Processes/Procedures Aligned Minor gap Moderate non-alignment

Rating: Information available Information available Information available

indicates that this aspect of
the requirement is diligently
addressed by processes
and procedures in place.
indicates that processes
and procedures are in place
but there are some minor
components missing.
indicates that some
processes and procedures
are in place, but there are
significant components
missing.

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 Major non-alignment
Information available
indicates that there are no
processes or procedures in
place or that major
components are missing.

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E&S GAP ANALYSIS
MATRIX OF SOCIAL AND ENVIRONMENTAL STANDARDS
Category World Bank Environmental and Social Standards
A. ASSESSMENT AND MANAGEMENT OF (ESS) 2017
ESS1: Assessment and Management of
ENVIRONMENTAL AND SOCIAL
B. LABOR AND WORKING RISKS AND
CONDITIONS Environmental andWorking
ESS 2: Labor and Social Risks and Impacts
Conditions
IMPACTS
ESS1
World Bank Guidance Note for Borrowers: ESS2
1)
(GN 2)

C. RESOURCE EFFICIENCY AND POLLUTION ESS1: Assessment and Management of

PREVENTION
D. COMMUNITY AND MANAGEMENT
HEALTH & SAFETY Environmental
ESS and Social
4: Community HealthRisks and Impacts
and Safety
F. LAND ACQUISITION, RESTRICTIONS ON ESS 5: Land Acquisition, Restrictions on Land Use
LAND
G. USE AND INVOLUNTARY
BIODIVERSITY CONSERVATION AND ESSInvoluntary
World
and
ESS 3:Bank
6: Resource Efficiency
Guidance
Resettlement
Biodiversity andBorrowers:
Note for
Conservation Pollution ESS4
and Sustainable
DISPLACEMENT
SUSTAINABLE
H. INDIGENOUS PEOPLES ANDOF
MANAGEMENT LIVING
FPIC Prevention
(GN 4)
Management and
of Management
Living Natural
ESS 1: Assessment and Management ofResources
NATURAL RESOURCES
I. CULTURAL HERITAGE World
ESS 8:Bank
Environmental Guidance
Culturaland NoteRisks
Social
Heritage for Borrowers: ESS5
and Impacts
World
(GN 5)Bank Guidance Note for Borrowers: ESS3
J. STAKEHOLDER ENGAGEMENT AND ESS
(GN 1: Assessment and Management of
3)
INFORMATION DISCLOSURE ESS 7: Indigenous
Environmental and Peoples/Sub-Saharan
Social Risks and Impacts African
Historically Underserved Traditional Local
Communities
ESS 7: Indigenous Peoples/Sub-Saharan African
Historically Underserved Traditional Local
World Bank Guidance Note for Borrowers: ESS7
Communities
(GN 7)
World Bank Guidance Note for Borrowers: ESS7
World
(GN 7)Bank Environmental and Social Standard 10:
Stakeholder Engagement and Information
Disclosure
World Bank(ESS 10)
Environmental and Social Standard 10:
Stakeholder Engagement and Information
Disclosure (ESS 10)

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Other International Standards National Laws and Regulations

● International Labor Organization

Core Standards (ILO)
● WB Good Practice Note:
Addressing Gender Based Violence
in Investment Project Financing
involving Major Civil Works: 2nd
edition (WB 2020)
WB/IFC Environmental, Health and
Safety
● GuidelinesPrinciples
The Voluntary (EHS) on
Security
● UN andPrinciples
Basic Human Rights (VPSHR)
and Guidelines
● UN
on Universal Declaration
Development-based on and
Evictions
Human Rights namely
Displacement, (UDHR)42, 49, 52, 54
● UN60.
and Code of Conduct for Law
(OHCHR)
Enforcement
● Voluntary Officials (OHCHR
Guidelines the 1979)
WB Good Practice Note:onAddressing
● UN Basic
Responsible Principles
Governance on the Use of
Gender Based Violence inofInvestment
Tenure
Force
of and Firearms
Land,Financing by Law
Fisheries involving
and Forests
Project Major Civil
Enforcement Officials (OHCHR 1990)
(VGGT)
Works: 2nd edition (WB 2020)
● WB Good Practice Note:
Addressing Gender Based Violence
in Investment Project Financing
involving Major Civil Works: 2nd
edition (WB 2020)
● WB Good Practice Note: Assessing
and Managing the Risks and Impacts
of the Use of Security Personnel (WB
2017)

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ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISK AND IMPACTS
World Bank Environmental and Social Standard 1: Assessment and Managment of Environmental and Social RIsks and Impacts (ESS 1)
World Bank Guidance Note for Borrowers: ESS1 (GN 1)

Relevant Standards
Has a study (e.g., due diligence, ESIA) been conducted to
identifythepotential
Does project issues system
have a and or procedures
impacts? to monitor
(ESS 1 Para 14,15a,and
23)
evaluate alignment with international standards and/or
If yes:
compliance with regulatory requirements? (ESS 1 Para 15d)
a. Are human rights, risks and impacts considered in the
assessment? ( ESS 1 Para 28b)
Does theassessment
b. Is the project document
based the results of
on current the monitoring
information, activities
including an
and provide
accurate corresponding
project descriptioncorrective and preventive
and appropriate actions?
environmental and
(ESS
social 1baseline
Para 45)data? (ESS 1 Para 24)

Does theproject
c. If the projectoutcomes
undertakerely
performance reviews
on the activities of its
of government
environmental and social performance? (ESS 1 D)
agencies or third paties, do assessments clearly identify and
evaluate potential impacts of this reliance? (GN1 Para 7.3)
Is there a plan with differentiated measures, such as a
community development plan or Indigenous Peoples
development plan (IPDP), so vulnerable groups, people with
disabilities, displaced persons, and/or Indigenous communities
are not disadvantaged in sharing development benefits and
opportunities? (ESS 1, para. 29; GN 1, Para 6)

Does the project provide sufficient information or documentation

for an independent expert to conduct a full review?

