Labour Management Procedures (LMP) : World Bank Unleashing The Blue Economy of The Caribbean (UBEC)

World Bank
Unleashing the Blue Economy of the Caribbean (UBEC)
Labour Management Procedures (LMP)

Draft for Consultation
October 1, 2021
Contents
1. INTRODUCTION ............................................................................................................................... 2
2. PROGRAM DESCRIPTION................................................................................................................. 3
3. OVERVIEW OF LABOUR USE ON THE PROJECT ............................................................................... 6
4. ASSESSMENT OF KEY POTENTIAL LABOUR RISKS............................................................................ 8
5. OVERVIEW OF LABOUR RELATIONS AND OCCUPATIONAL HEALTH AND SAFETY LEGISLATION .. 10
6. RESPONSIBLE STAFF ...................................................................................................................... 16
7. OHS POLICIES AND PROCEDURES ................................................................................................. 16
7.1 OHS Purpose ..................................................................................................................... 16
7.2 Scope ................................................................................................................................. 17
7.3 OHS Measures /procedures .............................................................................................. 17
7.4 OHS Policy Dissemination and Awareness ........................................................................ 18
8 AGE OF EMPLOYMENT ................................................................................................................... 18
9 TERMS AND CONDITIONS OF EMPLOYMENT ................................................................................. 20
10 GRIEVANCE REDRESS MECHANISM .......................................................................................... 23
11. CONTRACTOR MANAGEMENT .................................................................................................. 25
12. PRIMARY SUPPLY WORKERS ..................................................................................................... 25
13. COMMUNITY WORKERS............................................................................................................ 25
ANNEX 1- TEMPLATE CODE OF CONDUCT ............................................................................................ 27
ANNEX 2 - List of available GBV services and points of service, including contact information for
participating countries .......................................................................................................................... 32
ANNEX 3- COVID-19 CONSIDERATIONS IN PROJECT IMPLEMENTATION ............................................. 35
LMP Resources ...................................................................................................................................... 46
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1. INTRODUCTION
Labour Management Procedures (LMP) for the World Bank Unleashing the Blue Economy of the
Caribbean (UBEC) program set out the approach to meeting the objectives of the World Banks’s
Environmental and Social Framework (ESF), specifically the objectives of Environmental and Social
Standards 2 (ESS2): Labour and Working Conditions and Occupational Health and Safety1. ESS2 is
designed to ensure World Bank-financed projects meet with the following six objectives:
1. Promote safety and health at work;

2. Promote the fair treatment, non-discrimination, and equal opportunity of project workers;
3. Protect project workers, including vulnerable workers such as women, persons with
disabilities, children (of working age, in accordance with this ESS) and directly-hired workers,
contracted workers, primary supply workers, and community workers, as appropriate;
4. Prevent the use of all forms of forced labor and child labor;
5. Support the principles of freedom of association and collective bargaining of project workers
in a manner consistent with national law; and,
6. Provide project workers with accessible means to raise workplace concerns.
The UBEC Environmental and Social Management Framework (ESMF) identifies key risks in the area
of labour and community health and safety. The procedures laid out in this document seek to
ensure that measures are in place to manage risks associated with employment under the project
and help to determine the resources necessary for effective planning and management.
The LMP identifies the different types of project workers that are likely to be involved and sets out
the way in which the different types of project workers will be managed. The LMP describes worker
characteristics, provides an overview of key potential labour risks, identifies relevant legislation that
relates to labour and occupational health and safety (OHS) in each country participating in the
project country. The LMP also establishes the minimum age of employment and identifies
procedures to ensure persons below the minimum age are not employed to the project. Finally, the
LMP describes the Grievance Redress Mechanism (GRM) available to project workers which will
include considerations for gender-based violence (GBV).
The LMP describes the OHS measure that will be established to protect project workers from
contracting COVID-19, as guided by the Bank’s interim note, “Covid-19 Considerations in
Construction and Civil Works Projects” and WHO guidance. A code of conduct (COC) for project
workers is suggested in Annex 1. The code addresses the need to include provisions on non-
discrimination and the prevention of GBV and Sexual Exploitation, Abuse and Harassment (SEAH) as
specified in the Bank’s GBV guidance note2.
The LMP is a living document and is meant to be updated throughout the project cycle.
1
See World Bank Template on Labour Management Procedure ESS2
http://pubdocs.worldbank.org/en/755121538513950752/Labor-Management-Procedures.docx ; and the
guidance -note- for borrowers for ESS2: Labor and Working Conditions
http://documents1.worldbank.org/curated/en/149761530216793411/ESF-Guidance-Note-2-Labor-and-
Working-Conditions-English.pdf.
2
World Bank. 2018. Good Practice Note Addressing Gender Based Violence in Investment Project Financing
involving Major Civil Works.
http://documents1.worldbank.org/curated/en/399881538336159607/Environment-and-Social-Framework-ESF-
Good-Practice-Note-on-Gender-based-Violence-English.pdf
2
2. PROGRAM DESCRIPTION
The Unleashing the Blue Economy of the Caribbean (UBEC) Program is to be implemented as a Series
of Projects (SOP) over a five to fifteen-year period, with each project implemented over a five-year
period as per projected country demand3. UBEC’s Proposed Development Objective (PDO) is to
strengthen the enabling environment for the blue economy and to enhance resilience of selected
coastal infrastructure in and across participating countries . The PDO serves as an overall framework
for strengthening the management and resilience of marine and coastal assets to stimulate select
OECS economies at the regional, national and community levels. In particular, participating countries
will benefit from improved competitiveness of their economies in three critical and interconnected
sectors: tourism, fisheries & aquaculture and waste management.
While the UBEC program challenges are regional in nature, addressing these will require
interventions and institution building at both the regional and national levels. Coordination among
participating countries is critical for enhancing synergies given their economic dependence on
tourism and their shared marine ecosystems and fishery resources, as well as mitigating coastal and
marine pollution.
The SOP approach enables countries to join the program when they are ready, and to participate at
different implementation levels within the same PDO framework. Investment projects to be initiated
in FY2022 are to be led by the governments of Grenada, Saint Lucia, Saint Vincent and the Grenadines
(SVG) and the OECS Commission. A second phase comprising at least one additional country-level
investment projects is expected to be initiated in FY2023-2025. These could involve Antigua and
Barbuda and Dominica, among others. Other Caribbean countries may participate from FY2024
onwards. The design of the second and subsequent phase of projects will consider the capacity of
institutions, technical competencies, and challenges, and will benefit from lessons learned from phase
one.
The phase 1 project in the SOP is designed to stimulate economic recovery and support marine and
coastal resilience in the three participating countries by strengthening the sustainability and
competitiveness of two critical, interconnected sectors – tourism and fisheries – and one underlying
enabling infrastructure service, waste management. These objectives are to be accomplished
through four program components.
COMPONENT 1: STRENGTHENING GOVERNANCE, POLICIES AND CAPACITY BUILDING FOR KEY

PRODUCTIVE SECTORS
This component, through its two sub-components, targets national and regional policies, strategies,
institutions, legal frameworks, and capacity building by the public sector necessary to support
economic recovery and jobs and to improve the management of natural assets contributing to the
regional marine environmental health and resilience.
Subcomponent 1.1 Strengthening Regional Policies, Institutions and Coordination: This

subcomponent will support the harmonization of regulations and government procedures, while
boosting regional cooperation to allow for stronger economies of scale in the region. With the OECS
Commission playing a strategic role in strengthening regional integration and helping to manage
shared economic resources in the interest of OECS countries, the regional approach will address
potential transboundary issues and increase the impact of national interventions. The regional
3
The term “Program” in this document refers to a Series of Projects (SOP). The SOP approach provides
flexibility for considerable economies of scale and facilitates positive spillovers that accommodate for financial
constraints.
3
approach is essential to address transboundary issues such as fisheries, intra-regional tourism, and
for phasing out single-use plastics. This subcomponent will support the update of regional policies
on tourism, fisheries, and waste management and marine litter, as well as the development and
management of regional knowledge and data systems and regional knowledge exchanges.
Subcomponent 1.2 Strengthening National Policies, Institutions and Capacity Building: This
subcomponent is designed to strengthen governance and the regulatory framework of tourism,
fisheries and aquaculture, and waste management at the national level in the three participating
countries. This will be achieved through (i) support for sectoral standards, policies, and/or
operational guidelines, (ii) policy measures aimed at increasing value added investments and
reducing plastic pollution and enhancing domestic waste management, and (iii) capacity
development to ensure the region has access to a skilled workforce.
COMPONENT 2 - SCALE UP ACCESS TO FINANCE AND INFRASTRUCTURE INVESTMENTS IN

THE BLUE ECONOMY
Delivered through two subcomponents, this component includes an innovative financing mechanism
to enable private sector-led growth and direct investments into economic activities that enhance
ocean health and resilience leading to an increase in employment and greater GDP contribution
from ocean assets.
Subcomponent 2.1-Scale Up Access to Finance to Small and Medium Enterprises (SMEs) and
Fisherfolk Communities: The project will focus on two financing mechanisms under this
subcomponent.
The Regional SME matching grants program is designed to finance business development services
(BDS) and matching grants to increase the productivity, job creation, and upgrade the capabilities of
SMEs and communities within the blue economy value chains for the region’s tourism, fisheries and
aquaculture, and waste management sectors. The matching grants will be provided both at the
individual firm level (Window 1) and at the value chain group level (Window 2). Specific attention
will be given to assisting youth and women-owned SMEs and those that work within regional supply
chains to address and build business ideas out of critical regional problems such as plastics or
sargassum. Eligibility criteria will ensure SMEs with commercial viability adopt an approach of
building back better, respecting the integrity and resilience of the regional coastal ecosystems. The
program will be managed at the regional level by the OECS Commission to foster greater regional
collaboration..
Expansion of the regional climate-risk insurance for fisheries focuses on the Caribbean Ocean and
Aquaculture Sustainability Facility (COAST) fisheries risk insurance scheme. The COAST insurance
product supports governments’ efforts to rapidly channel financial resources to those fishers most
impacted by extreme weather events, by providing governments with funding to cover the most
immediate needs of fishers following a natural disaster or extreme weather event. COAST enhances
inclusiveness by covering, among others, fish vendors and processors, most of whom are women.
Through formal registration in the scheme, these women, for the first time, will be insured to support
their livelihoods. On a pilot basis, the Caribbean Catastrophe Insurance Facility (CCRIF) has made the
COAST product available to Grenada and Saint Lucia, for the 2019/20, 2020/21 and 2021/22 policy
years. This Project UBEC will now extend this risk insurance product to SVG and continue to support
Grenada and Saint Lucia to scale up efforts in the application of this insurance product.
Subcomponent 2.2 Scale Up Infrastructure Investments for Economic Resilience and Ocean Health:
This subcomponent will support direct investments in resilient coastal infrastructure that generate
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jobs in the short-term and lay the foundation for long-term recovery through investments that help
build a low-carbon, less polluting, more sustainable and resilient coastal economy that is adaptive to
climate change. Public investments supported by this sub-component will serve to de-risk private
investment by improving, restoring or preserving healthy and functioning marine ecosystems, and
measures to prevent further degradation of key marine/coastal hotspots. This activity will also
finance pre-feasibility studies, climate risk screening, cost-benefit analysis, environmental and social
impacts, and public consultations.
COMPONENT 3: CONTINGENT EMERGENCY RESPONSE COMPONENT (CERC)

