. Consent from the child is also not a
defense or excuse.
19. Unless there is full consent7 by all parties involved in the sexual act, sexual interactions between
the company’s employees (at any level) and members of the communities surrounding the work
place are prohibited. This includes relationships involving the withholding/promise of actual
provision of benefit (monetary or non-monetary) to community members in exchange for sex
(including prostitution). Such sexual activity is considered “non-consensual” within the scope of
this Code.
20. In addition to company sanctions, legal prosecution of those who commit acts of GBV will be
pursued if appropriate.
21. All employees, including volunteers and sub-contractors are highly encouraged to report suspected
or actual acts of GBV by a fellow worker, whether in the same company or not. Reports must be
made in accordance with project’s GBV Allegation Procedures.
7
Consent: refers to when an adult makes an informed choice to agree freely and voluntarily to do something.
There is no consent when agreement is obtained through the use of threats, force or other forms of coercion,
abduction, fraud, manipulation, deception, or misrepresentation; the use of a threat to withhold a benefit to
which the person is already entitled, or; a promise made to the person to provide a benefit. In accordance with
the United Nations Convention on the Rights of the Child, the World Bank considers that consent cannot be
given by children under the age of 18, even if national legislation of the country into which the Code of Conduct
is introduced has a lower age. Mistaken belief regarding the age of the child and consent from the child is not a
defense.
22. Managers are required to report and act to address suspected or actual acts of GBV as they have a
responsibility to uphold company commitments and hold their direct reports responsible.
Implementation
To ensure that the above principles are implemented effectively the company commits to:
23. Ensuring that all managers sign the project’s ‘Manager’s Code of Conduct’ detailing their
responsibilities for implementing the company’s commitments and enforcing the responsibilities
in the ‘Individual Code of Conduct’.
24. Ensuring that all employees sign the project’s ‘Individual Code of Conduct’ confirming their
agreement to comply with ESHS and OHS standards, and not to engage in activities resulting in
GBV, child endangerment or abuse, or sexual harassment.
25. Displaying the Company and Individual Codes of Conduct prominently and in clear view at
workers’ camps, offices, and in in public areas of the work space. Examples of areas include
waiting, rest and lobby areas of sites, canteen areas and health clinics.
26. Ensuring that posted and distributed copies of the Company and Individual Codes of Conduct are
translated into the appropriate language of use in the work site areas as well as for any international
staff in their native language.
27. Ensuring that an appropriate person is nominated as the company’s ‘Focal Point’ for addressing
GBV issues, including representing the company on the GBV Complaints Team (GCT) which is
comprised of representatives from the client, contractor(s), the supervision consultant, and local
GBV Service Provider.
28. Ensuring that an effective GBV Action Plan is developed in consultation with the GCT which
includes as a minimum:
i. GBV Allegation Procedure to report GBV issues through the project Grievance Redress
Mechanism (Section 4.3 Action Plan);
ii. Accountability Measures to protect confidentiality of all involved (Section 4.4 Action
Plan); and,
iii. Response Protocol applicable to GBV survivors and perpetrators (Section 4.7 Action Plan).
29. Ensuring that the company effectively implements the agreed final GBV Action Plan, providing
feedback to the GCT for improvements and updates as appropriate.
30. Ensuring that all employees attend an induction training course prior to commencing work on site
to ensure they are familiar with the company’s commitments to ESHS and OHS standards, and the
project’s GBV Codes of Conduct.
31. Ensuring that all employees attend a mandatory training course once a month for the duration of
the contract starting from the first induction training prior to commencement of work to reinforce
the understanding of the project’s ESHS and OHS standards and the GBV Code of Conduct.
I do hereby acknowledge that I have read the foregoing Company Code of Conduct, and on behalf of
the company agree to comply with the standards contained therein. I understand my role and
responsibilities to support the project’s OHS and ESHS standards, and to prevent and respond to GBV.
I understand that any action inconsistent with this Company Code of Conduct or failure to act mandated
by this Company Code of Conduct may result in disciplinary action.
Signature: _________________________
Title: _________________________
Date: _________________________
The company is committed to ensuring that the project is implemented in such a way which
minimizes any negative impacts on the local environment, communities, and its workers. This will be
done by respecting the environmental, social, health and safety (ESHS) standards, and ensuring
appropriate occupational health and safety (OHS) standards are met. The company is also committed
to creating and maintaining an environment where children under the age of 18 will be protected, and
where Sexual Exploitation and Abuse (SEA) and sexual harassment have no place. Improper actions
towards children, SEA and sexual harassment are acts of Gender Based Violence (GBV) and as such
will not be tolerated by any employee, sub-contractors, supplier, associate, or representative of the
company.
Managers at all levels have a responsibility to uphold the company’s commitment. Managers need to
support and promote the implementation of the Company Code of Conduct. To that end, managers
must adhere to this Manager’s Code of Conduct and also to sign the Individual Code of Conduct. This
commits them to supporting the implementation of the Contractor’s Environmental and Social
Management Plan (CESMP), the OHS Management Plan, and developing systems that facilitate the
implementation of the GBV Action Plan.
Managers need to maintain a safe workplace, as well as a GBV-free environment at the workplace and
in the local community. Their responsibilities to achieve this include but are not limited to:
Implementation
1. To ensure maximum effectiveness of the Company and Individual Codes of Conduct:
i. Prominently displaying the Company and Individual Codes of Conduct in clear view at
workers’ camps, offices, and in public areas of the work space. Examples of areas include
waiting, rest and lobby areas of sites, canteen areas and health clinics.
ii. Ensuring all posted and distributed copies of the Company and Individual Codes of Conduct
are translated into the appropriate language of use in the work site areas as well as for any
international staff in their native language.