Does the project have an Environmental and Social Management

System
Does the(ESMS)? (PS 1the
project have Para 5; PS 1 organizational
necessary GN 2; ESS 1 Para 41) and
structure
staff capabilities (i.e., knowledge and skills) to enable proper
implementation of the ESMS in conformance with international
standards? (ESS 1 Para 41)

Does the project have an overarching policy to achieve sound

environmental and social performance? (ESS 1 Para 41)

Is there a training plan to ensure that personnel have the skills

and knowledge
Does to perform
the project's ability totheir work?
achieve (ESS 1 Paraor1,social
environmental ESS 1
Annex 1 Para
outcomes 15.c)on the activities of other government agencies
depend
or third parties?
If yes, does the project identify and evaluate the potential
limitations as a result of this dependence and consider ways to
support the desired environmental and social outcomes? (GN 1
Para 7.3)

Does the project require that all engaged contractors operate in a

manner consistent with the requirements of the ESSs? (ESS 1
Annex 3)
If yes, answer a-f.
(a) Has the project assessed the environmental and social risks
and impacts associated with such contracts?
(b) Has the project ascertained that contractors engaged in
connection with the project are legitimate and reliable
enterprises, and have knowledge and skills to perform their
project tasks in accordance with their contractual commitments?
675403085.xls Page 5 of
(c) Ha the project incorporated all relevant aspects of the ESCP
into tender documents?
(d) Does the project contractually require contractors to apply the
relevant aspects of the ESCP and the relevant management
tools, including appropriate and effective non-compliance
remedies?
(e) Does the project monitor contractor compliance with its
contractual commitments?
(f) In the case of subcontracting, does the project require
contractors to have equivalent arrangements with its
subcontractors?

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AL AND SOCIAL RISK AND IMPACTS
ment and Managment of Environmental and Social RIsks and Impacts (ESS 1)

Key Findings (Key Gaps) Source (doc name Conformance

& section number)

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675403085.xls Page 8 of
Recommended Actions

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675403085.xls Page 11 of
675403085.xls Page 12 of
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LABOR AND WORKING CONDITIONS
World Relevant Standards and Social Standard 2: Labor
Bank Environmental Keyand
Findings (KeyConditions
Working Gaps) (ESS 2)
World Bank Guidance Note for
Has the country ratified all ILO core labor Borrowers: ESS2 (GN 2)
ILO Does
Core Standards
standards? If not,(ILO)
the project list the
have remainingfor
procedures ones. (ESS
managing
WB Does
2Good
and Practice
GN16.1, GN9.6
monitoring
the project Note:
the Addressing
(Footnote
labor
include managment
labor Gender Based Violence in Investment Project Financing involving Major Civil Works: 2nd edition (W
9);managment
ILO)
performance
the case ofof
requirements
In a third
in parties
third-party
party that whosubcontracts
contracts? engage (ESS 2
contracted
Para
workers,
Is 32)
there adoesworkers?
risk the
that (ESS
project
workers 2 Paras
require
Is there a risk that workers are exposed tofrom are that31-32)
precluded the third
parties
the
Might include
enjoyment
the project
Occupational equivalent
of
Health core ILO
be directly labor
labor
and Safety requirements
standards?
or indirectly
(OHS) risks
and
(e.g.,
involved
Does non-compliance
their
the in rights
child
project related
labor?
promote
including specific hazards in the remedies
to
(ESS 2 in
hours their
of
Para
agriculturalwork contracts
work,
17-19, 37,
production
areas,
with
wages,
–39, in
Might subcontractors?
40) overtime,
particular,
the project commodities
be (ESS
compensation,
directly
including physical (such as dangerous 2 Para
where
or 33)
and benefits
child
indirectly labor is
aupon
involvedbeginning
common in issue
forced the
(e.g. working
cocoa
labor?(ESS
machinery), chemical, biological hazards, and relationship
production)
2 Para 20) and
–
when
which
Does
specific any
could
the material
Human
threatsinterfere changes
toResources
women? with the occur)
child's
(HR)
(ESS (ESS
2policy
Para 2; ILO)
education
protect
25)
or
the
Doesbe harmful
workforce
the Human to
by the child's
addressing
Resources
Consider also injuries or loss of life from health
child
(HR) or physical,
labor
policy and
protect
mental,
forced
the
Is spiritual,
labor?
workforce
there
exposure antoHR (ESS
by moral,2 Paras
addressing
policy
wildlife. thatorsets
social outdevelopment?
17-20,
risks of37,
an 39, 40)
gender-
approach
(ESS
based
to
Has 2violence
managing
the Para
project 19)including
employees?
communicated sexual
( ESSto2exploitation
Para
all 9) and
employees
sexual
their
In harrasment?
working
countries conditions
where (GNand
national 2 Para
terms
law 13.4;
of 35.1)
recognizes
employment?
workers'
Where rights
the (ESS
projectto form Para
providesand10) to join workers' for
accommodation
organizations
workers,
Does the are
HR the of their
policy choosing
accommodations
promote thewithout
fairappropriate
treatment,
interference
and are
non-discrimination and
workers’ to bargain
basic
and needs
equal
Does the project have a grievance mechanism collectively,
met?
opportunity(ESS does
2 Para
of
the workers
28)
for
Do HR policy
workers, andtodoes
contracted explicitly
raise
workers state with
itreasonable
comply
have thatworkplace
access workers
national have
labor
to a third
theworker
and
party
Is freedom
employment
concerns?(ESS
grievance of association
health laws?
2andParas
mechanism? (ESS
safety and
21-23)
part collective
If2 not,
Para 13)
does
of the the
mandate
bargaining?
project
of the labor (ESS
facilitate
policy? 2(ESS
access Parato216)the
Para project
24) grievance
mechanism? (ESS 2 Para 33)