This component will support the capacity of the participating countries to rapidly respond in the
event of a future eligible crisis or emergency defined as “an event that has caused, or is likely to
imminently cause, a major adverse economic and/or social impact associated with natural or man-
made crises or disasters.” Such events may include a disease outbreak such the COVID-19 pandemic.
This component would draw from uncommitted loan resources from other project components to
cover the emergency response.
COMPONENT 4 - PROJECT MANAGEMENT, COMMUNICATION AND REGIONAL COORDINATION

The objective of this component is to ensure effective project implementation, monitoring of
activities and final project evaluation. The component will finance the expenditures of Project
Implementation Unit (PIU) in each country related to project coordination and management;
compliance with environmental and social safeguards; monitoring, evaluation, and impact
assessment; data collection; fiduciary administration, accounting and financial/technical audits;
stakeholder and citizens’ engagement mechanism, including a grievance redress mechanism;
communications; and regional coordination.
Institutional Structure for Project Implementation

The program will be implemented at both the national and regional levels, under a coordinated
framework. The implementation arrangements are designed to ensure clear ownership of the
project components and to strengthen regional and inter-ministerial coordination among and within
the participating countries. The implementation of this ESMF requires involvement of several
stakeholders each with different roles and responsibilities to ensure sound environmental and social
management during project implementation.
Phase 1 national participants will include the governments of Grenada, Saint Lucia and Saint Vincent
and the Grenadines, with the OECS Commission as the regional entity. At the national level, the
Ministry of Implementation (MOIID) in Grenada, the Ministry of Finance (MoF) of Saint Lucia, and
the Ministry of Tourism, Civil Aviation, Sustainable Development and Culture (MTSD) of Saint Vincent
and the Grenadines will be responsible for project execution, in close collaboration with the
implementing line ministries for each component. At the regional level, the OECS Commission will be
the institution principally responsible for regional coordination, knowledge exchange, and providing
additional capacity to project implementation and monitoring of impacts.
The Regional Project Steering Committee (PSC) will conduct the overall management/oversight of
the project. The PSC would be composed of a Permanent Secretary-level representative from the
Ministry of Finance from each country, and a representative from the OECS Commission (Director
General or delegate). The PSC will be responsible for: 1) oversight of annual workplans, 2) regional
procurement decisions, 3) discussion and agreement on regional policy issues related to the blue
economy, 4) oversight of regional fiduciary matters; and 5) oversight of reporting requirements from
National PIUs.
5
A dedicated Project Implementation Unit (PIU) will be established within the OECS Commission and
within each participating country. The regional PIU will be led by a full-time Project Manager and will
include a full-time M&E specialist, a full-time procurement specialist, a dedicated technical specialist
for each of the three project sectors, an environmental safeguards specialist and a social safeguards
specialist.
Each country will have a national PIU responsible for implementing national-level activities and
coordinating with relevant national ministries. National level PIUs will have a full-time project
manager that will be housed at the Ministry of Implementation for Grenada, the Ministry of Finance
for SLU, and the Ministry of Tourism for SVG. The full-time project manager will be responsible for
ensuring the delivery of all national activities, including obtaining the necessary approvals for
procurement and safeguards documents, data collection and reporting on national M&E indicators.
In each country, the National Ocean Governance Committee will serve as the National Blue Economy
Technical Committee (NBETC) for the Project. The NBETC will advise the national PIUs on the
technical implementation and contracting of activities related to the areas of Tourism, Fisheries and
Aquaculture, and Solid Waste Management, and the Regional PIU on policy issues. The Regional
Ocean Governance Team (OGT) will work to facilitate coordination between the governments and
regional institutions and help address strategic issues impacting project implementation. It will also
be responsible for oversight of the regional activities and ensure coordination with other OECS
countries not participating in the Project.
Responsibilities of the national E&S safeguards specialists will include approval of national ESF
documents and the supervision of all national-scale safeguard matters, including monitoring and
reporting on national scale project and sub-project compliance with ESF instruments. E&S
safeguards specialists will also participate in national scale sub-project screening and risk
assessment. E&S safeguards specialists will benefit from technical support from regional
counterparts contracted by the OECS Commission.
The regional PIU will provide extensive support to the national PIUs, including the drafting of ESF
instruments and preparation of bidding documents, though the approval of all ESF documents and
supervision of the application of the ESF will remain the responsibility of the national PIU. For
complex procurement activities, the Project will also use a Hands-on Expanded Implementation
Support (HEIS), in which the WB will provide specific procurement support, though the approval of
bidding documents, bid evaluations and awards will still be the responsibility of the regional or
national PIUs. For the regional SME grant program, the regional PIU at the OECS Commission will
manage it in close consultation with national PIUs.
3. OVERVIEW OF LABOUR USE ON THE PROJECT

The LMP applies to all project workers whether full-time, part-time, temporary, seasonal or migrant,
hired in relation to any of the project’s components. As per ESS2, the LMP is applicable to four types
of workers: direct workers, contracted workers, primary supply workers and community workers
(See Box 1 for definition). While the labour requirements for the project have not yet been fully
defined, the LMP anticipates the reliance on all four of these types of workers.
The regional PIU within the OECS Commission will be led by a full-time Project Manager and will
include a full-time M&E specialist, a full-time procurement specialist, a dedicated technical specialist
for each of the three project sectors, an environmental safeguards specialist and a social safeguards
specialist. Each national PIU will be composed of, at a minimum, a project manager, a financial
6
management specialist, an environmental safeguards specialist and a social safeguards specialist.
Based on the project components, it is expected that the project will engage consultants to carry out
capacity building activities to support tourism and fishing sector companies to market new products
and reach new markets, undertake greening operations to address climate adaptation and mitigation,
and adopt health and safety protocols, among others.
Consultants will also be engaged to conduct the studies and TAs for the strategic infrastructure
investment transactions under subcomponent 2.2. It is expected that the project will also engage local
contractors to complete any civil work associated with funded blue economy infrastructure.
Depending on the nature of the sub-project, contractors or beneficiaries may engage community
workers.
Box 1 World Bank Environmental & Social Framework Definitions of Categories of Workers
The World Bank ESF Guidance note on ESS2 Labour and Working Conditions provides the following
definitions of workers4:
A “direct worker” is a worker with whom the project has a directly contracted employment
relationship and specific control over the work, working conditions, and treatment of the project
worker.
Where government civil servants are working in connection with the project, whether full-time or
part-time, they will remain subject to the terms and conditions of their existing public sector
employment agreement or arrangement, unless there has been an effective legal transfer of their
employment or engagement to the project.
A “contracted worker” is a worker employed or engaged by a third party to perform work or provide
services related to the core functions of the project, where the third-party exercises control over the
work, working conditions, and treatment of the project worker.
A “primary supply worker” is a worker employed or engaged by a primary supplier, providing goods
and materials to the project, over whom a primary supplier exercises control for the work, working
conditions, and treatment of the person.
A “community worker” may take the form of labour provided by the community as a contribution to
the project in support of project activities fostering community-driven development. For example,
this could take the form of participation in the construction of small-scale community infrastructure.
Project Labour Requirements
Direct Workers: Direct workers will be hired by the PSC and PIUs, employing consultants and
support staff who are working on a contractual basis. Terms and conditions of support staff and
consultants are guided by National Labour Law.
Contracted Workers: Based on the requirement in every component the PSC and PIUs will employ
contractors who will hire contracted workers based on their level of skills and project needs. If
agreed with the PSC/PIU, sub-contracts of the work could be given. Sub-contractors recruited may
4
See World Bank. 2018. ESF Guidance Note on ESS2 Labor and Working Conditions section on Scope of
Application, paragraphs 4-7.
7
supply labourers as per the agreed terms and conditions. The regional grants activity under sub-
component 2.1 and direct investment activities under 2.2 may include the provision of jobs through
labour intensive civil work to be implemented by project contractors. In addition to relevant national
laws and World Bank policies, contractors will be required to ensure that the World Bank’s interim
note on “COVID-19 Considerations in Construction/Civil Works Projects” (Annex 2) is followed in
contracting project workers.
Contracted workers are eligible to work for a contract period fixed by the PIUs, and then recruited by
project contractors or beneficiaries. Their contracts will be renewed, if required, based on
satisfactory services.
Primary Supply Workers: Based on the requirement in every component primary supply workers will
be recruited by the suppliers as required. Their tenure of service will be based on supplies as
procured. Generally, the timing of labour requirements will be based on the project implementation
schedule to be developed for the project.
Community Workers: Any Community Workers participating in the project or sub-project activities
will participate within the framework of individual or community agreements. As with other types of
project workers, supervision of Community Workers will include checking the safety of the work
environment, confirming the age of community workers, and ensuring the terms of the agreements
governing the work are in compliance with ESS2.
For all classes of workers, the PIUs will make every effort to ensure that no children or forced labour
are recruited and supplied as workers. Monitoring will also be used to ensure compliance with the
project CoC. Any deviation from the CoC identified by the PIUs will result in action as prescribed in
the contract/ agreement and consistent with the LMP.
4. ASSESSMENT OF KEY POTENTIAL LABOUR RISKS