2. Verbally and in writing explain the Company and Individual Codes of Conduct to all staff.
3. Ensure that:
i. All direct reports sign the ‘Individual Code of Conduct’, including acknowledgment that
they have read and agree with the Code of Conduct.
ii. Staff lists and signed copies of the Individual Code of Conduct are provided to the OHS
Manager, the GBV Complaints Team (GCT), and the client.
iii. Participate in training and ensure that staff also participate as outlined below.
iv. Put in place a mechanism for staff to:
(a) report concerns on ESHS or OHS compliance; and,
(b) confidentially report GBV incidents through the Grievance Redress Mechanism
(GRM)
v. Staff are encouraged to report suspected or actual ESHS, OHS, GBV issues, emphasizing
the staff’s responsibility to the Company and the country hosting their employment, and
emphasizing the respect for confidentiality.
4. In compliance with applicable laws and to the best of your abilities, prevent perpetrators of sexual
exploitation and abuse from being hired, re-hired or deployed. Use background and criminal
reference checks for all employees nor ordinarily resident in the country where the works are taking
place.
5. Ensure that when engaging in partnership, sub-contractor, supplier or similar agreements, these
agreements:
i. Incorporate the ESHS, OHS, GBV Codes of Conduct as an attachment.
ii. Include the appropriate language requiring such contracting entities and individuals, and
their employees and volunteers, to comply with the Individual Codes of Conduct.
iii. Expressly state that the failure of those entities or individuals, as appropriate, to ensure
compliance with the ESHS and OHS standards, take preventive measures against GBV, to
investigate allegations thereof, or to take corrective actions when GBV has occurred, shall
not only constitute grounds for sanctions and penalties in accordance with the Individual
Codes of Conduct but also termination of agreements to work on or supply the project.
6. Provide support and resources to the GCT to create and disseminate internal sensitization
initiatives through the awareness-raising strategy under the GBV Action Plan.
7. Ensure that any GBV complaint warranting Police action is reported to the Police, the client and
the World Bank immediately.
8. Report and act in accordance with the agreed response protocol any suspected or actual acts of GBV.
9. Ensure that any major ESHS or OHS incidents are reported to the client and the DSC immediately,
non-major issues in accordance with the agreed reporting protocol.
10. Ensure that children under the age of 18 are not present at the construction site, or engaged in any
hazardous activities.
Training
1. The managers are responsible to:
i. Ensure that the OHS Management Plan is implemented, with suitable training required for
all staff, including sub-contractors and suppliers; and,
ii. Ensure that staff have a suitable understanding of the CESMP and are trained as appropriate
to implement the CESMP requirements.
2. All managers are required to attend an induction manager training course prior to commencing
work on site to ensure that they are familiar with their roles and responsibilities in upholding the
GBV elements of these Codes of Conduct. This training will be separate from the induction training
course required of all employees and will provide managers with the necessary understanding and
technical support needed to begin to develop the GBV Action Plan for addressing GBV issues.
3. Managers are required to attend and assist with the project facilitated monthly training courses for
all employees. Managers will be required to introduce the trainings and announce the self-
evaluations, including collecting satisfaction surveys to evaluate training experiences and provide
advice on improving the effectiveness of training.
4. Ensure that time is provided during work hours and that staff prior to commencing work on site
attend the mandatory project facilitated induction training on:
i. OHS and ESHS; and,
ii. GBV required of all employees.
5. During civil works, ensure that staff attend ongoing OHS and ESHS training, as well as the
monthly mandatory refresher training course required of all employees to on GBV.
Response
1. Managers will be required to take appropriate actions to address any ESHS or OHS incidents.
2. Regarding GBV:
i. Provide input to the GBV Allegation Procedures and Response Protocol developed by the
GCT as part of the final cleared GBV Action Plan.
ii. Once adopted by the Company, managers will uphold the Accountability Measures set forth
in the GBV Action Plan to maintain the confidentiality of all employees who report or
(allegedly) perpetrate incidences of GBV (unless a breach of confidentiality is required to
protect persons or property from serious harm or where required by law).
iii. If a manager develops concerns or suspicions regarding any form of GBV by one of his/her
direct reports, or by an employee working for another contractor on the same work site, s/he
is required to report the case using the GRM.
iv. Once a sanction has been determined, the relevant manager(s) is/are expected to be
personally responsible for ensuring that the measure is effectively enforced, within a
maximum timeframe of 14 days from the date on which the decision to sanction was made
by the GCT.
v. If a Manager has a conflict of interest due to personal or familial relationships with the
survivor and/or perpetrator, he/she must notify the Company and the GCT. The Company
will be required to appoint another manager without a conflict of interest to respond to
complaints.
vi. Ensure that any GBV issue warranting Police action is reported to the Police, the client and
the World Bank immediately
3. Managers failing address ESHS or OHS incidents, or failing to report or comply with the GBV
provisions may be subject to disciplinary measures, to be determined and enacted by the
Company’s CEO, Managing Director or equivalent highest-ranking manager. Those measures may
include:
i. Informal warning.
ii. Formal warning.
iii. Additional Training.
iv. Loss of up to one week's salary.
v. Suspension of employment (without payment of salary), for a minimum period of 1 month
up to a maximum of 6 months.
vi. Termination of employment.
4. Ultimately, failure to effectively respond to ESHS, OHS, and GBV cases on the work site by the
company’s managers or CEO may provide grounds for legal actions by authorities.
I do hereby acknowledge that I have read the foregoing Manager’s Code of Conduct, do agree to
comply with the standards contained therein and understand my roles and responsibilities to prevent
and respond to ESHS, OHS, and GBV requirements. I understand that any action inconsistent with this
Manager’s Code of Conduct or failure to act mandated by this Manager’s Code of Conduct may result
in disciplinary action.
Signature: _________________________
Title: _________________________
Date: _________________________
The Company considers that failure to follow ESHS and OHS standards, or to partake in activities
constituting GBV—be it on the work site, the work site surroundings, at workers’ camps, or the
surrounding communities—constitute acts of gross misconduct and are therefore grounds for
sanctions, penalties or potential termination of employment. Prosecution by the Police of those who
commit GBV may be pursued if appropriate.