675403085.xls Page 16 of
 Source (doc name & Conformance
section number)

or Civil Works: 2nd edition (WB 2020)

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Recommended Actions APN Comments

675403085.xls Page 18 of
KfW comments

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 Concept note references development of
biodiversity friendly supply chains, and
Frank Momberg (during interview)
referenced as a project acitivty supporting
RESOURCE EFFICIENCY AND POLLUTION PREVENTION communities
AND MANAGEMENT in the sustainable use of
World Bank Environmental and Social Standard 1: Assessment The
NTFPs. Concept
and Frank Note
Managmentmade describes
very clear plans
of Environmentalthat tothis wasand Social RIsks and Impacts
World Bank Environmental and Social Standard 3: Resource "support
designed the
Efficiency development
to beand sustainable
Pollution and of a field
no office,
Prevention and Management (ESS 3)
Is the use
World BankofGuidance
pesticidesNote (selection ESS3 (GN 3) research
and management)
for Borrowers: pesticidesstation,
planned education
to be used. andNeed community
to
aligned with good international
IFC/WB General EHS Guidelines (EHS) industry practice and part outreach
triangulate facilities".
Franks comments by
of a management plan (ESS 3 Paras 21-25) understanding - Which NTFPs will be
Will those and
promoted be new doesconstruction
the development or of
Relevant Standards Key Findings (Key
upgrading/use Gaps) infrastructure? Not
of existing
Is there a pesticide application regime that avoids these require cheminal inputs such as
Has
damage the project
to natural checked
enemies pesticides
of the targetproposed pest?for critical
pesticides?(and Is probably
there any unlikely)
possibility but Pesticide
thatthere Management
are
procurement against the criteria of carcinogenicity, plans that candevelopment
agriculatural be shared that show the size
requiring
mutagenicity,
Where avoidance or reproductive
is not possible, toxicitydoes outlined in the
the project of those facilities
chemical inputs could and more be becomedetaileda project
plans
pesticide's
demonstrate Material
attempts Safety Dataand
to avoid Sheet and asdamage?
minimize set for theirinuse?
activity Will those
the future? Needfacilities
to nowproduce explore
forth by relevant international agencies and outlined in pollution that could are
whether pesticides be aalready
significant usedrisk iin to
the Globally Harmonized System of Classification and people See above
subsistence or theagriculture,
environment? NTFP (The term or
harvesting
Labelling of Chemicals (GHS)? (GN 3 Para 22.1) “pollution”
Does islevel
FFI foresee
commercial usedag to (e.g.
any refer toplanned
of itspalm both and hazardous
projectn
paper)
and
the landscape? Is there a risk that by in
nonhazardous
activities resulting inchemical
increased pollutants
waste
Has the client demonstrated it has avoided the release the solid, local
production?
securing liquid, or gaseousland
Orcommunity
hazardous phases,
waste? access and
What rights
of pollutants, or when avoidance is not feasible, includes
does
(and it other
predict
community
See above components
the most
forestry), such
significant
pesticide as thermal
waste
use
Will the project involve the application of pesticides, discharge toincrease
water,
minimize and/or control the intensity and mass flow of streams could then will be? Foremissions
example use
subsequently of short-
or a and
as
fungicides or herbicides (biocides)
their release? (ESS 3 Para 11) or of integrated pest provision long-lived
Will theAre
result? ofclimate
project there have
paints, any agri
Pollution
pollutants,
any
otherkind
chemicals, ofand
nuisance
activities
Resource Efficiency Management
monitoring
oils,
being
management?
Does the client (ESS apply3)project-specific pollution odors, noise, vibration, radiation,
programme
petrols
LLF funded (however
or hydrocarbons,
that might basic) or any
indirectly in place
medical
promote the
prevention
Might and control
Is therethehistorical
project cause techniques
pollution? If so, to
pollution that
has are
air,the aligned
client
land or water with wastes,
electromagnetic
whereby potentialenergy,
batteries orpollution andimpacts
lightbulbs? the creationwill beof
use
See of pesticides?
above
good international
determined
resources?
Will
Has the
the project
clientwhether
(ESS lead industry
3)
applied it
to is
a practice
responsible
increased
hierarchical
Does the project have alternatives to reduce project- waste(e.g.,
for WBG
mitigation
production,
approach toEHS in
avoid, potential
monitored? visual impacts including light ). If
Guidelines)
measures,
particular, to
and mitigate
hazardousif legally adverse
?responsible,impacts have on human
15) the liabilities these projects are likely
wastetodisposal
result insites a in
minimize,
related
Does
health theGHG
and
recover,
clientemissions
the in have awaste?
reuse
environment?
and
(ESS
process (ESS
apply
(ESS
3 Para
for 3)
environmentally
determining
vetting
3 Para its 11) whether Are
contractors
there licenced
been
sound
licensedresolved
disposal ofaccordance
waste, with
including national
hazardous law and/or
waste? significant
the area impact,
that can behow usedwill toFFI mitigate
dispose of this
to confirmdisposal
they aresites are being
licensed operated
and obtain chainto applicable
of custody
GIIP?
(ESS
Does 3 (ESS
the
standards? Para 3
projectPara
17) have
(ESScontrol 12)
3 Para technically
a plan to and
quantify financially
the GHG feasible risk?
project waste
18) 18) are applied, has the Does the project have any plans to utilise if significant waste streams
documentation?
Ifemissions
less stringent (ESS 3measures
Para
and cost-effective
in accordancemeasures withfor improving efficiency
internationally recognized in will be produced?
client provided its rationale/justification? Has the 16) renewable
client Does
Frank FFI Momberg energy
foresee sources
any
interview of the inproject
talks theabout
project the
itsthe
consumption
Ifmethodologies
project has ofthe
and energy,
good water,
practice?
potential and(ESS
to constitute other aresources
3 Para
significant
demonstrated its approach is aligned with the mitigation landscape,
activities e.g. solar?
requiring additional water usage to
and
source
Is material
there inputs? in(ESS
ofanemissions
overarching an 3 Para
already
policy that 5)degraded
defines area, has possibility
Are there of
any scaling
known up ecotourism
issues in the (from
hierarchy (minimize or reduce adverse impacts on what is
community already
landscape ofbased used
disposal in the
ecotourism landscape?
of hazardous that exists
wastes
Will client
the the project
environmental consideredlead tostrategies
objectives significant andincreases
and principles? adopted Has ofmeasures
it been
Is therehealth
human a planand to avoid
the or reduce water usage so that
environment? now) - Please can FFIoperations
describe in more
greenhouse
that avoid or gas
communicated reduceemissions
negative
throughout or effects?
the to a substantial
organization?(ESS 3(ESS Para115) by
reduction commercial scale (e.g. palm
the project’s water consumption does not have Are
detailthere any
the plans wider issues in the
for developing landscape
community
23) pools, e.g., through loss in vegetation cover or and
of carbon
Para paper cultivation)?
significant impacts on others? (ESS 3 Paras 5,9 ) of over extraction of water (e.g.
below- and above-ground carbon stocks? (ESS 3 Para based ecotourism, what will they be
groundwater)
funding? Couldthat FFIare causing
foresee other issues
a situation
16)
such as reduced access
where ecotourism could develop beyond by local
communities
community ecotourism or subsistence? and require
additional infrastructure and footprint?
Where will the ecotourism most likely be
located?