The key labour and OHS risks which may be associated with the project are outlined below as well as
proposed mitigation measures which will be implemented to address:
(a) identification of potential hazards to project workers, particularly those that may be life
threatening.
(b) Provision of preventive and protective measures, including modification, substitution, or
elimination of hazardous conditions or substances.
(c) Training of project workers and maintenance of training records.
(d) Documentation and reporting of occupational accidents, diseases and incidents.
(e) emergency prevention and preparedness and response arrangements to emergency situations.
(f) Remedies for adverse impacts such as occupational injuries, deaths, disability and disease.
Table 1 Summary of Project Risks and Proposed Mitigation Measures

Key identified Description Proposed mitigation
labour risk measures
1. Occupational Includes risk of exposure to a number of Conduct regular awareness
Health & hazards that could result in illness, injury or raising sessions reaching
Safety death. Field work in coastal ecosystems project workers and affected
carries a risk of drowning. Activities involving communities as well as
travel carry a risk of road traffic accidents or adequate OHS training.
air accidents, in addition to exposure to Use of adequate protective
infectious diseases, including COVID-19. gear.
Project workers may face risks created by
relatively high levels of crime and violence
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present in some of the jurisdictions in which
the project will be implemented.
Project workers throughout the region are
exposed to an elevated risk of natural
disasters especially during hurricane season.
2. Unfair Project workers could be subjected to unfairRequirement for fair
treatment or treatment or discrimination on the basis of recruitment policies and
discrimination personal characteristics unrelated to job enforcement of zero
of project requirements, such as race, gender, religiontolerance to discrimination.
workers and sexual orientation. These risks apply toTo be addressed through
workers on sub-projects, as well as staff awareness, monitoring and
employed and engaged by the PIUs. enforcement of compliance
with the CoC.
3. Physical, Project workers could be exposed to physical, The project will adopt a
psychological psychological or sexual abuse. Risks include zero-harassment policy for
or sexual both physical forms of abuse (such as all workers, reflected in the
abuse of violence and sexual assault) and non-physical CoC and to be broadcast to
project forms (such as verbal abuse, bullying and all workers through various
workers unwanted sexual attention). These risks apply media and formats.
to workers on sub-projects, as well as staff The CoC will be integrated
employed and engaged by the PIUs. into contracts of all
employees, and the project
GRM will be available to all
workers.
Awareness raising and
training will be conducted
for all employees reviewing
the terms and conditions of
these procedures and tools.
4. Gender-based GBV refers to inappropriate or criminal All project workers’
violence (GBV) behaviour, such as sexual harassment of a contracts will include a Code
person, exploitative sexual relations, and of Conduct with GBV
illicit sexual relations with minors from the provisions.
local community. GBV also includes any PIUs will monitor
exploitative sexual relationships and human compliance with the CoC
trafficking whereby women and girls are including GBV provisions.
forced into sex work. Project workers will be
provided GBV orientation.
GBV considerations are
included in the GRM for
project workers, in the form
of maintaining a list of GBV
service providers in each
implementing country.
5. Transmission Activities under all project components Adherence to World Bank’s
of COVID-19 involve travel to and/or within the Caribbean interim note on “COVID-19
or other Islands, including between countries and Considerations in
communicable between urban centres and rural areas. Construction/Civil Works
diseases Project staff and stakeholders may travel to Projects”, WHO guidance,
9
participate in gatherings of large numbers of and compliance with
people, including workshops, seminars, national laws and
community meetings and training events. regulations.
Such activities have an elevated risk of PIUs will prepare Covid-19
transmission of COVID-19 or other transmission prevention
communicable diseases. There is a particular plan which includes
risk of transmission of disease to remote procedures to be followed if
coastal communities that may be particularly a project worker contracts
vulnerable, due to underlying health the disease.
conditions and lack of access to healthcare.
6. Child and While the risk exists, the probability of the Certification of labourers’
Forced Labour incidence of child labour or forced labour is age using legally recognized
minimal as the project will generally requires documents.
technical staff with skills that require Awareness raising of the
experience and education. COC, careful monitoring, and
Hiring youth and children under the age of strict enforcement of
18 risks exposure to hazards and may compliance.
interfere with the child’s education or be Where persons under the
harmful to the child’s health or physical, age of eighteen but above
mental, spiritual, moral or social dement. the legal minimum age are
hired, the project will
maintain a register
containing the dates of their
births in keeping with the
Employment Act of
participating countries.
5. OVERVIEW OF LABOUR RELATIONS AND OCCUPATIONAL HEALTH

AND SAFETY LEGISLATION
Project workers are expected to be based in each participating country. Grenada, Saint Lucia and
Saint Vincent and the Grenadines are expected to participate in phase 1 projects of the UBEC
program. In each of these jurisdictions, relevant labour laws are those related to conditions of
employment (e.g., minimum wage, hours of work, minimum age, vacation and sick pay, maternity
leave), anti-discrimination (i.e., protection from discrimination on the grounds of protected
characteristics), industrial relations (e.g., trade union establishment, collective bargaining,
arbitration of disputes, etc.) and occupational health and safety (OHS). The key aspects of national
policies and legislation related to these, as well as any gaps between national legislation and ESS2,
are summarized in the following table and discussed below in greater detail.
Table 2 Summary of National Legal Frameworks and Gaps related to ESS2

ESS2 requirement Gaps between legislation and ESS2 Mitigation measures
Conditions of employment Each of the project countries By default, project
ESS2 requires that no child establishes a minimum legal age for workers will be
under the legal minimum age or employment of 14 or older. required to be a
the age of 14 (whichever is minimum age of 18.
lowest) be employed or
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engaged in connection with the There are gaps in the legal protections ESS2 permits children
project. given to children under the age of 18 under the age of 18
from involvement in hazardous work. to be employed or
ESS2 also requires that no child engaged only where
under the age of 18 may be As a result of shortcomings with the permitted by law and
employed or engaged in legal framework and its only in exceptional
connection with work that is implementation in the project circumstances. Hiring
likely to be hazardous, interfere countries, it is unfortunately the case of workers under the
with the child’s education or be that children are still engaged in the age of 18 will be
harmful to the child’s health or worst forms of child labour, including subject to rigorous
physical, mental, spiritual, moral in agriculture and commercial sexual scrutiny.
or social development. exploitation. The Employment of
Women, Young Persons and Children
Act of SVG has a similar gap, with
discrepancies between the minimum
age for work and the maximum age
for compulsory education, leaving
children without adequate protection
from child labour.
Anti-discrimination including Anti-discrimination legislation, in one The project will
Gender Based Violence and form or another, exists in all project implement workplace
Sexual Harassment5 countries. General guarantees of policies that meet the
ESS2 requires that decisions equality are provided in the requirements of ESS2
relating to the employment or constitution. The protected categories in relation to anti-
treatment of project workers defined by law are not, however, discrimination. These
not be made on the basis of always as comprehensive as those will be included in the
personal characteristics required by ESS2. For instance, while CoC which will be a
unrelated to inherent job discrimination on the grounds of race, part of the contract
requirements (e.g., gender, religion, place of origin or sex is for all project
race, religion, sexual prohibited in all countries, such workers.
orientation) but be based on the protections are not universal for age,
principle of equal opportunity disability and, especially, sexual
and fair treatment. orientation.
All three countries have legislation

that criminalizes GBV, through the
Criminal Code and Domestic Violence
Act. However, while sexual
harassment is a criminal offence and
recognized as unlawful discrimination
in Saint Lucia, neither Grenada nor
SVG currently have legislation which
specifically deals with sexual
harassment.
Industrial relations Freedom of assembly, freedom of The LMP and
ESS2 respects the role of legally association, collective bargaining and associated CoC will
established workers’ industrial relations are guaranteed be shared with
organizations and legitimate through the Constitutions and employers and
5
See: https://caribbean.unwomen.org/en/caribbean-gender-portal
11
workers’ representatives. These regulated through the labour relations workers’
will be provided with legislation in all three countries. organizations.
information needed for These include Grenada’s Labour
meaningful negotiation in a Relations Act, Saint Lucia’s Essential
timely manner. Services Act, and SVG Trade Union
Act.
Occupational health and safety Legislation and regulations necessary Information
ESS2 imposes general to develop and implement procedures dissemination and
requirements related to to establish and maintain a safe awareness raising
occupational health and safety working environment, including that regarding the LMP
that apply to all project workers. workplaces, vehicles, equipment and will be prioritized
processes under their control are safe from project
and without risk to health are inception, and
generally adequate. However, the designed to reach all
level of awareness of the importance project employers
of OHS issues among employers and and workers.
workers is limited. In the absence of
No known legislation or regulations legislation, employer
exist explicitly addressing OHS for OHS obligations
community workers. regarding community
workers will be
guided by this LMP.
Labour Relations and OCH Legislation in Grenada

The overarching major national labour legislation in Grenada is the Employment Act of 1999 which
regulates the terms and conditions of employment and contains provisions on the establishment
and functions of the Department of Labour. The guiding principles reside on the prohibition of
forced labour, discrimination, equal pay for equal works, as well as remedies for infringements of
rights. The Employment Act strictly prohibits discrimination of employees based on race colour,
national extraction, social origin, religion, political opinion, sex, marital status, family responsibilities
or disability. An employee also has the right, by law, to remove himself or herself from a work
situation which he or she reasonably believes presents an imminent or serious danger to life or
health.
The Employment Act makes it mandatory for employers to furnish employees with written
particulars of employment, stating hours of work, wages, leave entitlements, job description,
grievance procedures, benefits if any among others. Specifically, Part VI deals with the matter of
hours of work and continuity of employment and will apply to the risk of extended hours of work as
perceived as a minor risk to the project. Part VII speaks to Protection and Regulation of wages, Part
VIII - Leave entitlements and other benefits and Part IX expounds on discipline and termination of
employment.
The Factories Act is the main law governing occupation safety and health, and there are a number of
detailed regulations developing the main Act, including the Factories (Sanitary Accommodation)
Regulations, Factories (Welfare) Regulations, Factories (Electricity) Regulations, and Factories (Lifting
Tackle) Regulations.
Under the Occupational Safety and Health Convention, 1981 (No. 155), 155, the Government of
Grenada takes account of the following main spheres of action in so far as they affect occupational
safety and health and the working environment:
12
(a) design, testing, choice, substitution, installation, arrangement, use and maintenance of the
material elements of work (workplaces, working environment, tools, machinery and equipment,
chemical, physical and biological substances and agents, work processes);
(b) relationships between the material elements of work and the persons who carry out or supervise
the work, and adaptation of machinery, equipment, working time, organisation of work and work
processes to the physical and mental capacities of the workers;
(c) training, including necessary further training, qualifications and motivations of persons involved,
in one capacity or another, in the achievement of adequate levels of safety and health;
(d) communication and co-operation at the levels of the working group and the undertaking and at
all other appropriate levels up to and including the national level;
(e) the protection of workers and their representatives from disciplinary measures as a result of
actions properly taken by them in conformity with the policy referred to in Article 4 of this
Convention.
Table 3 Grenada National Labour Legislation6