• Not engage in sexual favors —for instance, making promises of favorable treatment (e.g.
promotion), threats of unfavorable treatment (e.g. loss of job) or payments in kind or in cash,
dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior.
• Not use prostitution in any form at any time.
• Not participate in sexual contact or activity with children under the age of 18—including
grooming, or contact through digital media. Mistaken belief regarding the age of a child is not a
defense. Consent from the child is also not a defense or excuse.
• Unless there is the full consent8 by all parties involved, I will not have sexual interactions with
members of the surrounding communities. This includes relationships involving the withholding
or promise of actual provision of benefit (monetary or non-monetary) to community members in
exchange for sex (including prostitution). Such sexual activity is considered “non-consensual”
within the scope of this Code.
• Consider reporting through the GRM or to my manager any suspected or actual GBV by a fellow
worker, whether employed by my company or not, or any breaches of this Code of Conduct.
• Bring to the attention of my manager the presence of any children on the construction site or
engaged in hazardous activities.
• Wherever possible, ensure that another adult is present when working in the proximity of
children.
• Not invite unaccompanied children unrelated to my family into my home, unless they are at
immediate risk of injury or in physical danger.
• Not use any computers, mobile phones, video and digital cameras or any other medium to exploit
or harass children or to access child pornography (see also “Use of children's images for work
related purposes” below).
• Refrain from physical punishment or discipline of children.
• Refrain from hiring children for domestic or other labour below the minimum age of 14 unless
national law specifies a higher age, or which places them at significant risk of injury.
• Comply with all relevant local legislation, including labour laws in relation to child labour and
World Bank’s safeguard policies on child labour and minimum age.
• Take appropriate caution when photographing or filming children (See Annex 2 for details).
8
Consent is defined as the informed choice underlying an individual’s free and voluntary intention, acceptance
or agreement to do something. No consent can be found when such acceptance or agreement is obtained using
threats, force or other forms of coercion, abduction, fraud, deception, or misrepresentation. In accordance with
the United Nations Convention on the Rights of the Child, the World Bank considers that consent cannot be
given by children under the age of 18, even if national legislation of the country into which the Code of Conduct
is introduced has a lower age. Mistaken belief regarding the age of the child and consent from the child is not a
defense.
• Before photographing or filming a child, assess and endeavor to comply with local traditions or
restrictions for reproducing personal images.
• Before photographing or filming a child, obtain informed consent from the child and a parent or
guardian of the child. As part of this I must explain how the photograph or film will be used.
• Ensure photographs, films, videos and DVDs present children in a dignified and respectful
manner and not in a vulnerable or submissive manner. Children should be adequately clothed and
not in poses that could be seen as sexually suggestive.
• Ensure images are honest representations of the context and the facts.
• Ensure file labels do not reveal identifying information about a child when sending images
electronically.
Sanctions
I understand that if I breach this Individual Code of Conduct, my employer will take disciplinary
action which could include:
1. Informal warning.
2. Formal warning.
3. Additional Training.
4. Loss of up to one week’s salary.
5. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a
maximum of 6 months.
6. Termination of employment.
7. Report to the Police if warranted.
I understand that it is my responsibility to ensure that the environmental, social, health and safety
standards are met. That I will adhere to the occupational health and safety management plan. That I
will avoid actions or behaviors that could be construed as GBV. Any such actions will be a breach this
Individual Code of Conduct. I do hereby acknowledge that I have read the foregoing Individual Code
of Conduct, do agree to comply with the standards contained therein and understand my roles and
responsibilities to prevent and respond to ESHS, OHS, GBV issues. I understand that any action
inconsistent with this Individual Code of Conduct or failure to act mandated by this Individual Code of
Conduct may result in disciplinary action and may affect my ongoing employment.
Signature: _________________________
Title: _________________________
Date: _________________________
It will be the duty of the GCT with support from the management of the contractor(s) and
consultant(s) to inform workers about the activities and responsibilities of the GCT. To effectively
serve on the GCT, members must undergo training by the GBV Service Provider prior to the
commencement of their assignment to ensure that they are sensitized on GBV.
9
Where there are multiple contractors working on the project, each shall nominate a representative as
appropriate.
The GCT shall hold quarterly update meetings to discuss ways to strengthen resources and GBV
support for employees and community members.
GRM
The project operates a GRM which is managed by a designated GRM operator with the project
management unit or, ideally, an entity independent of the project implementation. The GRM must be
designed to ensure that:
i. Complaints can be made through different channels, such as the traditional local practices
(e.g. village chiefs), online, phone, in-person, the local GBV Service Provider, the
manager(s), or the Police.
ii. Complaints should be able to be made in different ways such as online, via telephone or
mail, or in person;
iii. Anonymity should be ensured if the complainant so desires it, especially about GBV;
There needs to be a specific workflow for handling GBV complaints. The figure below illustrates the
work flow adopted in 2017 for the Vanuatu Aviation Investment Project (VAIP).
If the complaint to the GRM is made by an GBV survivor, or on behalf of a survivor, the complainant
will be directly referred to the GBV Service Provider to receive support services (if so desired) while
the GCT investigates the complaint in parallel.
The World Bank requires that all complaints regarding GBV must immediately be reported to the
World Bank task team by the GRM operator. These complaints may be referred to the World Bank
management in accordance with the World Bank’s reporting protocols.
The GRM shall only collect two items of data related to GBV—to be inferred from discussions with
the complainant:
Additional information shall be gathered by the GBV Service Provider using their existing survivor
support protocols. This information shall be confidential and not part of the GRM process.
The GRM operator will refer complaints related to GBV to the GCT to resolve them. In accordance
with the GBV Action Plan, the GCT through the GBV Service Provider and Focal Point(s) will
investigate the complaint and ultimately provide the GRM operator with a resolution to the complaint,
or the Police if appropriate. The victim’s confidentiality should also be kept in mind when reporting
any incidences to the Police.