675403085.xls Page 20 of
nmental and Social RIsks and Impacts (ESS 1)
ention and Management (ESS 3)

Source (doc name & section Conformance Recommended Actions

number)
Pesticide Management

nd Resource Efficiency Management

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COMMUNITY HEALTH AND SAFETY
World Bank Environmental and Social Standard 1: Assessment and Management of Environmenal and Social Risks and Impacts (ESS 1
World Bank Environmental and Social Standard 4: Community Health and Safety (ESS 4)
IUCN SSC Human-Wildlife Conflict Task Force
Relevant Standards Key Findings (Key Gaps)
The Voluntary Principles on Security and Human Rights (VPSHR)
UN Universal Declaration on Human Rights (UDHR)
Hasofthe
UN Code project for
Conduct evaluated the risks and
Law Enforcement impacts
Officials to
(OHCHR 1979)
health
UN Basic and safety
Principles to the
on the Useaffected
of Forcecommunity?
and Firearms (ESSby 4Law Enforcement Officials (OHCHR 1990)
Use ofPara 5; VPSHR;
Security Forces:IFC 2017) and Managing Risks and Impacts, Guidance for the
Assessing
Private Sector in Emerging Markets (IFC 2017)
WB Good
Has Practice
the projectNote: Assessing
evaluated and Managing
project-related risksthe
of Risks and Impacts of the Use of Security Personnel (WB 2017)
WB Good Practice
gender based Note: Addressing
violence, includingGender
sexual Based
Is there a plan to prevent or minimize the risks and Violence
exploitation in Investment Project Financing involving Major Civil Works (WB 2020)
and sexual
impacts
Has harassment,
to the
the project health andinsafety
evaluated the community?
of the affected
project-related (WB
risks of
2020) the project
communities
gender-based
Does during theanduration
violence,
have including
emergencyofsexual
thepreparedness
project? (ESS
exploitation
4 Para
and
Is 5)a risk
sexual
response
there harassment,
system
that the or in theto
plan
project community?
stir orto (WB
respond
would
2020)
accidental
exacerbate and emergency
conflicts amongsituations?
communities,(ESS 4 Paras
groups or
19-23)
individuals (e.g., by increasing resource competition
when promoting economic opportunities,
strengthening rights of selected groups) or the risk of
violence to project-affected communities and
individuals?

Consider in particular risks prevalent in a conflict or

post-conflict context and dynamics of recent or
expected migration (e.g., displaced people).Does the
project have a plan to manage conflicts among
communities, groups or individuals or the risk of
violence to project-affected communities and
individuals? (ESS 1 Para 28b; ESS10 Annex 1 A.
5.e: Social and Conflict Analysis)
Does the project have a plan to prevent, mitigate,
and
Is compensate
there a probabilitycommunity
that the health
projectand safety risks
causes
in there
Is the context
community a risk of
thatHuman-Wildlife
exposure thetoproject
healthexposesConflict
issues such (HWC)?
as water-
communities
(ESS
to
Is both4water-based
borne,
there Para 5) and
accidental
a probability and vector-borne
natural
that hazards,
the project diseases,
createand
particularly
could
communicable
where
nuisancesstructural diseases? (ESS
elementshealth
to community 4project
of theand Para 15)
or program
safety, e.g., Security
are accessible
through to members
the generation of the
of dust, affected
burning of wastes,
Has thenoise,
community,
traffic, project assessed
orinflux
whereof their the risksetc.?
failure
foreigners, posed
could by 4its
result
(ESS inPara
security
injury to the community? (ESS 4 Para 5-8) outside
5) arrangements to those within and
the project, including arrangements where
government security personnel are deployed to
provide security services? (ESS 4 Paras 24, 25;
OHCHR 1979; OHCHR 1990; IFC 2017)

Is there a plan to ensure that the safeguarding of

personnel and property is carried out in a legitimate
manner that minimizes risks to the community’s
safety and security? ( ESS 4 Paras 24-26; OHCHR
1979)
Does the community health and safety plan include
measures to monitor, address and respond to
reports of gender-based violence? (WB 2020)

675403085.xls Page 22 of
Is there a plan to manage direct or contracted (i.e.,
private) security personnel that will safeguard its
personnel and property?