Legislation Description
Employment Act of 1999 regulates the terms and conditions of employment and contains
provisions on the establishment and functions of the
Department of Labour
The Factories Act of 1973 the main law governing occupation safety and health
implemented by means of a number of detailed regulations.
The Accidents and Regulates notification of accidents and occupational diseases.
Occupational Diseases
(Notification) Act, 1951
Right of Association Under the Convention, the Government of Grenada commits to
(Agriculture) Convention, 1921 ensure that all those engaged in agriculture enjoy the same
(No. 11) rights of association and combination as industrial workers, and
to repeal any statutory or other provisions restricting such rights
in the case of those engaged in agriculture.
Equality of Treatment Grants nationals of any other national Convention signatories
(Accident Compensation) who suffer personal injury due to industrial accidents happening
Convention, 1925 (No. 19) in its territory, or to their dependants, the same treatment in
respect of workmen's compensation as it grants to its own
nationals.
Occupational Safety and Commits signatories to formulate, implement and periodically
Health Convention, 1981 (No. review a coherent national policy on occupational safety,
155). occupational health and the working environment, the aim of
which is to prevent accidents and injury to health arising out of,
linked with or occurring in the course of work, by minimising, so
far as is reasonably practicable, the causes of hazards inherent
in the working environment.
Labour Relations and OCH Legislation in Saint Lucia

One primary piece of legislation guides and regulates the terms and conditions of employment in Saint
Lucia. Saint Lucia Labour Code No. 37 of 2006 makes it mandatory for employers to provide employees
with written details of employment stating, hours of work, leave entitlement, job description,
grievance procedures, benefits, health and safety etc. Within this legislation there are provisions
relating to: Fundamental principles of employment-Part II; Contracts of employment-Division 1; Hours
6
https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:11200:0::NO::P11200_INSTRUMENT_SORT,P11200_COUNTRY_ID:2,103320
13
of Work-Division 3; Wages and minimum wages-Division 4&5; Leave entitlements (annual leave, sick
leave, maternity leave, bereavement leave etc.)-Divisions 6, 7 and 2; Employment of Children and
Young persons-Division 9; Termination of Employment-Division 10; Duties of Employers, workers and
other persons-Part IV Division; Occupational Health and Safety-Part IV; Equality of opportunity and
treatment in employment-Part V Division 1,Trade Unions and employers organizations-Part VII.
Part II of the Labour Code under Fundamental Principles of Employment (Division 7) states that “an
employer shall not discriminate against any employee on the grounds of race, colour, sex, religion,
national extraction, social origin, ethnic origin, political opinion or affiliation, age, disability, serious
family responsibility, pregnancy, marital status or HIV\AIDS, in respect of recruitment, training, work
facilities or service, promotion, terms and conditions of employment or benefit arising out of the
employment relationship”. The Code also makes provision on how the matter of discrimination can
be addressed.
Project workers will be paid on a regular basis as required by national law and labour management
procedures. Deductions from payment of wages will only be made as allowed by national law or the
labour management procedures, and project workers will be informed of the conditions under which
such deductions will be made. Project workers will be provided with adequate periods of rest per
week, annual holiday and sick, maternity and family leave, as required by national law and labour
management procedures.
Part four of the Saint Lucia Labour Code speaks to occupational health and safety in the workplace.
Under Part four, Divisions 1-4 provides for preventative health measures, protective devices and
equipment, medical examinations, notification of employment injuries and diseases, and training.
The Labour Code obligates the employer to ensure the safety and health of all employees and to
mitigate risk of exposure to any hazards in the work environment. Division three of the Code clearly
outlines the procedures to be followed in relation to notification of accidents, occupational diseases
and other diseases. Division four specifically speaks to the responsibilities of employers, employees
and other persons in adhering to health and safety regulations. The Code also clearly outlines the
circumstances where employees may refuse to work on health and safety grounds and the
procedures for how such matters should be addressed.
Table 4 Saint Lucia National Labour Legislation

Saint Lucia Labour Code of Establishes fundamental principles of employment, including
Saint Lucia (2006; amended) with regards to terms and conditions, occupational health and
safety, equal opportunities and industrial relations. The code
prohibits employment of children and young persons below the
minimum school leaving age.
Saint Lucia Education Act Sets the minimum school leaving age at 15.
(1999)
Saint Lucia Equality of Provides for protection against unlawful discrimination on
Opportunity and Treatment in grounds of race, sex, religion, colour, ethnic origin, family
Employment and Occupation responsibilities, pregnancy, marital status, or age, and places
Act (2000) restrictions on work and employment of minors.
Saint Lucia Minimum Wages Establishes process for setting minimum wages for workers in
Act (1999; amended) particular sectors or industries.
Saint Lucia Employees Covers all aspects of occupational health and safety, including
(Occupational Health and providing for preventive health measures, protective devices and
Safety) Act (1985) equipment.
14
Labour Relations and OCH Legislation in Saint Vincent and the Grenadines
Labour legislation in Saint Vincent and the Grenadines, is composed, among others by the Wages
Councils Act of 1953, providing for the establishment of wages councils and the making of wages
council orders and the Trade Unions Act of 1950, provides for the establishment and regulation of
trade unions. Requires wages to be paid by the employer to the worker only in money and the
payment of wages is to be made at intervals not exceeding fourteen days. More recent legislation
includes the Protection of Employment Act of 2003 and Equal Pay Act of 1994.
National legislation states that an employer shall not terminate the services of an employee on any
of the following grounds: i) Trade union membership or participation in trade union activities outside
working hours or, with the consent of the employer, within working hours; ii) Seeking office as, or
acting as the capacity of, an employee representative, iii) Making a complaint or participating in
proceedings against an employer involving an alleged violation of laws and regulation; iv) . Race,
colour, sex, marital status, pregnancy, religion, political opinion, nationality or social origin; v)
Reasonable absence from work due to family emergencies or responsibilities; vi) Absence from work
during maternity leave as certified by a medical practitioner vii) Absence from work due to injury or
illness provided that the employee submits a medical certificate to his employer by the third day of
absence, and viii)Absence from work in the performance of jury service as required by law.
Labour occupational health and safety in Saint Vincent and the Grenadines, in part is enforced by the
Environmental Health Services Act of 1991, the 1955 Factories Act and the Accidents and
Occupational Diseases (Notification) Act of 1952.
Table 5 Saint Vincent and the Grenadines National Labour Legislation

Wages Councils Act Provides for the establishment of wages councils and the making of
(1953) wages regulations addressing inter alia minimum wage, hours of work,
overtime, vacation and sick pay, maternity leave and health and safety.
Trade Unions Act Provides for the establishment and regulation of trade unions.
(1950)
Trade Disputes This Acts provides for the establishment of an arbitration tribunal and a
(Arbitration and board of inquiry in connection with trade disputes and to make
Inquiry) Act (1940) provision for the settlement of such disputes, and for the purpose of
enquiring into economic and industrial conditions in SVG.
Protection of Provides for maintenance of good relationships between employers and
Employment Act (2003) employees, and addresses matters of severance and settlement of
disputes.
Equal Pay Act (1994) This Act provides for the removal and prevention of discrimination,
based on the sex of the employee, in the rates of remuneration for
males and females in paid employment, and for all incidental matters.
Employment of Foreign The Act Regulates the employment of foreign nationals and
Nationals and Commonwealth citizens in SVG.
Commonwealth
Citizens Act, 1973
Constitution of Saint Establishes right of protection from discrimination on grounds of sex,
Vincent and the race, place or origin, political opinions, colour or creed.
Grenadines (1979)
Factories Act (1955) Part II provides for health, safety, welfare and special protective
measures in certain workplace settings.
Employment of Establishes the legal age of a child as under 14 and prohibits
Women, Young employment of children in certain settings. This Act regulates the
15
Persons and Children employment of women, young persons and children in industrial
Act (1935) undertakings and on ships in accordance with the following
International Labour Organization Conventions: Minimum Age
(Industry) Convention (Rev.) 1937; Night Work of Young Persons
(Industry) Convention 1919; Night Work (Women) Convention 194 .
Employers and Requires wages to be paid by the employer to the worker only in money
Servants Act, 1937 and the payment of wages is to be made at intervals not exceeding
fourteen days.
Environmental Health Provides for the regulation of activities that may affect public health
Services Act (1991) and the environment.
Public Health Act, 1997 This Act regulates environmental health issues, including monitoring of
communicable diseases, in SVG and provides remedies for same.
Public Health (COVID– This Statutory Rule and Order sets out restrictions/rules for public
19) Rules, 2021 gatherings (including at bars, restaurants, nightclubs, outdoor
functions) and penalties for contravention of these rules/restrictions.
General Guidelines for These guidelines outline what is expected of organisations and their
Organisations: Safe employees and are applicable regardless of the nature of the business
Working During the or service provision or size or complexity. They include practical
COVID–10 Pandemic – examples for different types of organisations to help determine the
SVGNS 85:2020 actions which can be taken to make workplaces safer.
Accidents and places a legal obligation on the employer to inform the Labour
Occupational Diseases Commissioner in writing on the prescribed form, any accident involving
(Notification) Act, 1952 any worker that arises out of and in the course of employment and
which causes loss of life or serious bodily injury or disables a worker.
The employer is also obligated to inform the Labour Commissioner on
any occupational disease which he reasonable believes or suspects to
have occurred among workers employed by him.
6. RESPONSIBLE STAFF
Project workers will be engaged and managed either directly by national level PIUs or by contractors
or beneficiaries delivering sub-project activities. The project manager and the national level PIUs will
be responsible for the overall management of all project workers and contractors and
subcontractors. Direct responsibility for occupational health and safety (OHS), training of workers,
and addressing worker grievances will rely on the party hiring project workers, contractors and
subcontractors.
7. OHS POLICIES AND PROCEDURES

