In addition, according to the ESF Good Practice Note “Addressing Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) in Investment Project Financing involving Major Civil Works,” “all projects need to have a framework for properly handling SEA/ SH allegations.”63 A report from the Bank’s Global Gender-Based Violence Task Force also indicates that the GRMs for all Bank investment projects must have “mechanisms to track complaints specifically linked to SEA and GBV” incorporated into them.64 Survivors that submit grievances about gender-based violence (GBV), especially sexual exploitation and abuse and sexual harassment (SEA/SH), may have “risks of stigmatization, rejection and reprisals.”65 The Good Practice Note explains that “SEA and SH are manifestations of GBV,” which is “an umbrella term for any harmful act that is perpetrated against a person’s will and that is based on socially-ascribed gender differences.”66 Equipping GRMs to handle GBV/SEA/SH in the examined SEPs Five of the examined SEPs — those of Liberia, Philippines, Sri Lanka, Burkina Faso, and Nepal — indicate that the GRMs used for the projects will be equipped to handle GBV or GBV/SEA/SH. Table 5 shows, however, that these five projects use different terminology to describe how they will equip their GRMs to handle different forms of gender or sexual violence. Three SEPs, those of Philippines, Burkina Faso, and Nepal, state that their GRMs will have procedures to handle “GBV” grievances.67 The GRMs for both the Liberia and Sri Lanka projects will be equipped to handle allegations of “GBV/SEA/ SH.”68 The Uganda and El Salvador SEPs indicate that the Ministry of Health will make available resources to report cases of “GBV/SEA” and violence against children (VAC), but describe these resources as 63 See 6d under GPN in Annex 1; Grown et al., “Good Practice Note: Addressing SEA/SH,” 44, par. 116. It is outside the scope of this report to assess whether all or parts of these projects are considered major civil works and whether the ESF Good Practice Note should be applied. 64 Sierra and Gupta, “Working Together to Prevent Sexual Exploitation and Abuse,” 41. 65 See 6c under GPN in Annex 1; Grown et al., “Good Practice Note: Addressing SEA/SH,” 36, par. 87. 66 See 6a under GPN in Annex 1; Grown et al., “Good Practice Note: Addressing SEA/SH,” 5, par. 12; 6, par. 16. 67 The Philippines SEP does not provide information specifically about how the GRM will be equipped to handle GBV complaints but says that a revised SEP will have further details. The Burkina Faso SEP indicates that the GRM will have “specific procedures in place for addressing GBV” and that the project will consider establishing a separate GRM to handle GBV complaints. The Nepal SEP says that the GRM for the project “will be used for addressing GBV-related issues.” See: Demombynes, “SEP - Philippines COVID-19 Project,” 10; Besarabic Bennett, “SEP- Burkina Faso COVID-19 Project,” 13; Bhattarai, “SEP - Nepal COVID-19 Project,” 11. 68 Chisaka, “SEP - Liberia COVID-19 Project,” 11-12; Kak, “SEP - Sri Lanka COVID-19 Project,” 15-16. BANK INFORMATION CENTER | MAR 2021 hotlines separate from a GRM.69 Though only five projects indicate that their GRMs will specially handle GBV/SEA/SH complaints, all 11 projects’ ESRSs point to the fact that there is a potential risk of some combination of GBV/SEA/ SH and VAC. Table 5 shows, however, that the risk comes up in different parts of the ESRSs in different ways. Four of the projects’ ESRSs mention the risk under “Social Risk Rating” in the “Environmental and Social Risk Classification” section as well as a risk in connection to “ESS1 Assessment and Management of Environmental and Social Risks and Impacts,” as something that could happen to women and children under self-isolation. Six projects mention the risks as being associated with ESS4 Community Health and Safety, and refer to the potential for GBV/SEA/SH to occur in workplaces. The Bangladesh project brings up GBV as a risk in the context of “ESS2 Labor and Working Conditions.”70 Furthermore, some ESRSs list “GBV/SEA/SH,” some just list “GBV/SEA,” and others list “SEA/SH.” In addition to the irregularities across the 11 projects, different documents prepared for the same project do not refer to potential risks of sexual and genderbased violence in a consistent manner. For example, the Burkina Faso ESRS indicates that SEA/SH are risks, but the SEP only describes the project’s GRM being equipped to handle GBV complaints.71 Since the mechanisms for avoiding the risks and handling the grievances of each of these issues may differ, it is important that terminology is used precisely and consistently. It is outside the scope of this report to assess whether all or parts of these projects are considered major civil works and whether the ESF Good Practice Note is applicable. It is also outside the scope of this report to assess whether or not they should have included fewer or more forms of sexual and gender-based violence as risks and whether or not the inconsistencies in terminology was intentional. Regardless, the Good Practice Note recognizes 69 As an example, the Uganda SEP says, “[T]he MoH will collaborate with the Ministry of Gender and other relevant actors to ensure the dissemination of information on available services for SGBV, use of established response hotlines and community outreach” notably to report cases of VAC and SEA. See: Borrowing Agency, “SEP - Uganda COVID-19 Project,” 9; Gordillo-Tobar, “SEP - El Salvador COVID-19 Project,” 8. 70 The Bangladesh project only says that GBV issues will be addressed in the bidding process for contractors with regards to “ESS2 Labor and Working Conditions” under “Specific Risks and Impacts” and a separate GRM is required for potential complaints associated with ESS2. See: “Environmental and Social Framework,” 34, par. 21; Mohammed-Roberts, “ESRS - Bangladesh COVID-19 Project,” 7. 71 Besarabic Bennett, “SEP- Burkina Faso COVID-19 Project,” 13; Besarabic Bennett, “ESRS - Burkina Faso COVID-19 Project,” 4-5. 15