If yes, does the plan include Rules of Conduct,

training, monitoring and investigation of misconduct
and corrective actions? (ESS 4 Paras 24-26;
OHCHR 1979; OHCHR 1990)
Does the project or its partners engage or work with
security personnel (including ecoguards) that may
pose a potential safety risk for communities and/or
individuals, e.g., due to a lack of adequate training or
accountability? (ESS 4 Paras 24-26)

Is the project using government security personnel?

If yes, is there a plan or agreement to ensure that

they are to act in a manner consistent with what is
applied to the project’s direct or contracted security
personnel? (ESS 4 Paras 24-26; OHCHR 1979;
OHCHR 1990)
Does the project involve armed personnel to conduct
law enforcement activities? (ESS 4 Para 26; IFC
2017; OHCHR 1979; OHCHR 1990)? If yes, answer
a-f.
a) Is there a track-record of human rights abuses on
the part of law enforcement personnel in the
country?

b) Please describe the recruitment procedure and

criteria for law enforcement personnel.
c) Is there a professional code of conduct for law
enforcement personnel?

d) Is there a training regime in place for law

enforcement personnel on use of force, appropriate
conduct, conflict mediation and resolution as well as
on human rights?
e) Are disciplinary procedures in place to handle
allegations of unlawful conduct on the part of law
enforcement personnel, and are they interlinked with
relevant authorities?
f) Is the project aware of any serious
incidents/human rights violations related to the
conduct of law enforcement personnel?

Do risks posed by the project warrant a full Security

Risk Assessment (SRA)?
If yes, does the SRA include background research,
an onsite assessment, consideration of scenarios,
and development or refinement of mitigation
measures in line with international standards? (IFC
2017)

675403085.xls Page 23 of
and Social Risks and Impacts (ESS 1)

Source (doc name & section Conformance Recommended Actions

number)

rsonnel (WB 2017)

ving Major Civil Works (WB 2020)

ecurity

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LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY DISPLACEMENT
World Bank Environmental and Social Standard 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement (ESS 5)
Please
World Bank consider the and
Environmental following
Socialactivities:
Standard Guidance Note 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlem
1) establishing new protected
United Nations Basic Principles and Guidelines areas (PA)on orDevelopment-based
extending the Evictions and Displacement (OHCHR)
area of an existing PA
Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests (VGGT)
2) improving enforcement of PA regulations, e.g., training
b) Could access restrictions lead to adverse impacts on
guards, providing monitoring and/or enforcement equipment
Does the project
livelihoods, foresee any
food security, restriction
businesses and onemployment
access to land dueor
3) providing training/tools for improving management
use of other resources including communal property and
to:
effectiveness
Relevant Standards
•natural
Loss ofresources
access tosuch as marine
natural resourcesandinaquatic resources,
a particular area, i.e.
4) constructing physical barriers that prevent access by
timber and non-timber
displacement of fisheries forest products, fresh water,
people
medicinal
•a) Change plants,
Indicateto the hunting
theproject
quality orand
activitiesgathering
thatof(might)
quantity grounds
resources aand
involve grazing
household
5) changing how specific natural resources are managed to
and access
cropping
restrictions
can andareas? (ESS 5 Para
the respective 4f ) to be restricted.
resources
a management system that is more restrictive.
• Change in seasonal access to a resource
c) Are there
• Change individuals
in nature and communities
of access with strongtoties to
(i.e. from unregulated
Doesorthe
land projectand
territory foresee activities
resources and that
with involve
customaryrestricting
tenure
regulated)
access to
system land/water
(despite not or natural
being resources
recorded, titled or
or changes
protected inbythe
• Change in types of assets needed to access resources.
use and
government)?management of
(ESS 5 Para natural resources? (ESS 5
4c)different livelihood elements Para 4
If yes, please elaborate on the
8; ESS
Consider 5 GN 4.8, 4.9)
also communities whose
that are affected. (ESS 5 Para 4, 14rights recognized
(footnote 16) andunder
Ifinternational
yes, answerlaw, a-ee.g.,
belowIndigenous peoples.
35b;ESS 5 GN 12.1 and 35.1)
d) Is there a risk that the project might negatively affect
current tenure arrangements or community-based property
rights
e) If it to natural
is not resources,
possible to avoid land/water areas,
restrictions, will or
theterritories
project
through measures
include measures to other than access
minimize restrictions?
or compensate (ESS 5
for impacts
Has a census with appropriate socio-economic baseline data
Para loss/restrictions
from
Does 1the
(footnote
project 2), 4ofand
support 20; ESS
access?
state 5 GN
Please
efforts 4.8 and 4.9)
describe
to establish the
up-to-date
been conducted to identify persons who will be eligible for
measures.
tenure (ESS 5 on
information Para 11)fisheries and forests that they
land,
Ifcompensation
the project involves? (ESS 5unavoidable
Para 20) land acquisition or
own or control by creating and maintaining accessible
restrictions
Has a census on with
landappropriate
use, are persons compensated
socio-economic at data
baseline
inventories? (VGGT 8.4)
replacement
Ifbeen
the livelihoods cost?
conducted to (ESS
of identify
displaced5 Para 12)
persons
persons who will be eligible
is land-based, didforthe
compensation?
project
Does theoffer (ESS
have5apersons
displaced
project Para 20)an option
grievance mechanismfor replacement
in place to
Are eligibility criteria established that define who is entitled to
land in accordance
address with paragraph
specific concerns 35(a)? (ESS 5relocation
about compensation, Para 14)or
benefits or compensation? Are they transparent and fair,
livelihood
Where landrestroration
acquisitionmeasures? (ESS 5 Para
is the responsibility of the19)host
e.g., in proportion to their losses and to their needs if they
government,
Does the projectdoesconsult
the project assist
with the in the resettlement
community to agree upon a
are poor and vulnerable? (ESS 5 Paras 10-12)
planning,
suitable
Was implementation
alternative
an attempt madewhen and monitoring?
there
to avoid is aminimize
or (VGGT
loss of public 3.2)
amenities?
involuntary
(OHCHR
displacement
Have 38) wherever
affected persons and feasible by exploring
communities, alternative
including host
project
communities,
For designs?
projects been
that (OHCHR
consulted
involve 38)in the
economic
physical decision-making
displacement
displacement ofofpeople,
people,is
processes?
is
therethere a plan(OHCHR
a resettlementdetailing38)the plan
action measures
(RAP)? needed
(ESS 5toPara improve
20) or
restore livelihoods? (ESS 5 Para 21d) Resettlement or Eviction
Does the project offer provide relocation
persons who assistance suited to the
have no recognizable
needs of each group of displaced persons,
legal right or claim to the land they occupy a choice with particular
of
Will the project involve resettling peoples or communities?
attention paid
adequate to thewith
housing needs of theofpoor
security tenure?and(VGGT
the vulnerable?
3.2. 5.3)
(ESS 5 Para 11) If yes, answer a-b below.
(VGGT
a) Describe 5.4)?the project activities that require resettlement
b) Have alternative project design options for avoiding
resettlement been rigorously considered?
Is there a risk that the project could result in forced
evictions? (ESS 5 Para 31; OHCHR 8, 11)
a) If there is a risk of forced eviction, does the project have a
If yes, answer a-e below.
framework
b) If there isoraplan to forced
risk of encourage the goverment
eviction, does the projectto meet have a
internationalorstandards
framework with the elements
plan to encourage the govermentoutlined in
to meet
c) If there is a risk of forced eviction, does the project have a
OHCHR 37-44
international prior to eviction?
standards with the elements outlined in
framework
d) In the event or plan to encourage
of forced eviction,thedoesgoverment
the project to have
meet a
OHCHR 45-52 during eviction?
international
framework
e)In the event orstandards
plan with
to encourage
of forced the elements
eviction, the
does the outline
projecttoinhave
goverment OHCHR
meet a
52-58 after or
international
framework eviction
plan to? encourage
standards with the elements
the govermentoutlinetoinmeet
OHCHR
59-68?
international standards with the elements outline in OHCHR
If69-70?
the project includes any livelihood measures, what
are/were the eligibility criteria that define who will receive
livelihood support and who would be ineligible? (ESS 5 Para
9,31e, 33b)