The GRM operator will, upon resolution, advise the complainant of the outcome, unless it was made
anonymously.
The GBV Service Provider is a local organization which has the trust of the local community,
experience and ability to support survivors of GBV. They will be identified by the client during
project preparation, if necessary with the support of the World Bank.
The client, the contractor(s) and consultant(s) must establish a working relationship with the GBV
Service Provider, so that GBV cases can safely be referred to them. The GBV Service Provider will
also provide support and guidance to the GBV Focal Points as necessary. The GBV Service Provider
will have a representative on the GCT and be involved in resolving complaints related to GBV.
The contract for the GBV Service Provider shall include provision for financing costs around
providing the necessary support to survivors.
All the Focal Points on the GCT must be trained and empowered to resolve GBV issues. It is essential
that all staff of the GRM and GCT understand the guiding principles and ethical requirement of
dealing with survivors of GBV. All reports should be kept confidential and referred immediately to
the GBV Service Provider represented on the GCT10.
The GCT shall confirm that all complaints related to GBV have been: (i) referred to the client and the
World Bank by the GRM operator; and, (ii) are referred to Police (or other authorities) for
investigation if of appropriate severity. In GBV cases warranting Police action; and, (iii) management
for further action.
The GCT shall consider all GBV complaints and agree on a plan for resolution. The appropriate Focal
Point will be tasked with implementing the plan (i.e. issues with contractor’s staff will be for the
contractor to resolve; consultant’s staff the consultant; and client’s staff the client). The Focal Point
will advise the GCT on resolution, including referral to the Police if necessary. They will be assisted
by the GBV Service Provider as appropriate.
ACCOUNTABILITY MEASURES
All reports of GBV shall be handled in a confidential manner to protect the rights of all involved. The
10
Survivors of GBV may need access to Police, justice, health, psychosocial, safe shelter and livelihood
services to begin on a path of healing from their experience of violence.
client, contractor and consultant must maintain the confidentiality of employees who notify any acts
or threats of violence, and of any employees accused of engaging in any acts or threats of violence
(unless a breach of confidentiality is required to protect persons or property from serious harm or
where required by law). The contractor and consultant must prohibit discrimination or adverse action
against an employee because of survivor’s disclosure, experience or perceived experience of GBV
(see Annex 1 for examples of actions to maintain accountability).
To ensure that survivors feel confident to disclose their experience of GBV, they can report cases of
GBV through multiple channels such as: (i) online, (ii) phone, (iii) in-person, (iv) the local GBV
Service Provider, (v) the manager(s), (vi) village councils; or, (vii) the Police. To ensure
confidentiality, only the GBV Service Provider will be privy to information regarding the survivor.
The GCT will be the primary point of contact for information and follow up regarding the perpetrator.
RESPONSE PROTOCOL
The GCT will be responsible for developing a written response11 protocol to meet the project
requirements, in accordance to national laws and protocols. The response protocol must include:
i. Mechanisms to notify and respond to perpetrators in the workplace;
ii. The GRM process to ensure competent and confidential response to disclosures of GBV,
and;
iii. A referral pathway to refer survivors to appropriate services (See 4.8 Survivor Support
11
Develop appropriate protocol for written recording of GBV issues raised in case the notes are subpoenaed. Develop processes for record
keeping including activities undertaken by the GCT.
Measures below).
The contractor(s), consultant(s) and client shall encourage notification through the GRM channels
from employees and community members about perpetrators in the workplace through awareness
raising activities. An employee who discloses a case of sexual harassment in the workplace shall be
referred to the GRM for reporting to seek services.
Through the GCT, the companies and client shall oversee the investigation of these grievances,
ensuring procedural fairness for the accused, and within the local laws. If an employee has breached
the Code of Conduct, the employer will take appropriate action which could include:
Any survivor will receive care regardless of whether the perpetrator is associated with the project will
receive support/ The support will be provided by the GBV Service Provider—including medical and
psychosocial support, emergency accommodation, transport fees necessary to receive services,
security including Police protection and livelihood support—by facilitating contact and coordination
with these services. See Annex 1 for examples of the types of support which could be considered
under the project.
The contract with the GBV Service Provider shall explicitly detail the services to be provided, and
how the associated costs shall be financed by the project.
If the survivor is an employee of the contractor(s), consultant(s) or client, to ensure the safety of the
survivor, and the workplace in general, the client, contractor or consultant, in consultation with the
survivor, will assess the risk of ongoing abuse to the survivor and in the workplace. Reasonable
adjustments will be made to the survivor’s work schedule and work environment as deemed necessary
(see Annex 1 for examples of safety measures). The employer will provide adequate leave to
survivors seeking services after experiencing violence (see Annex 1 for details).
SANCTIONS
In accordance with the Code of Conduct, any employee confirmed as a GBV perpetrator shall be
considered for disciplinary measures in line with sanctions and practices as agreed in the Individual
Code of Conduct. Potential Sanctions to employees who are perpetrators of GBV include:
i. Informal warning
ii. Formal warning
iii. Additional Training
iv. Loss of up to one week’s salary.
v. Suspension of employment (without payment of salary), for a minimum period of 1
month up to a maximum of 6 months.
vi. Termination of employment.
vii. Referral to the Police or other authorities as warranted.
It is important to note that, for each case, disciplinary sanctions are intended to be part of a process
that is entirely internal to the employer, is placed under the full control and responsibility of its
managers, and is conducted in accordance with the applicable national labour legislation.
Such process is expected to be fully independent from any official investigation that competent
authorities (e.g. Police) may decide to conduct in relationship to the same case, and in accordance
with the applicable national law. Similarly, internal disciplinary measures that the employer’s
managers may decide to enact are meant to be separate from any charges or sanctions that the official
investigation may result into (e.g. monetary fines, detention etc.).