Mitigation measures responding to the risks related to project labour and OHS conditions will
incorporate standardized clauses in contract documents so that the contractors will be aware of
their obligations under the project. The national level PIUs will ensure compliance of the following
clauses, including compliance by contractors and beneficiaries of project technical assistance and
grants hiring project workers of any type. Employment Contracts will be prepared by each employer,
in compliance with the policies and procedures laid out in the LMP.
7.1 OHS Purpose

The primary purpose of these OHS measures is the health and safety of any and all project workers
at work. The measures also establish and define the authority for the OHS and associated safety
16
systems. These measures will be enforced on all activities of the PIUs, project contractors and sub-
contractors and project beneficiaries through contractual arrangements as is appropriate.
7.2 Scope
Occupational health and safety (OHS), commonly referred to as occupational safety and health,
occupational health, or workplace health and safety, is concerned with the safety, health, and
welfare of people at work. Safety is defined as “the well-being of project employees whilst at work
or carrying out work duties”.
OHS Management System is the standards, policies, guidelines, that address project worker's safety,
monitoring and evaluation of safety, worker's health, work and general environment.
7.3 OHS Measures /procedures

The obligations of the project under the OHS policy includes the following:
 Compliance with all national and international OHS legislation that are applicable to the
participating country governments and the World Bank;
 Compliance with the Environmental and Social Standards of the World Bank;
 World Bank Environmental Health and Safety (EHS) Guidelines7
 Prevention of injury and ill health of all project workers;
 Establishment of safety systems, processes and performance;
 Continuous improvement of Safety Systems;
 Management and mitigation of adverse environmental and social impacts;
 Prevention of use of faulty equipment or sub-standard equipment.
 Environmental and Social Incident Response Toolkit (ESIRT)8
The project will commit to safety considerations in the conduct of all its activities and that of
contractors, sub-contractors and beneficiaries.
The project will provide systems, processes, procedures, the necessary safety equipment and gears,
and training for all project employees so that all activities are conducted in a safe environment.
Workers will be responsible, subject to their roles, for the maintenance of a safe environment
including the assessment of risks and actions to mitigate minimize and manage risks to the safety of
the work environment.
The project will develop and implement systems, processes, policies, and services that are national
and international in compliance with national and international legal requirements including
industry standards and best practices in relation to safety.
Workers at all levels have the authority to stop any activity they consider to be a danger to
themselves or other workers, the public or the environment. Workers in this situation must rely on
the project’s GRM, which lays out procedures and timeframes for resolution. The LMP also requires
incidents and accidents to be logged and reported by the PIU Project Manager to the Regional PIU.
There will be no retaliation to project workers for stop-work whistle blowing.
7
http://documents1.worldbank.org/curated/en/157871484635724258/pdf/112110-WP-Final-General-EHS-
Guidelines.pdf
8
http://documents1.worldbank.org/curated/en/794121486383424061/pdf/112174-WP-ESMS-Toolkit-
General-PUBLIC.pdf
17
Each environmental safeguards specialist and social safeguards specialist attached to each PIU and
the OECS Commission is responsible for the implementation and monitoring of the safety
management systems of the project. The E&S safeguards specialists will develop sub-policies,
guidelines, procedures, instructions and training and awareness materials to support this policy.
The project will also ensure that all employees hired as part of the project:
 Ascribe to the principle of not harming people;
 That sexual harassment, gender-based violence, sexual exploitation, abuse and harassment
not be tolerated;
 That discrimination will not be tolerated in the workplace;
 The employment of project workers will be based on the principle of equal opportunity and
fair treatment, and there will be no discrimination with respect to any aspects of the
employment relationship, such as recruitment and hiring, compensation (including wages
and benefits), working conditions and terms of employment;
 Given that there are direct workers under PIUs, the PIUs will adapt and receive training on
Code of Conducts as well as on OHS measures required under ESS2;
 That there is compliance with the laws of the Countries at all times; and,
 That all health and safety measures are adhered to as laid out under World Bank’s
Environmental and Social Standards on Labour and Working Conditions.
7.4 OHS Policy Dissemination and Awareness

The OHS policy will be disseminated to all project workers, contractors and beneficiaries before start
of contract. The information will be disseminated in various formats including an adapted and
summarized version to be prepared by each of the PIU E&S safeguards specialists.
8 AGE OF EMPLOYMENT
ESS2 states that the minimum age for employment or engagement in connection with the project
will be the age of 14 unless national law specifies a higher age. A child over the minimum age, and
under the age of 18 may be employed or engaged in connection with the project only where
national laws permit, and only under the following specific conditions:
(a) an appropriate risk assessment is conducted prior to the work commencing; and,
(b) the Borrower conducts regular monitoring of health, working conditions, hours of work and the
other requirement of ESS2 of the World bank: Labor and Working condition.
Under no circumstances will a child under the age of 18 be employed or engaged in connection with
the project in a manner that is likely to be hazardous9 or interfere with the child’s education or be
harmful to the child’s health or physical, mental, spiritual, moral or social development.
The following process will be followed to verify the age of project workers. This process will be
completed by project contractors and verified by the PIUs.
9
Work considered hazardous for children is work that, by its nature or the circumstances in which it is carried
out, is likely to jeopardize the health, safety, or morals of children. Examples of hazardous work activities
prohibited for children include work: (a) with exposure to physical, psychological or sexual abuse; (b)
underground, underwater, working at heights or in confined spaces; (c) with dangerous machinery, equipment
or tools, or involving handling or transport of heavy loads; (d) in unhealthy environments exposing children to
hazardous substances, agents, or processes, or to temperatures, noise or vibration damaging to health; or (e)
under difficult conditions such as work for long hours, during the night or in confinement on the premises of
the employer.
18
All project workers will be asked to produce identification documents (ID) that are acceptable in
local laws, employment and human resources practices as “proof of age”. These forms of ID will be
birth certificates, national driver’s licenses, national passports or national registration cards. The
number and type of pieces of required ID is at the discretion of each country, though one piece of ID
is considered sufficient for the purposes of compliance with the LMP.
In the absence of one of those forms of IDs the project will apply and document an age verification
process. The age verification process will consist of alternative methods including copies of academic
certificates, testimony/affidavits from officials of the schools attended, a medical examination,
statements from family members and parish/village officials/local authorities. In addition, all
documents will be cross-referenced and subjected to a verification process to ensure the validity of
the documents. In instances where the documents are thought to be falsified the project will
conduct the same process to ensure their authenticity.
In all the processes the attendant care will be provided to ensure that the applicant or employee’s
data are protected and their right to privacy is guaranteed. All copies of the IDs and documents
pertaining to the applicant's age and other supporting materials will be kept in files with the human
resources personnel. Audits and controls of the process will be a requirement of the contractors and
included in the contracts, in keeping with the country’s Labour/ Employment Acts.
If workers are found to have been hired without complying with the project’s minimum working age
requirements, the following actions will be undertaken:
 Any employer, contractor or beneficiary found hiring persons failing to meet the project’s
minimum working age requirements, but above the national minimum age will be required to
participate in a review of the project’s age requirements and procedures.
 Any employer, contractor or beneficiary found hiring persons below the national legal minimum
age will have their contract immediately terminated and will be reported to the authorities.
 A meeting will be scheduled with the child to determine the reasons for seeking employment;
 The child will be referred to other support services as appropriate. These could include a social
worker or a ministry responsible for social services;
 Services of NGOs and CBOs will be secured to assist the child.
National legislation governing age requirements for participation in the labour force is presented
below for each of the three participating countries.
Table 6 The age of employment in the project countries

Country Minimum Age National Labour Law
Grenada 16 Grenada Employment Act No. 14 of 1999
Saint Lucia 15 The Labour Act No. 37 of 2006
SVG 14 Employment of Women, Young Persons, and
Children Act of 1935
Grenada - Minimum Working Age National Legislation

The project will be guided by the Grenada Employment Act of 1999 which states that the minimum
age of employment in Grenada is sixteen years old. In line with this Employment Act, the procedure
for assessing the risks will be as follows:
 All persons will be asked to provide a medical certificate with the results of a medical
examination.
 An assessment will be done of the tasks assigned, to ensure that persons below the age of 18 are
not subjected to hazards and risks
19
 There will be clear policy guidelines regarding supervision of young persons to prevent
exploitation and sexual harassment
 Young persons will be provided with educational and awareness information on the policies of
the workplace including sexual harassment policies and labour related grievances and the
grievance redress mechanism of the project.
Saint Lucia – Minimum Working Age National Legislation

The Labour Act No. 37 of 2006 Section 122 (1)provides that, a person shall not employ or allow to
be employed any child who is under the minimum school leaving age as declared by any law in force
in Saint Lucia except for employment during school holidays in light work. Section 2 defines the term
“child” to mean a person aged fifteen and under. “Young person” means a person who is over the
age of fifteen years but who has not attained the age of eighteen years.
Saint Vincent and the Grenadines – Minimum Working Age National Legislation
Part II, Article 8 of the Employment of Women, Young Persons, and Children Act, 1938:
Prohibition of employment of a child — (1) Subject to subsection (2), a child shall not be employed.
(2) Nothing in subsection (1) applies— (a) to work done by any child in accordance with the
provisions of Part I; (b) to the service rendered by any child to his parent or guardian in light
agricultural or horticultural work on the family land or garden outside of school hours; (c) to the
participation of a child, without fee or reward, in an entertainment the net proceeds of which are
devoted to any charitable or educational purpose or to any purpose other than the private profit of
the promoters.
SCHEDULE II, ARTICLE 2 Children under the age of fourteen years shall not be employed or work in
any public or private industrial undertaking, or in any branch thereof, other than an undertaking in
which only members of the same family are employed: Provided that, except in the case of
employment which, by their nature or the circumstances in which they are carried on, are dangerous
to the life, health or morals of the persons employed therein, national laws or regulations may
permit such children to be employed in undertakings in which only members of the employer's
family are employed.
9 TERMS AND CONDITIONS OF EMPLOYMENT