675403085.xls Page 26 of
 AND INVOLUNTARY DISPLACEMENT
Acquisition, Restrictions on Land Use and Involuntary Resettlement (ESS 5)
ce Note 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement (ESS 5 GN)
elopment-based Evictions and Displacement (OHCHR)
f Tenure of Land, Fisheries and Forests (VGGT)

Key Findings (Key Gaps) Source (doc name Conformance

& section number)

Resettlement or Eviction

675403085.xls Page 27 of
Recommended Actions

675403085.xls Page 28 of
 Will the project introduce or use alien species (flora and
fauna), whether accidental or intentional? If so, has a
BIODIVERSITY CONSERVATION
risk assessment AND SUSTAINABLE
been undertaken? (ESS 6 Para 29) MANAGEMENT OF LIVING RESOURCES
World Bank Environmental and Social Standard
Where alien species are already established in the 6: Biodiversity Conservation & Sustainable Management of Living Natural Resources (ES
country or region of the I'd like to explore whether there are any existing known
Where alien species areproposed project, hasinthe
already established the
proponent exercised diligence in not spreading them significant issues of invasive alien species in the
country
RelevantorStandards
region of the proposed project, has the Key Findings (Key Gaps)
into
Has areas in which taken
the proponent
proponent exercised they have not
measures
diligence already
in not alien landscape? If yes, are FFI and implementing partners
been them
tospreading
eradicate
Are any from
species
into areas
project
established? theactivities
(ESS
in which 6they
Para
natural proposed within
29)not over
habitats
have alreadywhich
beenthey haveto aware of these species? If required, will FFI and
or adjacent
areas of
management high biodiversity
control? value or critical
(ESS29)6 Para 30) habitats, implementing
Yes partners bedetails.
- need to determine taking What
steps national
to mitigate the do
status
established? (ESS 6 Para
including legally protected areas, areas proposed for spread
they of these
have? Whatfurhter?
are they protected for? Who is
protection, or recognized as such by authoritative responsible for their protection? Are they receiving
Has
Is the aproponent
there taken adverse
risk ofIndigenous
causing measures to eradicate alien
impacts
sources and/or peoples or localto adeqaute funding and management to meet goals?
species from
biodiversity the natural
and(ESS habitats
the integrity over which they have
communities? 6 Para 8)of the ecosystems (such
management
as waste, noise, control? ESSetc.)
pollution, 6 Para
that30 ) result in a
could
loss, degradation or fragmentation of protected or
ecologically sensitive areas (e.g., wetlands, migration
routes), and other areas of conservation interest due to
site footprint and earthworks during construction or
maintenance? (ESS 6 Para 8)

Is there a risk that the project could give rise to an

If the
Is project
there a riskpromotes the usenegatively
that the project of resources fromwater
affects
increase of incoming migration and population Only potentially through increased ecotourism in the
naturalthrough
flows habitats (such as diversion
extraction, timber or non-timber
or containmentforest
of
increase, which could put a strain on the existing future. See ESS3 for questions on Ecotourism.
products),
surface is there a risk(e.g.,
or groundwater that this mightdams,
through lead toreservoirs,
natural resource base? (ESS 6 Para 8)
unsustainable
canals, levees,use?
river How
basinwill this be prevented?
developments, (ESS 6
groundwater
Para 31) or through other activities and as such alter
extraction)
existing stream flow and reduce seasonal availability of
water resources? (ESS 6 Para )

675403085.xls Page 29 of
ving Natural Resources (ESS 6)

Source (doc Conformance Recommended Actions

name &
section
number)