1. Inform all employees that confidentiality of GBV survivors’ personal information is of utmost
importance.
2. Provide the GCT with training on empathetic and non-judgmental listening.
3. Take disciplinary action, including and up to dismissal, against those who breach survivor’s
confidentiality (this is unless a breach of confidentiality is necessary to protect the survivor or
another person from serious harm, or where required by law).
Based on the rights, needs and wishes of the survivor, survivor support measures to ensure the
safety of the survivor who is an employee can include12:
1. Changing the perpetrator or survivor’s span of hours or pattern of hours and/or shift patterns.
2. Redesigning or changing the perpetrator or survivor’s duties.
3. Changing the survivor’s telephone number or email address to avoid harassing contact.
4. Relocating the survivor or perpetrator to another work site/ alternative premises.
5. Providing safe transportation to and from work for a specified period.
6. Supporting the survivor to apply for an Interim Protection Order or referring them to appropriate
support.
7. Taking any other appropriate measures including those available under existing provisions for
12It is critical that a survivor centered approach be adopted. The survivor should be fully involved in the
decision making. Except for exceptional circumstances the perpetrator should be required to take appropriate
actions to accommodate the survivor (e.g. move, change hours, etc.), rather than the survivor changing.
1. An employee experiencing sexual harassment should be able to request paid special leave to attend
medical or psychosocial appointments, legal proceedings, and relocation to safe accommodation
among other services that may be needed.
2. An employee who supports a person experiencing sexual harassment may take care givers leave,
including but not limited to accompanying them to court or hospital, or to take care of children.
3. Employees who are employed in a casual capacity may request unpaid special leave or unpaid care
givers leave to undertake the activities described above.
4. The amount of leave provided will be determine by the individual’s situation through consultations
with the employee, the management and the GCT where appropriate.
1. Informal warning
2. Formal warning
3. Termination of employment.
November 2021
NOVEMBER 2021
Financed by:
Notice
This manual was produced for the Director General of the Ministry of
Infrastructure and Public Utilities of Vanuatu (MIPU) for the Vanuatu
Climate Resilient Transport Project. It has been adapted from the GRM
for the Vanuatu Infrastructure Reconstruction and Improvement Project .
Document History
Purpose /
Rev Originated Checked Reviewed Authorised Date
Description
Carol Iain
1 Initial Draft Craig
Dover Haggarty
Clark
Carol
2 2nd Draft Craig
Dover
Clark
4
Contents
1. Introduction .......................................................................................................................................................... 1
2. GRM Principles ...................................................................................................................................................... 1
3 GRM Implementation ........................................................................................................................................... 3
4 Grievance Process ................................................................................................................................................. 7
5 Institutional Arrangements ................................................................................................................................. 11
6 Awareness raising .............................................................................................................................................. 12
7 Conclusion and Application of the GRM ............................................................................................................. 12
Annex A. Complaint Form ........................................................................................................................................... 13
Abbreviations
An initial GRM outline was presented in the VCRTP Environmental and Social Impact Assessment (ESIA).
That GRMoutline has been revised and expanded so it can be released as a standalone document that
covers both complaints and grievances under VCRTP for easier use and reference. A copy of this GRM
will be containedin the Annexes of the VCRTP safeguards documents; the Abbreviated Resettlement
Action Plan (ARAP) and the Environmental and Social Management Plan (ESMP). This standalone GRM
document will be updated as needed during project implementation. .
The GRM outlines a process for documenting and addressing project grievances and complaints that
may be raised by affected persons or community members regarding any aspects of the project,
including specific project activities, environmental and social performance, the engagement process,
and/or unanticipated environmental or social impactsresulting from project activities. It describes the
scope and procedural steps and specifies roles and responsibilities of the parties involved. The GRM is
subject to revision based on experience and feedback from stakeholders.
2. GRM Principles
A Grievance Redress Mechanism (GRM) is proposed to address any complaints and grievances arising
during the course of designing and implementing the project. Members of the public may perceive
risks to themselves or their property or have concerns about the environmental or social performance
of the project. Any concerns or grievances should be addressed quickly and transparently, and without
retribution to the affected person (AP) or complainant.
1
GRM Objectives
1. Establish a prompt, easy to understand, consistent and respectful mechanism to support the
receiving, investigating and responding to complaints or grievances from community stakeholders;
2. Ensure proper documentation of complaints or grievances and any corrective actions taken;
3. Contribute to continuous improvement in performance of VCRTP through the analysis of
trends and lessons learned.
GRM Definitions
An affected person (AP) is a person that is adversely affected temporarily or permanently as a result
of project-related activity under VCRTP
Vulnerable groups are people who by virtue of gender, age, physical or mental disability, economic
disadvantage, or social status may be more adversely affected than others and who may be limited in
their ability to raise a complaint or grievance. They may require additional support.
A complaint is a statement (verbal or written) of displeasure that an impact or effect arising from the
project is unsatisfactory or unacceptable to the complainant. For the purposes of this GRM, a
complaint is a concern about an impact or effect that is low in risk and typically does not require an
investigation but does require a specific response to remove or resolve the unsatisfactory or
unacceptable impact or effect. Unresolved complaints may become grievances if not dealt with
appropriately and within a short timeframe (typically 2 days but a maximum of 14 days). Complaints
able to be dealt with or resolved immediately can be referred to as minor complaints.
A grievance is a statement about an action, impact or effect arising from the project that adversely
affect the rights, health, property and/or well-being of an affected person or people to the extent that
it forms legitimate grounds for grievance and if upheld, may result in compensation, legal action or a
change to the project in order to resolve the grievance. For the purposes of this GRM, a grievance will
require specific response and potentially a formal intervention by the supervision consultant or the
client (represented by the PWD Division Manager, Santo) for resolution. .Such resolution must be
formally agreed and recorded. Grievances may be raised verbally or in writing but must be reported
using the Complaint Form (Annex A).