The terms and conditions of employment are presented below for each of the three participating
countries with respect to issues such a contracts, hours of work, termination
GRENADA
The following terms and conditions apply to project workers in accordance with the Grenada under
the Employment Act of 1999. All workers hired by the project, including those hired by the PIUs,
contractors, sub-contractors and beneficiaries, shall pay rates of wages and observe hours and
conditions of employment which are not less favourable than those established in the country.
All project contractors, sub-contractors and beneficiaries hiring workers shall be certified according
to the Government Requirements for governmental contractors including that contractors certify
that the wages and conditions of employment of all those employed.
The contracts will be guided by the principle of collective bargaining if applicable and where there is
no minimum wage or rates established in the country, the guiding principle will be of fair wages and
reasonable rates commensurate with governmental minimum wage and similar established rates
and conditions.
20
In keeping with the Employment Act, the contractor shall keep proper wage records and time sheets
for all those employed in relation to the execution of the contract, and the contractor shall produce
the wage records and timesheets for the inspection of any person authorised by the project or the
Labour authorities of Grenada.
Contractors are required by law, to post conditions of work in conspicuous places informing workers
of their rights and conditions of work. The contractor shall ensure sufficient insurance so as to pay
compensation to workers under the Workmen’s Compensation Act, Chapter 343. 9.
A subcontractor shall be bound to conform to the conditions of the main contract and the main
contractor shall be responsible for the observance of all contract conditions.
Contractors and subcontractors shall recognise the right of their workers to be members of the trade
unions.
Minimum Wage10
All project workers shall be paid a wage that is above or equal to the minimum wage as established
by the Government of Grenada. Wages will be paid on a weekly, bi-weekly or monthly basis. Each
employee is entitled to a statement accompanying pay that itemised the following: “(a) the
employee’s gross wages due at the end of that pay period; (b) the amount of every deduction from
his or her wages during that pay period and the purpose for which each deduction was made; and (c)
the employee’s net wages payable at the end of that pay period.”
Hours of Work
The maximum number of ordinary hours of work for employees shall be 40 hours per week with the
ordinary working days being Mondays to Saturdays.
Project employees are prohibited from working more than 10 hours per day inclusive of two hours
for lunch and rest periods. No person under the age of eighteen years shall be employed or allowed
to work between the hours of 9.00 p.m. to 6.00 a.m. Other provisions related to hours of work will
be guided by the Employment Act on this matter.
SAINT LUCIA
The Saint Lucia Labour Code guides and regulates the terms and conditions of employment. Division
1 “Contracts of Employment” applies to all persons engaged under contracts of employment. The
Act mandates that “Within fourteen days from the date on which employment commences, an
employer may prepare a written contract correctly describing the terms and conditions of
employment that have been agreed upon by the employer and employee”. The Code also states that
“where a contract of employment is not written the employer shall explain to the employee the
contents of the contact of employment….”. The Code further states that “upon written request to
the employer, an employee who is not employed under a written contract
shall be given, within one month of the request, a written contract.
The Labour code, para. 27.— (1) states that subject to subsections (2) and (3), an employer shall not
require any employee to work for more than forty hours during any week, excluding overtime. In
para. 265. — (1) It also states that an employer shall not — (a) dismiss or threaten to dismiss an
employee; (b) discipline or suspend or threaten to discipline or suspend an employee, (c) impose any
penalty upon an employee; (d) intimidate or coerce an employee; or (e) discriminate against an
employee in any way.
10
The minimum wage rates in Grenada, Saint Lucia and Saint Vincent and the Grenadines are set by the
respective Departments of Labour by sector.
21
The code states, that a person discriminates against another person if the first mentioned person
makes, on any of the grounds specified in subsection (2), any distinction, exclusion or preference,
the intent or effect of which is to nullify or impair equality of opportunity or treatment in occupation
or employment. (2) The grounds referred to in subsection (1) are — (a) race, sex, religion, colour,
ethnic origin, social origin, political opinion or affiliation, disability, serious family responsibility,
pregnancy, marital status, HIV/AIDS, trade union affiliation or activity, or age except for purposes
of retirement and restrictions on work and employment of minors or for the protection of children
and young persons.
Para 285.—(1) states that, without prejudice to the provisions under this Division, an employer shall
not refuse to employ a person, demote or dismiss a female employee, alter the terms and conditions
of her contract of employment, refuse her promotion or training or in other way discriminate against
her because she is or was pregnant or for any reason connected with pregnancy.
Under this Project all consultants will be provided with a written contract, in accordance with the
Labour Code, outlining terms and conditions for executing the particular work that they have been
contracted for. The terms and conditions of employment will make adequate provisions for periods
of rest per week, annual holiday, sick, maternity and vacation and bereavement leave as stipulated
in the Labour Code.
SAINT VINCENT AND THE GRENADINES

The project will be guided by the Protection of Employment Act, 2003. This Act provides for the
maintenance and promotion of good employment relationships between employers and employees.
Among other elements, it addresses the promotion of employment rights, severance pay and
disputes.
Protection against dismissal without good cause

5. (1) Subject to the following provisions, every person shall be protected against the unfair
termination of his employment without good cause.
5. (2) The employment of a worker shall not be terminated for reasons related to his conduct or
performance before he is provided an opportunity to defend himself against the allegations made
except in cases where the employer cannot reasonably be expected to provide such opportunity.
Termination after fixed term of employment

6. (1) The services of an employee who has been specifically employed for a fixed period may,
notwithstanding anything contained in this Act, be terminated on the expiration of the term so
stipulated.
6. (2) For the purposes of this section, the effective date of termination of the services of an
employee in relation to an employee who has been specifically employed for a fixed period and
where that period expires without being renewed under the same contract, shall be the date on
which the term expired.
Terms of employment in writing

8. (1) Save in the case of daily paid and weekly paid workers, an employer shall inform an employee
in writing of the terms and conditions in writing of employment and such terms and conditions shall
include:
a) the date of commencement of employment;
b) the name and address of the employer and the employee;
c) the rate of pay, the overtime rate if any and the pay period;
d) the probationary period if any;
e) the hours of work including time off and rest period, if any;
22
f) the rate of vacation, sick and maternity leave if applicable; and
g) the duties to be performed.
8. (2) An employer shall provide to the employee the conditions of service referred to in subsection
(1) within seven working days from the date of employment or four calendar weeks where the
employee is in employment at the commencement of this Act,
8. (3) Any person who fails to comply with the provisions of this section commits an offence and is
liable on conviction to a fine not exceeding one thousand dollars.
10 GRIEVANCE REDRESS MECHANISM

The Grievance Redress Mechanism (GRM) for all Project Workers is as follows:
GRM Point of Contact

Contractors and beneficiaries hiring workers of any kind will appoint a representative/employee who
will be the point of contact for all grievances. In the case of PIUs, the point of contact will be the
project manager. Contact information will become available once the PIU project managers are on
board, and the contractors are known. Contact information will be available prior to the hiring of
workers and it will be provided to workers upon signing of contract.
GRM contact information in each PIU will be updated upon establishment and staffing of the PIUs.
Given below are contact details of the line ministries where each PIU will be housed.
Table 7 GRM Points of Contact (TO BE COMPLETED)

Country Organisation Department Name Title Email Telephone Website
address
Grenada
Saint
Lucia
SVG
OECS
Documentation of Grievance
All received grievances received by the project shall be logged and filed by the PIU Project Manager.
Upon receipt of grievances not channelled through the PIU project manager, the contractor staff or
point of contact will notify the PIU project manager. In the case of issues with project management
staff the Project Manager may be required to exclude herself or himself if the complaint directly
involves him or her. Where the Project Manager is the subject of the grievance, the complaint
should be directed to a contact in the Ministry responsible for the project. This contact is named in
Table 7.
The point of contact will attempt to address grievance within established time frame of 3 weeks
upon receipt. In cases of timely or urgent matters a period of a minimum of 24 hours and a
maximum of 15 calendar days will be allotted for addressing and resolving the grievance. Grievances
can be made in person, telephone call or writing. Grievances can be made anonymously. A dedicated
email and a telephone number will be provided for all grievances. Grievances made via telephone or
in person will be recorded at a later date and the complainant asked to sign same if in agreement to
disclose their name.
Resolution of Grievance
23
The contractor or beneficiary point of contact will notify the PIU Project Manager through a report
of the successful resolution of any grievance. The complainant will also be informed via writing of
the measures taken to address the grievance. If the grievance cannot be resolved by the contractor
or beneficiary, the point of contact will inform the PIU Project Manager.
The PIU Project Manager and E&S safeguards specialists will meet with the project contractor/
beneficiary and workers and attempt resolution. In the case of grievances directed towards PIU staff,
the Permanent Secretary within the Department of Finance will meet directly with the staff.
If issues cannot be resolved the issue will be referred to the Ministry of Labour of the respective
country for their action and pronouncement. The Ministry of Labour’s ruling would be the final tier
of the grievance mechanism.
Anonymity
Grievances may be submitted anonymously. Grievances can be submitted without providing the
complainant’s name or contact details with the understanding this might result in difficulties in some
cases. A grievance made anonymously is to be addressed without knowledge of the name of the
individual initiating the grievance.
Addressing gender-based violence

The GRM will specify and train an individual who will be responsible for dealing with any gender-
based violence (GBV) issues, should they arise. This individual will be included in the GRM point of
contacts listed in Table 7.
A list of GBV service providers will be kept available by the GBV trained individual, the PIU Project
Managers or the Permanent Secretary of the respective ministries in each of the participating
countries. The GRM should assist GBV survivors by referring them to GBV Services Provider(s) for
support immediately after receiving a complaint directly from a survivor.
Annex 2 provides an initial mapping of GBV services by country that will be updated annually to
ensure the information is current.
The Code of Conduct addresses procedures for referring GBV incidents to the corresponding legal
authorities, including for potential prosecution under the Criminal Code. If a GBV-related incident
occurs, it will be reported through the GRM, as appropriate keeping the survivor information
confidential. Specifically, the GRM will only record the following information related to the GBV
complaint:
 The nature of the complaint (what the complainant says in her/his own words without direct
questioning);
 If, to the best of their knowledge, the perpetrator was associated with the project; and,
 If possible, the age and sex of the survivor.
Any cases of GBV brought through the GRM will be documented but remain closed/sealed to
maintain the confidentiality of the survivor. Here, the GRM will primarily serve to:
 Refer complainants to the GBV Services Provider; and
 Record the resolution of the complaint
The GRM will also immediately notify both the Implementing Agency and the World Bank of any GBV
complaints with the consent of the survivor.
24
11. CONTRACTOR MANAGEMENT
It is mandated that the contractor execute the management of the contract in a manner that is
acceptable to the client and is in accordance with the World Bank rules and regulations as it relates
to ESS2, specifically relating to the selection process for contractors, management of labour issues,
including health and safety, procedures for managing and monitoring of performance for
contractors, as well as reporting on workers under the project.
Information on Public Records: The Contractor must have in place information on corporate
registers and documents relating to the violation of applicable law, including reports from labour
inspectorates and other enforcement bodies.
Certification and Approval of Business and Workers: Documentation of approved business licenses,
registration, permits and other approvals and workers’ certification/permits and training to perform
the work.
Health and Safety: Document and have in place labour management systems as it relates to
organizational health and safety. Records of incidents and corresponding root cause analysis with a
corrective mitigation plan. First aid cases, high potential near misses, and remedial and preventive
activities required. Identification and establishment of safety committee and records of meetings
Workers Payroll Records: Documentation of the number of hours work and pay received inclusive of
all payments made on their behalf, for example payment made to the National Insurance Scheme
and other entitlements regardless of the workers being engaged on a short- or long-term
assignment or fulltime or part time worker.
12. PRIMARY SUPPLY WORKERS