675403085.xls Page 30 of
INDIGENOUS PEOPLES AND FPIC
World Bank Environmental and Social Standard 1: Assessment and Management of Environmental and Social Risks and Impacts (ESS 1
World Bank Environmental and Social Standard 7: Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local C
World Bank Environmental and Social Standard 10: Stakeholder Engagement and Information Disclosure (ESS 10)

Relevant Standards Key Findings (Key Gaps)

Could
Is theretheanproject
Indigenouspotentially
Peoples discriminate
Development againstPlan
vulnerable
(IPDP)?a (ESS
Where groups
project 7 Parawith17regards
proposes ) to usetothe participation
cultural in the
design
resources
Are and implementation
of Indigenous
individuals and groups peopleof project activities or to
for commercial
that may be
access
purposes, to opportunities
are thereaffected
disproportionately
Is there a likelihood thatand
plansprojectbenefits?
tobyensure
therisks (ESS
fair
project
and and 1equitable
Paraof
because
negative
28b
sharing
their
impacts of
fallbenefits
vulnerable from(including
status
disproportionatelycommercialization?
on Indigenous
disadvantaged (ESS or7
people)
Parasthe 29-30)
identified?
vulnerable
Does (ESS 1have
individuals
project Paraora 28b;
groupsESSother
framework 7 or
Paras
plan 7-10,
than 12)
Indigenous
to ensure
peoples
the
Does the(for
involvement example,
project ofseek women,
identified
to avoid girls,
vulnerable
adverse elders) or to
persons
effects
contributes
(including
communities to their
Indigenous
of discrimination
Indigenouspeople) in
peoples?
Is the plan to consult with all Indigenous people or
the marginalization?
design
(ESS 7and
Para 18)
implementation
affected
Does thebyproject ofobtain
project
the project activities
culturally
free, or toinformed
priorappropriate
and accessand
Considerinimpacts
opportunities
accessible?
consent the and
(ESS on material
benefits?
7 Para
project 13)(ESS
design, or non-material
10 Para 7) and
implementation
livelihood outcomes
expected conditions.related to impacts in special
(ESS 1 Para 29;(ESS
circumstances? GN 17Annex Paras124-33)Para 13f; ESS 2 Paras
13-14)
a) Name the groups; distinguish, if applicable, the
geographical
b) What
Is the are the
project areas
key
site in of their
areapresence
characteristics
an inhabited (including
thatbyqualify the
the
or important
areas
identified
c)
to Is of resource
there
Indigenous groups
a risk asuse)
that
peoples, theand
Indigenous how
project
tribal theseorrelate
groups?
affects
peoples their
other to the
Do these
livelihood
project's
groups
in
traditional area
waysidentify
other ofthemselves
than
peoples? influence.(ESS
through
(ESS 7access as
Para 77)Para
Indigenous? 12)answer
restrictions,
If yes, Howe.g.,
doesby
the host
affecting
questions country's
their
a-h. government
self-determination, refer to
cultural these groups?
identity,
d) Are
e) Doesany the project intend
Indigenous groupsto promote
living in the use of
voluntary
(ESS
f)values
Even 7and
Explain
if Para 8 andand
practices,
whether
Indigenous 12)social
groups cohesion,
how legitimate or at
bytheproviding
representatives
IndigenousIf peoples'
isolation? yes, how does are
traditionalthe not found
ecological
project project
knowledge?
respect their
inequitable
of Indigenous
sites, is therebenefits?
groups
still a (ESS
riskhavethat 7the
Para
been 12) could
consulted
project to affect
discuss
rights
g) Has(paying
a process attention to national
been started laws on the matter)
or implemented to
theExplain
h) project andlivelihood
whetherbetter understand
opportunities potential
are impacts
considered to
achieve their free, prior and informed consent to (ESS
and rights
avoid and
any negative of Indigenous
impacts? (ESS peoples?
7 Para 19)
uponParathem?
provide
7activities (ESS
7benefits
and 8) 7 Indigenous
Para11,
foryes,
If answer 13questions
and 23) a-h.
peoples? If yes, is it
that might affect them, positively or
ensured that this is done in a way agreed with them
negatively? (ESS 7 Para 24)
and is culturally appropriate and gender-inclusive?
(ESS 7 Para 20 and 21)

675403085.xls Page 31 of
nd Social Risks and Impacts (ESS 1)
ally Underserved Traditional Local Communities (ESS 7)
sure (ESS 10)

Source (doc name Conformance Recommended Actions

& section number)

675403085.xls Page 32 of
CULTURAL HERITAGE
World Bank Environmental and Social Standard 8: Cultural Heritage (ESS 8)

1. Is the project located in or near a site officially designated

orRelevant
proposed Standards
as a cultural heritage site (e.g., UNESCO World
Is the project
Cultural or Mixeddesigned
Heritageto avoid
Sites,significant
or Culturaldamage to
Landscapes) or
acultural heritage?
nationally (ESS site
designated 8 Para
for 9cultural
) heritage protection?
(ESS
a) Will8the
Para 4 andinvolve
project 17) If yes, answer a-c
development of below.
infrastructure (e.g.,
Is critical cultural heritage being altered, damaged or
roads, dams, slope restoration, landslides stabilization) or
removed?
Are (ESSto8 Para
there plans consult 12)with stakeholders to identify
2. Does the project
construction site include
of buildings important
(e.g., visitor cultural
center, watchresources
tower)?
cultural
Has the heritage of importance?
project allowed continued ( ESS 8 Para
access 14) sites
to cultural
such as burial sites, buildings or monuments of
that are within project sites? (ESS 8 Para 16 )
archaeological
b) Will the project historical,
involve artistic,
excavationreligious, spiritual of
or movement or earth,
symbolic
flooding
Will orvalue? (ESS
physical
the project 8local
Parausers'
environmental
restrict 4 andaccess
18) If yes,
changes answer
to(e.g., a-cof
as part
cultural
below.
ecosystem
resources
Is there a riskorrestoration)?
natural features/sites
that project activities with cultural,
might spiritual or
affect intangible
Will the project promote the use of (or development of
symbolicresources
cultural significance?such(ESS 8 Paranorms
as values, 16) or practices of
economic benefits) from cultural resources or natural
3. Is
c) Does
local therethea project
risk thatarea
communities? site
physical
(ESS include
7) any natural
interventions
8 Para features
described in or
features/sites with cultural significance? (ESS 8 Paras 29
resources
items a) andthatb)are of cultural,
might spiritual,
affect known or symbolic
or unknown (buried)
and 30)
significance,
cultural such as sacred natural sites, ceremonial areas,
resources?
or sacred species? (ESS 8 Para 4 and 24) If yes, answer a-c
below.