2
3 . Overview of the GRM Implementation
For all complaints and grievances associated with the project the following mechanisms will be used.
All complaints about the project will be dealt with as presented within this VCRTP GRM and should be
recorded even if resolved immediately. For most complaints, if immediate resolution is achieved and
the complainant is satisfied, the matter will be recorded in the Contractors site diary and reported in
the Contractors regular monthly report and considered closed. If the complaint cannot be resolved
immediately a Complaint Form (Annex A) will be completed and forwarded to the PIU Community
Liaison Office (CLO) who will log the details into the ‘Grievance and Complaints Logging System’ (GCLS)
database for tracking and reporting on resolution.
Complaints that cannot be resolved after 14 days become a grievance. The CLO PIU will update the
GCLS database accordingly and refer the matter to the PWD Division Manager who will investigate. The
PWD Division Manager may seek the support of the Project Support Team (PST), Supervision Consultant
(SC) or Contractor’s Community Liaison Officer (CCLO) to assist with the investigation. In accordance with
the World Bank’s ‘Citizen Engagement’ commitments under IDA 17, key indicators from the GRM are
published online at the VCRTP project website. [Include website address here once available].
The VCRTP Project Implementation Unit (PIU) Community Liaison Officer (CLO) will manage the overall
GRM, utilizing formal, informal and traditional grievance procedures suitable to the Vanuatu context.
Generally, complaints and grievances will be resolved at the community level as much as possible
under the management of the Contractors Community Liaison Officer (CCLO) and the Supervision
Consultant (SC). Assistance will be provided by the Public Works Department (PWD) through the CLO.
In the event of complaints or disputes to do with school grounds, the School Principal, staff and/or
community member(s) may be involved.
Where a complaint is unresolved it becomes a grievance and may be firstly referred to customary
conflict mediation arrangements where appropriate,with the assistance of the Area Chief, so long as
the Chief is not directly affiliated with those who are party to the grievance. If the issue cannot be
resolved at this level, it will be raised to the next level.
Regular community representative meetings will be held for all VCRTP project and sub-project
activities. These meetings will include consideration of all aspects of the project and include
discussions on nuisance, review of complaints and confirmation that all complaints have been
resolved. Issues that cannot be resolved by changes to work practices or simple on-site solutions will
be referred to the PIU CLO for resolution.
Results of complaints and records and minutes of community representative meetings will be reviewed
regularly by the PIU to identify opportunities to reduce negative impacts of project activities.
The GRM aims to address all complaints received, regardless of whether they arise from real or
perceived issues. Any stakeholder (man or woman) who considers themselves affected by the project
will have access to this procedure at no cost or threat of any negative repercussions. The statutory
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rights of the Complainant to undertake legal proceedings remain unaffected by participation in this
process.
Gender Based Violence Compliance Team (GCT): The structure of the GRM will include a Gender Based
Violence Compliance Team (GCT). The GCT will include: the PIU Community Liaison Officer (CLO), the
Contractors Community Liaison Officer (CCLO), the Supervision Consultant (SC) representative, the
South Santo Area Administrator, Vanuatu Women’s Centre SANMA branch and/or a representative
from the Department of Women’s Affairs and a representative from the Vanuatu Disability Promotion
and Advocacy Association. Gender based violence, sexual assault and/or exploitation issues may also
require the involvement of the Family Protection Unit of the Police. Discretion will be employed and
the complainants rights to privacy and confidentiality will be respected.
WB Level Resolution: In addition to the above project level GRM, communities and individuals who
believe that they are adversely affected by a WB supported project may submit complaints to the
WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly
reviewed to address project-related concerns.
Project affected communities and persons may submit their complaint to the WB’s independent
Inspection Panel which determines whether harm occurred, or could occur, as a result of WB
noncompliance with its policies and procedures. Complaints may be submitted at any time after
concerns have been brought directly to the WB’s attention, and WB Management has been given an
opportunity to respond.
For information on how to submit complaints to the World Bank’s corporate GRS, please visit
http://www.worldbank.org/GRS . For information on how to submit complaints to the World Bank
Inspection Panel, please visit www.inspectionpanel.org .
Complaints
Complaints arising during construction are expected to be minor complaints concerning traffic, dust
or noise that should be able to be resolved quite easily. Ideally, all complaints should be directed to
the Contractors Community Liaison Officer (CCLO). However, in practice, complaints can be made to
anyone involved in VCRTP or perceived to be in authority including Provincial or Local Authorities,
PWD Officers or the Supervision Consultant (SC) or Project Support Team (PST). Irrespective of the
initial receiver of the complaint, the following will happen for Contractor related complaints:
• All complaints will be communicated to and registered by the Contractor, in their site diary,
immediately upon receipt. Details recorded will include; date and time, name and contact details
of the Complainant, nature of the complaint, attempts to resolve the complaint, the resolution of
the complaint and outcome.
• The site diary will be made available for inspection by any authorised representatives of MIPU,
including the Supervision Consultant, PIU CLO, members of the PST and PIU.
• If immediate resolution is achieved and the Complainant is satisfied, the matter will be recorded
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in the site diary and reported in the regular monthly report and considered closed.
• If unresolved, the Contractor will provide a completed complaint form to the PIU CLO within 1
day of receiving the complaint. The PIU CLO will enter the complaint into the Grievance and
Complaints Logging System (GCLS) database for tracking and reporting on resolution. The
database will reflect who is tasked with following up with the Complainant and by when.
• The SC or PIU CLO or others may also assist the Contractor in resolving a complaint.
• The Contractor will have a maximum of 14 days to resolve the complaint and convey a decision
to the Complainant. The complaint can be heard and at the relevant local nakamal and decisions
on a resolution agreed. Once resolved, the resolution should be entered accordingly into the site
diary and both the SC and PIU CLO informed of the outcome. The PIU CLO will update the matter
as resolved in the GCLS. The details of the resolution will be included in the next Contractor’s
monthly report.