Primary suppliers supporting project activities will be required to adhere to the procedures
established in the ESS2, particularly with respect to monitoring and mitigating the risk of child labour
or forced labour, and the requirement to implement OHS procedures laid out in the LMP in order to
mitigate risks of safety issues related to primary supply workers.
National government, OECS, contractor and beneficiary employees involved in project

implementation will remain subject to the terms and conditions of their contracts unless there is an
effective legal transfer of their employment to the project. For this category of worker, only the OHS
requirements under ESS2 apply11.
Where primary supply workers are involved, the contractor who subcontracts the supply of
materials and equipment will be responsible to include conditions and specifications on OHS aspects
in subcontracting agreements, including and to prevent the use of child labour, forced labour and
serious safety issues which may arise in relation to primary suppliers, and consistent with ESS2.
13. COMMUNITY WORKERS

At this stage it is not clear whether community labour will be engaged by the project. If Community
Workers are engaged in the project, a determination will be made by the PIU as to whether the
labour will be voluntary or based on individual or community agreements. Where the project
includes the provision of labour by community workers, the terms and conditions on which
11
See World Bank. 2018. ESF Guidance Note for ESS2 Labor and Working Conditions, Section G (Primary Supply
Workers) requirements laid out in paragraphs 39 to 42.
25
community labour will be engaged will be clearly defined, including amount and method of payment
(if applicable) and times of work.
The provisions of this ESS will apply to Community Workers, including but not limited to working
conditions, occupational health and safety, requirements and procedures related to child labour or
forced labour, and the Grievance Redress Mechanism12.
12
See World Bank. 2018. ESF Guidance Note for ESS2 Labor and Working Conditions, Section F (Community
Workers) requirements laid out in paragraphs 34 to 38.
26
ANNEX 1- TEMPLATE CODE OF CONDUCT
I, ______________________________, staff at the PIU in [name of Ministry/Agency where the PIU

sits) for the Project [name of Project], acknowledge that adhering to environmental, social, health and
safety (ESHS) standards, following the project’s occupational health and safety (OHS) requirements,
and preventing Gender Based Violence (GBV), including sexual exploitation and abuse (SEA), and
sexual harassment (SH) at the workplace, is important in and outside the context of this project, as
further set out in this Code of Conduct. As such, we acknowledge this Code of Conduct identifies the
behavior that is expected of all PIU staff for the Project [name of the Project].
Our workplace is an environment where unsafe, offensive, abusive or violent behavior will not be
tolerated and where all persons should feel comfortable raising issues or concerns without fear of
retaliation.
For the purpose of this Code of Conduct, it is important to note that 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. GBV includes the following concepts:
 Sexual Exploitation and Abuse (SEA): Sexual exploitation 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. Sexual abuse is defined as the actual or threatened physical intrusion
of a sexual nature, whether by force or under unequal or coercive conditions.
 Sexual harassment (SH): occurs between personnel and staff onf the project and means any
unwelcome sexual advance, request for sexual favors, and other verbal or physical conduct of
a sexual nature.
A violation to this Code of Conduct, including failure to follow ESHS and OHS standards, or
engaging in activities constituting GBV including SEA/SH—be it on the workplace, work sites, work
site surroundings, at workers’ camps, or the surrounding communities—, constitute acts of serious
misconduct, which contravenes the terms of employment, and are therefore grounds for disciplinary
action up to and including termination of employment for PIU staff. Acts that may violate the laws of
[country] will be additionally referred to the corresponding legal authorities, including for potential
prosecution under the Criminal Code.
27
Commitments under this Code of Conduct
I agree that while working on the project I shall:
General:
1. carry out my duties competently and diligently.

2. comply with this Code of Conduct and all applicable laws, regulations and other requirements,
including requirements to protect the health, safety and well-being of other Project staff, workers,
and any other person.
Regarding ESHS and OHS
3. Attend and actively partake in training courses related to ESHS and OHS as requested by my
employer.
4. Always wear my personal protective equipment (PPE) when at the work site or engaged in project
related activities.
5. Implement the OHS Management Plan.
6. Adhere to a zero-alcohol policy during work activities, and refrain from the use of narcotics or
other substances which can impair faculties.
7. Report work situations that are not safe or healthy and remove myself from a work situation
which I reasonably believe presents an imminent and serious danger to my life or health.
Regarding equality of opportunity and treatment
8. Treat women, children (persons under the age of 18), and men with respect regardless of race,
color, language, religion, political or other opinion, national, ethnic or social origin, property,
disability, birth or other status.
Regarding discrimination and violence based on gender
9. Not use language or behavior towards women, children or men that is inappropriate, harassing,
abusive, sexually provocative, demeaning or culturally inappropriate.
10. Not engage in SEA with project beneficiaries and members of the surrounding communities.
11. Not engage in sexual harassment with other project personnel and staff —for instance, comments
on the appearance of another worker (either positive or negative) and sexual desirability. making
unwelcome sexual advances, looking somebody up and down; kissing, howling or smacking
sounds; hanging around somebody; whistling and catcalls; and offering or giving personal gifts.
12. 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.
28
13. Unless there is the full consent13 by all parties involved, not have sexual interactions with
members of the surrounding communities or work colleagues. 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.
Regarding children under the age of 18
14. Not engage in any form of 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 or his/her
consent is not a defense or excuse.
15. Bring to the attention of my manager the presence of any children on the construction site or
engaged in hazardous activities.
16. Wherever possible, ensure that another adult is present when working in the proximity of
children.
17. Not invite unaccompanied children unrelated to my family into my home, unless they are at
immediate risk of injury or in physical danger.
18. Not use any computers, mobile phones, video and digital cameras or any other medium to exploit
or harass children or to access child pornography.
19. Refrain from hiring children below the minimum age of 18.
20. Comply with all relevant local legislation, including labor laws in relation to child labor.
21. When photographing or filming a child for work related purposes, I must:
a) Before photographing or filming a child, assess and endeavor to comply with local traditions
or restrictions for reproducing personal images.
b) 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.
c) Ensure photographs, films, videos and DVDs present children in a dignified and respectful
manner and not in a vulnerable or submissive way. Children should be adequately clothed and
not in poses that could be sexually suggestive.
d) Ensure images are honest representations of the context and the facts.
e) Ensure file labels do not reveal identifying information about a child when sending images
electronically.
13
Consent is defined as the informed choice underlying an individual’s free and voluntary intention, acceptance or agreement to do
something. Consent must be informed, based on a clear appreciation and understanding of the facts, implications and future consequences of
an action. The individual also must be aware of and have the power to exercise the right to refuse to engage in an action and/or to not be
coerced (i.e., by financial considerations, force or threats). 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. For the purpose of this Code of Conduct, consent
cannot be given by children under the age of 18, even if national legislation introduces a lower age. Mistaken belief regarding the age of the
child and consent from the child is not a defense.
29
Disciplinary measures
The Ministry of [specify ministry where the PIU sits] shall be responsible for making decisions on the
specific sanctions to be imposed on workers for violations to this Code of Conduct. I understand that
if I breach this Code of Conduct, the Ministry of [specify ministry where the PIU sits] will take
disciplinary action according to the seriousness of the offense which could include:
 verbal notification (For Public Officers)/ warning for PIU staff employed by the Ministry of
[specify ministry where the PIU sits]
 written notification (For Public Officers)/ warning for PIU staff employed by the Ministry of
[specify ministry where the PIU sits]
 termination of employment
Infringements sanctioned with verbal notification

Those behaviors that do not cause relevant risks to the Ministry of [specify ministry where the PIU
sits], other workers and/or its relationship with the communities. Verbal warnings may involve a
reminder of the Code of Conduct and its applicability.
Infringements sanctioned with written notification

Those behaviors that cause minor risk to the Ministry of [specify ministry where the PIU sits], other
workers and/or its relationship with the communities and/or the environment.
Infringements sanctioned with termination of employment

Those behaviors that cause substantive risks to the Ministry of [specify ministry where the PIU sits],
other workers and/or its relationship with the communities and/or the environment, or behaviors that
constitute serious misconduct in accordance with this Code of Conduct. In such cases, the termination
of employment may be accompanied by a referral to the corresponding legal authorities. Cases of
SEA or SH will always be considered serious misconduct. Recurrent offences to the Code of Conduct
will also be considered serious misconduct.
Termination of employment shall be carried out in accordance with the Labor Code of [country].
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; and, that
I will avoid actions or behaviors that could be construed as GBV, including SEA and SH. Any such
actions will be a breach of this Code of Conduct. I do hereby acknowledge that I have read the foregoing
Code of Conduct, agree to comply with the standards contained herein, and understand my roles and
responsibilities to prevent and respond to ESHS, OHS, and GBV issues. I understand that any action
inconsistent with this Code of Conduct or failure to act, may result in disciplinary action.
30
Staff Signature: _________________________
Printed Name: _________________________
Title: _________________________
Date: _________________________
31
ANNEX 2 - List of available GBV services and points of service,
including contact information for participating countries
Grenada List of available GBV services
Name of GBV Service provided Contact

