See section E.1 in the main text for more information about relevant ESF requirements the mechanism “culturally appropriate and readily accessible to all project-affected parties.” 3. GRMs equipped to handle GBV/SEA/SH → Both the original and revised SEP indicate that the GRM will be equipped to handle GBV/SEA/SH See section D.2 in the main text for more information about relevant ESF requirements 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,”27 “all projects need to have a framework for properly handling SEA/ SH allegations.”28 Both the original and revised LCERP SEPs indicate that the GRMs will be equipped to handle GBV/SEA/ SH complaints. Both describe how the GRM will be equipped in this way differently. The original SEP states that “first responders will be trained with the basic skills to respond to disclosures of GBV” and that health workers will also be trained in the basic skills.29 It also states that “psychosocial support will be available to women and girls who may be affected by the outbreak and are also GBV survivors.”30 The revised SEP, on the other hand, simply says that the GRM will include “specific procedures for SEA/SH, such as confidential and/or anonymous reporting with safe and ethical documenting of SEA/SH cases.”31 The Bank provides a template SEP for Borrowers to propose “sample approaches” for fulfilling the requirements of a SEP.32 The template suggests that the resources for implementing stakeholder engagement should be included in the SEP, including confirmation that an adequate budget has been allocated for stakeholder engagement.33 While the original LCERP SEP did not include a specific SEP budget, the revised SEP estimates in the “Resources” section of the document that the budget for implementing the SEP and the operational cost of the GRM is $75,000. It specifies that this budget will come from the funding carved out for “component 4 (community engagement, risk communication and advocacy” for the project.34 The revised SEP does not, however, provide an itemized budget for the costs of staff and different forms of engagement, such as information disclosure and consultation. While the revised SEP improves upon the original by providing a budget, the lack of an itemized budget obfuscates whether “an adequate budget has been allocated for stakeholder engagement” and if there is enough funding to perform the necessary tasks to implement the SEP.35 There are reasons why it might make sense that the original and revised SEPs do not use consistent language to describe how the project will be equipped to handle GBV/SEA/SH. Perhaps, for instance, consultations at the beginning of project implementation clarified what would be most useful to stakeholders in how GRMs are equipped. If the SEPs are not consistent in their description, however, it is good practice for the revised SEP to provide an explanation for why elements of the mechanism described in the original SEP are not longer considered necessary to include. 2. Budgets for SEP implementation → The revised SEP provides a specific budget for SEP implementation 27 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. 28 See 6d under GPN in Annex 1; Grown et al., “Good Practice Note: Addressing SEA/SH,” 44, par. 116. 29 Chisaka, “SEP - Liberia COVID-19 Project,” 12. 30 Ibid. 31 “Revised SEP - Liberia COVID-19 Project,” 32. BANK INFORMATION CENTER | MAR 2021 32 33 34 35 “Template for ESS10,” 1 See 3o under ESS10 in Annex 1; “Template for ESS10,” 5 sec. 5.1. “Revised SEP - Liberia COVID-19 Project,” 39 See 3o under ESS10 in Annex 1; “Template for ESS10,” 5 sec. 5.1. 46