• Should the Contractor or the Complainant not be satisfied with the proposed resolution or any
aspect of communication around the issue, the matter will then be passed to the PWD Divisional
Manager for resolution it must be recorded in the GCLS as a grievance and the procedure for
grievance redress be followed.
Grievances
• All grievances must be referred to the PIU CLO using the Complaint Form (refer Annex A).
• When a grievance is reported, the PIU CLO will refer the matter to the PWD Division Manager who
will investigate the matter. The SC, PST and/or the CCLO may all be tasked by PWD to support the
investigation and achieve resolution.
• Any grievance involving project personnel accused of gender based violence, sexual abuse and/or
exploitation will involve the GBV Compliance Team (GCT) for the purpose of investigation and
resolution. The GCT will be contacted within 2 days for a meeting to be held within 7 days.
• The GRM process, responsibilities and timeframes are set out in Section 4 Grievance Process.
Important Notes
• Vulnerable groups: Complaints and grievances from affected women, children, persons living with
a disability, elderly or other vulnerable groups in the community, may be raised by a
representative and may require a meeting of the GBV Compliance Team (GCT). The PIU CLO will
be responsible for coordinating meetings of the GCT.
• Concerns, complaints and grievances to do with the Contractor’s activities within school grounds
shall be raised by the School Principal, staff and/or community member and dealt with in the same
manner as a community complaint or grievance.
• Should a dispute arise that cannot be resolved and is serious enough to prevent the project works
taking place, then the Contractor will be instructed to stop work on that element of the contract
until the matter is resolved. This resolution may include handling through legal processes.
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Community Consultation
The Contractor, supported by PWD, the PIU and the SC, will regularly update project stakeholders
(including community representatives) with details of planned project works and timeframes.
Consultation will disclose the key social safeguards documents; the Abbreviated Resettlement Action
Plan (ARAP), the GRM and the Environmental and Social Management Plan (ESMP). The ESMP presents
a set of mitigation measures that must be followed by the Contractor. Any breaches of the ESMP
conditions will also be entered into the site diary and the resolution of the breach will be recorded.
Community Consultation topics to be discussed will include but not be limited to:
Community consultation will seek agreement on the above and will also identify and nominate the
community representatives who are authorised to speak on behalf of the community members. Table
1 provides a list of key communities for ongoing consultation and information disclosure.
Regular meetings will take place between the Contractor, PWD, PIU, SC and community
representatives. The purpose of these meetings is to confirm that all minor complaints have been
resolved and to identify and, if possible, resolve any ongoing complaints or grievances.
The GRM does not deal with grievances relating to internal communication or disputes between the
project team, Implementing Agency, other agencies; nor intra/inter-community conflicts that are not
project-related.
GRM Process will be a key topic at community consultations so that potential Complainants
understand how to access the GRM. It is important that the GRM process is disclosed during
community consultation and explained in detail to potentially impacted parties. Key details to be
explained include:
4 . Grievance Process
The grievance resolution process includes four key stages – (i) Receive; (ii) Investigate/Enquire; (iii)
Respond and Resolve; and (iv) Follow up/Close Out.
The intention is to resolve complaints as quickly as possible so that they do not become a grievance.
(i) Receive
The first point of contact for all complaints (potential grievances) from community members is usually
the CCLO or SC as they are most often on-site. The PIU CLO will also be prepared to receive complaints
and will man the VCRTP Help Line phone. Avenues will include: face to face, by telephone, in writing
or via email.
A complaint can be raised by the Complainant or through their representative, for example local chief,
Church leader or community women’s rep. For matters relating to school operations or on school
grounds, the School Principal or staff or community member.
If a complaint cannot resolved immediately, the details must be formally recorded on a Complaint
Form (Annex A). The SC, PIU CLO and CCLO must be informed and a copy of the Complaint Form must
immediately be sent to the PIU CLO for entry into the GCLS database. The GCLS database will reflect
7
who is tasked with following up with the Complainant and by what date. Complaints will be
acknowledged within two days by a response to the Complainant confirming that the grievance has
been received and is under investigation.
If the GBV Compliance Team is to be involved, the team members will be contacted within 2 days for
a meeting to be held within 7 days. The meeting will determine how best to proceed with the issue.
The Contractor may request that a Community Representatives meeting to assist investigations and
confirm details of the grievance.
Investigations may include site visits to determine the scale and impact of the grievance and what
options there may be for appropriate responses or resolutions.
If the Complainant is NOT satisfied the matter is considered a grievance and will escalate to the PWD
Divisional Manager for review and a final decision. The severity of each grievance and subsequent course
of action shall be determined by the PWD Division Manager. If the issue is easily resolvable, (for example a
grievance covered under the compensation mechanisms under the ARAP), the responsible parties should
endeavour to address the issue directly on site. If the grievance is a more complex issue, it may require
additional meetings and further investigation. PWD Division Manager will seek to confirm a resolution with
the Complainant (or their representative) within 1 week of investigation.
If the Complainant is still dissatisfied with the outcome, they may be referred to the legal process or use the
WB Grievance Redress System, which is available at any stage to the Complainant. However, courts should
be the last avenue for addressing grievances.
If a grievance is dismissed as groundless; the Complainant will be informed of their rights in taking it
to the next level. A copy of the decision is to be given to the Complainant in writing and the outcome
recorded in the GCLS Database. A copy of the decision will be shared with the PWD Deputy Director.
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closed out within the initial 30 days or as soon as possible thereafter and after all reasonable attempts
to resolve the grievance have been attempted.
The response should communicate findings of the investigation and the resolution and seek approval
from the Complainant. If the Complainant is satisfied with the outcome then the grievance is closed
out and they provide their signature (or fingerprint) on the agreement as confirmation. The status will
be recorded in the GCLS database as follows
• Resolved – a solution has been agreed and implemented and signed documentation is
evidence of this.