675403085.xls Page 33 of
tural Heritage (ESS 8)

Key Findings (Key Gaps) Source (doc name & Conformance

section number)

675403085.xls Page 34 of
Recommended Actions

675403085.xls Page 35 of
STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE
World Bank Environmental and Social Standard 10: Stakeholder Engagement and Information Disclosure (ESS 10)
World Bank Environmental and Social Standard Guidance Note 10: Stakeholder Engagement (ESS 10 GN)
WB Good Practice Note: Addressing Gender Based Violence in Investment Project Financing involving major Civil Works: 2nd edition (W

Key Findings (Key Gaps)

Have project stakeholders been identified? (ESS
10 Para
Has 10)
information about the project – objectives,
activities,
Does sites and
the project potential
have risks – been
a stakeholder engagement
disclosed?
program (ESS
that 10 strong,
builds Para 19)
constructive and
responsive relationships with affected
communities? (ESS 10 Para 13)

Does the stakeholder engagement plan or

program
Does thedemonstrate
project describe howhow it provides for active
the identified
participation
Ifstakeholder
the projectwillof abewide
includes range
further of stakeholders
engaged
expansion, –
during project
demarcation
particularly
implementation?
and/or
Has women
themaintenance
project (as
(ESS
disclosed individuals
of 10 Para 13)
Protected
relevant or groups),
Areas or civil
information
society
activities
such
Does as organizations
the that
project would
project (CSO),
result
objectives,
have an external representatives
inactivities,
negative impactsofon
risks,
the local
affected
impacts
Does communities
populations
theand
communications opportunities?
project – and
procedure?
facilitate local
e.g.,inclusive
through
(ESS groups,
access
10 Paras 11,
consultation
Indigenous
restrictions,
23)
and meaningfulpeoples? (ESSa10
etc. participation
– is there inPara 13,15,16
participatory
the language and
process
of Grievance Mechanism
17;
in ESS
place
Were relevant
preference 10 GN
allowing 13.1)
(i.e.,and project-affected
localvulnerable
languagegroups people to
– e.g.,
or dialect) of the
Has
women, a project-level
determine
affected zoning
civil society
community ofgrievance
well asmechanism
restricted
organizations
as areas, access
in a (CSO), been
culturally 31.1. Safeguarding Children and Vulnerable
restrictions, manner?
established
representatives
appropriate that
and of explains
thethe
sequencing
the10
local
(ESS processes
of project
communities
Paras for
and local
20-22) Adults Policy: Corporate grievance mechanism
activities?
submitting
groups, ESS
grievances,
Indigenous 10 Para resolving
6; ESS
peoples, etc.10and
– GNescalating
6.3 in the
involved does not state Local safeguarding Focal Point for
grievances?
consultations or consulted separately? (ESS 10 Indonesia Program as on appendix 3.
IfPara
not,5-11,
explain how and19,when
13,15-17, 20, ESS this will happen.
10 GN 13.1)
(ESS 10 Para 26; ESS 10 GN 26.1)

Is there a grievance mechanism to resolve Q1, Yes

concerns and grievances about the project's Q2, Yes
social and environmental performance raised by
individuals or groups? (ESS 10 Para 26)
Is the mechanism designed to address concerns Yes
Does the?mechanism
promptly explain
(ESS 10 Paras 26, the
27a)processes for
submitting grievances, resolving and escalating
Is the grievance
grievances? mechanism
(ESS 10 Para 26;process
ESS 10easily
GN 26.1) Yes
understandable and transparent? (ESS 10 Para
27a)
Does the mechanism allow for anonymous Yes
complaints to be raised and addressed? (ESS10
Para 27b)
Is the grievance mechanism culturally appropriate Coroporate grievance mechanism does not
and readily accessible to all segments of the appropriate for West Papua Project
affected communities at no cost or retribution to
all segments of the affected communities? (ESS
10 Para 27a)

Are the affected communities informed about the Doc. 24 PreFS FFI's IP sites_v4 (Page 21 Para
mechanism in the course of the community 2); does not specifically mentioned that the
engagement process? (ESS 10 Para 19f, 27a) affected communities informed about the
mechanism in the course of the community
Is the grievance mechanism safe and accessible engagement process
to victims of gender-based violence, including
sexual exploitation and sexual harassment? (WB
2020)

675403085.xls Page 36 of
Disclosure (ESS 10)
ESS 10 GN)
nvolving major Civil Works: 2nd edition (WB 2020)

Source (doc name Conformance Recommended Actions

& section number)

ievance Mechanism
Document review Appointed Local Safeguarding Focal Point for
Indonesia Program
Moderate non-alignment

Document review
Aligned

Document review Aligned

Document review
Aligned

Document review
Aligned

Document review Developing guidance in Bahasa and appointed

Local Safeguarding Focal Point for West Papua
Moderate non-alignment Project.

Document review Developing procedure for community engagement

process
Moderate non-alignment

675403085.xls Page 37 of
Conformance
Aligned
Minor gap
Moderate non-alignment
Major non-alignment
N/A