• Unresolved – it has not been possible to reach an agreed solution within the GRM and the
case has been elevated to the WB Grievance Redress System or the Courts.
• Abandoned – cases where the attempts to contact the Complainant have not been successful
for two months following receipt of formal grievance.
All grievances will be reviewed for opportunities to help identify and reduce future, similar
occurrences across VCRTP subprojects.
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Table 2: Grievance Process Timeframes
Timeframe Actions
Complaint received • Immediate resolution – Record in Contractors Site Diary and Monthly Report
• Not resolved – Contractor, SC or PIU CLO prepares a Complaint Form providing
full details of the alleged grievance.
Within 1 day • Copy of the Complaint Form shared with PIU CLO for entry into GCLS Database.
• Database reflects who is tasked with following up with Complainant
Within 2 days • The Complainant is contacted, and the concern is acknowledged and the
grievance process is explained in full.
• If the GBV Compliance Team is to be involved, team members will be
contacted within 2 days for a meeting within 7 days.
Within 14 days • Contractor will seek to resolve the complaint. Depending on nature or severity
of the issue a community representatives meeting may be called at the local
nakamal to identify acceptable resolutions
• If the Complainant agrees that the issue is resolved, the resolution is recorded
in the site diary, monthly report and the GCLS database is updated
• If Complainant is not satisfied, the matter is considered a grievance and is
passed to the PWD Divisional Manager for further investigation and resolution.
Within 30 days • PWD Division Manager investigates the details of the grievance with assistance
from the PIU CLO or PST and/or Contractor, if required, meets with relevant
parties, village leaders etc.
• Confirm resolution with Complainant (or their representative) within 1 week
and seek their approval or confirmation that the grievance is resolved.
• Grievance closed out by PWD Division Manager in writing, PWD Deputy
Director informed.
• Complaint Form signed by all parties and copy given to Complainant and to PIU
CLO to update the GCLS Database.
• If unresolved: Complainant may initiate legal process through the courts or
through the WB GRS.
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5 . Institutional Arrangements
Overall Arrangements
MFEM will be the Executing Agency for VCRTP, while MIPU will be the Implementing Agency. MIPU
will implement the project through a PIU established within PWD. The PIU Head will be responsible
for line management of the implementation of VCRTP. A Project Support Team (PST) of international
specialists will be set up and embedded in the PIU to work with the other members of the PIU to
support MIPU-PWD in the implementation of the project. There is no Project Steering Committee.
The PIU National Social Safeguards Specialist (SSS) and PIU Gender Specialist will support planning and
implementation of (i) community consultations, (ii) training of community representatives, (iii)
distribution of GRM Summary and Complaint Forms. The National SSS and Gender Specialist may be
called upon to provide support to (i) grievance investigations, (ii) coordination of Community
Representatives meetings, (iii) coordination of GBV Compliance Team meetings.
The Project Support Team (PST) Social and Environmental Safeguards Specialists, as part of the PIU,
will assist in the management of the GRM and provide oversight to monitoring and reporting as
needed.
The Public Works Department (PWD) Division Manager is responsible for final oversight of community
consultation and grievance management. If there is any grievance/issue arising that goes beyond the
capacity/authority of the Division Manager, they will raise the issue to the PWD Deputy Director.
The PWD Deputy Director serves as the PIU Head and is the contact person for any environmental
emergency situations that may arise during the implementation of the VCRTP civil works. The PIU
Head is to be available 24 hours a day, seven days a week, and has delegated authority to stop or
direct works. The PIU Head is supported by a Deputy Head and a Road and Bridge Engineer/PST
Coordinator.
Community representatives
The community representatives have the responsibility to accurately and fairly represent the AP or
Complainant’s concerns as described to them.
Contractor(s)
Contractors will be briefed on the GRM and are expected to follow its requirements as part of the
oversight of their subproject. The Contractor’s representative (typically the CCLO) will attend
community sessions on GRM and safeguards awareness or training run by the PIU.
The Contractor is responsible for logging all complaints and other safeguards non-compliance
incidents in the site diary (or equivalent) for inspection by the SC or MIPU representative. The
Contractor is also responsible for ensuring that all minor complaints are dealt with and resolved
directly without any undue delays.
Communities and potentially affected persons will be advised of the GRM in the early stages of
engagement on the project, and be made aware of:
• The potential impacts of the project and how these impacts are to be minimised (mitigation measures);
• How they can access the GRM (i.e. key contacts and complaint form);
• Who to speak to and how to make a complaint or lodge a grievance;
• The timeframes for each stage of the process;
• The GRM being confidential, responsive and transparent; and
• Alternative avenues of dispute resolution where conflicts of interest exist.
The GRM document will be disclosed on the VCRTP website and the complaint form will be available at the two
South Santo Administrative Offices and at PWD Luganville Office. Contact details for the Construction CLO and
the Supervision Consultant will be provided on works notice boards.
It is intended that the GRM be reviewed if or when necessary to ensure that it can deal with potential
sub-projects and in a manner that is appropriate and suits the social, cultural and legal situation in
Vanuatu. Once this document is publicly disclosed all the arrangements for dealing with complaints
and grievances under VCRTP as set out under this GRM will be implemented.
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Annex A. Complaint Form
Assign GCLS Database Number: ______ Date: ____ Time: ____
________________________________________________________________________________
9. Do you expect any form of retaliation or threats for filing this complaint? Yes____ No_______
10. Nature of the complaint: Compensation / Land Access / Inadequate Notification/ Disruption to
Business or Property / Property Damage / Irrigation / Boundary Dispute / Environmental Damage /
Construction Activities / Safety Risk /Traffic / Violence-Abuse-Exploitation/Other
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
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_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
No ☐ Why not?_______________________________________
_____________________________________________________________________________________
No ☐ Why not?_______________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
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