Organisation
Division of Provides direct social and psychological Sir Eric Matthew Gairy Botanical Gardens,
Family and services to victims of IPV and adult victims of St. George's Grenada, W.I.
Gender Affairs sexual abuse. Tel: +1 (473) 440-2255
Fax: +1 (473) 440-4116 |
This includes counselling, a +1 (473) 435-7285
psychoeducational programme developed
specifically for survivors, child protection, and Email: pmpress@gov.gd
social safety nets such as the Support for
Education, Empowerment and Development Web: www.gov.gd
(SEED) Programme which provides financial
payments to the poorest and most
vulnerable, and housing and relocation to
Cedars Home for Abused Women and Their
Children, if needed.
Cedars Home Shelter facility Undisclosed. But information on services

for Abused available from the Division of Family and
Women Gender affairs (above).
Legal Aid Clinic General legal advice and representation, St. John’s St., St. Georges.
counselling, psychological services, psycho- Tel: 1 473-440-3785
social, and mediation. Covid-19 emergency contact: 440 3788,
440 3785,419 4112 and 456 7571
WhatsApp : 405 8643.
Email:lacc@spiceisle.com.
Royal Grenada Emergency response, investigations, arrests, Headquarters Fort George, St. George's
Police Force and providing evidence for prosecution. SVU Grenada, W.I..
(RGPF) Hotline Tel: (473) 440-3999 | (473) 440-1043 |
(473) 440-1047
Call 400 for SVU Hotline
Civil Society Organisations
Sweet Water Sexual Violence Help line. Branch of an WhatsApp: Message 473-534-5787
Foundation organisation located in Canada. Telephone: 473-800-4444
Email:helpline@sweetwaterfoundation.ca
Grenada Sexual and reproductive health services and Grenville, Grenada

Planned education to women and girls, including Tel: 473-442-5442
Parenthood through their youth arm (i.e. Youth Advocacy
Association Movement). They run two full time clinics in
(GPPA) St. George’s and St. Andrew’s.
32
Saint Lucia List of available GBV services
Name of Organisation GBV Service provided Contact
Government Organisations
Department of Gender Hotline; counselling, legal services, skills Ground Floor, Georgian Court
Relations training, job placement, alternative Building, John Compton
housing Highway, Castries, St. Lucia.
Public education campaigns, referral +1 758-716-3123 ·
services
Women’s Support Centre Residential shelter for women and Contact via DGR
children (up to 5 families); legal services,
counselling
Family Court Cases management, counselling for City Courthouse, Castries
survivors and perpetrators, Protection Tel: 758-453-2839
Orders, Occupation Orders, Tenancy
Orders
Vulnerable Person Emergency response, investigation, arrest, Tel: 758-456-3980 (Southern
Team/Unit and provision of evidence for prosecution. Division)
Public education campaigns, referrals 758-456-4050 (Northern
division).
Civil Society
St. Lucia Crisis Centre Emergency shelter facilities, hotline, Ms. Rufina Paul/ Ms. Paul-
counselling, public education, referrals Akuffo
107 Chausee Rd. Castries, St.
Lucia.
Tel: 758-453-6848
National Organisation of Public education campaigns, referrals. Ms. Virgina Albert
Women Tel: 758-450-5247
United and Strong Public education around GBV and the Adaryl Williams
LGBTQI community; referrals Tel; 758-450-0976
Raise Your Voice St. Lucia Training on GBV prevention and response Manoel Street
using human rights based and survivor Castries
centered approaches. Tel: 758-723-4227.
33
Saint Vincent & the Grenadines- Available GBV services
Name GBV Service Contact
Gender Affairs Receives reports and provides http://mobilization.gov.vc/mobilization/index.php/ge

Division direct social and psychological nder-affairs
services to victims of IPV and
The Ministry of National Mobilisation, Social
adult victims of sexual abuse.
Development, Family, Gender Affairs, Youth,
Report can be made via Housing and Informal Human Settlement
telephone, email, mail or a visit Halifax Street
to the Bureau’s office Kingstown
Saint Vincent
Conducts capacity building and
training of other GBV service Tel: (784) 453-2061
providers. Implements public email: office.socialdevelopment@mail.gov.vc
education programmes on GBV.
The Crisis Counselling, Shelter services, Contact through the Gender Affairs Division
Centre Small grants for reintegration
Tel; 784-453-2061.
and relocation if needed, 24
Hour Hotline
Royal Saint Emergency response, Criminal Investigation Division (CID)

Vincent Police investigations, arrests, and
1-784-456-1810
Force providing evidence for
prosecution. Also has a Anti-
Trafficking Unit and a Sexual
Offences Unit.
Civil Society Organisations
Marion House Skills training for survivors Marion House

Richmond Hill
Counselling services
Tel: 784-456-2161
Fax: 784-456-1318
National Advocacy to encourage https://www.facebook.com/pages/category/Non-

Council for legislative changes to improve Governmental-Organization--NGO-/National-Council-
Women SVG protection for women and of-Women-555847524550908/
ensure that DV cases are
Ms. Muriel Byam
prosecuted.
National Council of Women
It also provides training on
domestic violence prevention P.O. Box 1157 Kingstown St Vincent
and response
Tel: 456 4743
E-mail: muriel@vincysurf.com.
34
ANNEX 3- COVID-19 CONSIDERATIONS IN PROJECT IMPLEMENTATION
WORLD BANK ESF/SAFEGUARDS INTERIM NOTE: COVID-19
CONSIDERATIONS IN CONSTRUCTION/CIVIL WORKS PROJECTS
This note was issued on April 7, 2020 and includes links to the latest guidance as of this date (e.g.
from WHO). Given the COVID-19 situation is rapidly evolving, when using this note it is important to
check whether any updates to these external resources have been issued.
1. INTRODUCTION
The COVID-19 pandemic presents Governments with unprecedented challenges. Addressing COVID-
19 related issues in both existing and new operations starts with recognizing that this is not business
as usual and that circumstances require a highly adaptive responsive management design to avoid,
minimize and manage what may be a rapidly evolving situation. In many cases, we will ask
Borrowers to use reasonable efforts in the circumstances, recognizing that what may be possible
today may be different next week (both positively, because more supplies and guidance may be
available, and negatively, because the spread of the virus may have accelerated).
This interim note is intended to provide guidance to teams on how to support Borrowers in
addressing key issues associated with COVID-19, and consolidates the advice that has already been
provided over the past month. As such, it should be used in place of other guidance that has been
provided to date. This note will be developed as the global situation and the Bank’s learning (and
that of others) develops. This is not a time when ‘one size fits all’. More than ever, teams will need
to work with Borrowers and projects to understand the activities being carried out and the risks that
these activities may entail. Support will be needed in designing mitigation measures that are
implementable in the context of the project. These measures will need to take into account capacity
of the Government agencies, availability of supplies and the practical challenges of operations on-
the-ground, including stakeholder engagement, supervision and monitoring. In many circumstances,
communication itself may be challenging, where face-to-face meetings are restricted or prohibited,
and where IT solutions are limited or unreliable.
This note emphasizes the importance of careful scenario planning, clear procedures and protocols,
management systems, effective communication and coordination, and the need for high levels of
responsiveness in a changing environment. It recommends assessing the current situation of the
project, putting in place mitigation measures to avoid or minimize the chance of infection, and
planning what to do if either project workers become infected or the work force includes workers
from proximate communities affected by COVID-19. In many projects, measures to avoid or
minimize will need to be implemented at the same time as dealing with sick workers and relations
with the community, some of whom may also be ill or concerned about infection. Borrowers should
understand the obligations that contractors have under their existing contracts (see Section 3),
require contractors to put in place appropriate organizational structures (see Section 4) and develop
procedures to address different aspects of COVID-19 (see Section 5).
2. CHALLENGES WITH CONSTRUCTION/CIVIL WORKS

Projects involving construction/civil works frequently involve a large work force, together with
suppliers and supporting functions and services. The work force may comprise workers from
international, national, regional, and local labour markets. They may need to live in on-site
accommodation, lodge within communities close to work sites or return to their homes after work.
There may be different contractors permanently present on site, carrying out different activities,
each with their own dedicated workers. Supply chains may involve international, regional and
national suppliers facilitating the regular flow of goods and services to the project (including supplies
essential to the project such as fuel, food, and water). As such there will also be regular flow of
35
parties entering and exiting the site; support services, such as catering, cleaning services, equipment,
material and supply deliveries, and specialist sub-contractors, brought in to deliver specific elements
of the works.
Given the complexity and the concentrated number of workers, the potential for the spread of
infectious disease in projects involving construction is extremely serious, as are the implications of
such a spread. Projects may experience large numbers of the work force becoming ill, which will
strain the project’s health facilities, have implications for local emergency and health services and
may jeopardize the progress of the construction work and the schedule of the project. Such impacts
will be exacerbated where a work force is large and/or the project is in remote or under-serviced
areas. In such circumstances, relationships with the community can be strained or difficult and
conflict can arise, particularly if people feel they are being exposed to disease by the project or are
having to compete for scarce resources. The project must also exercise appropriate precautions
against introducing the infection to local communities.
3. DOES THE CONSTRUCTION CONTRACT COVER THIS SITUATION?

Given the unprecedented nature of the COVID-19 pandemic, it is unlikely that the existing
construction/civil works contracts will cover all the things that a prudent contractor will need to do.
Nevertheless, the first place for a Borrower to start is with the contract, determining what a
contractor’s existing obligations are, and how these relate to the current situation.
The obligations on health and safety will depend on what kind of contract exists (between the
Borrower and the main contractor; between the main contractors and the sub-contractors). It will
differ if the Borrower used the World Bank’s standard procurement documents (SPDs) or used
national bidding documents. If a FIDIC document has been used, there will be general provisions
relating to health and safety. For example, the standard FIDIC, Conditions of Contract for
Construction (Second Edition 2017), which contains no ‘ESF enhancements’, states (in the General
Conditions, clause 6.7) that the Contractor will be required:
• to take all necessary precautions to maintain the health and safety of the Contractor’s Personnel
• to appoint a health and safety officer at site, who will have the authority to issue directives for the
purpose of maintaining the health and safety of all personnel authorized to enter and or work on the
site and to take protective measures to prevent accidents
• to ensure, in collaboration with local health authorities, that medical staff, first aid facilities, sick
bay, ambulance services and any other medical services specified are available at all times at the site
and at any accommodation
• to ensure suitable arrangements are made for all necessary welfare and hygiene requirements and
for the prevention of epidemics
These requirements have been enhanced through the introduction of the ESF into the SPDs (edition
dated July 2019). The general FIDIC clause referred to above has been strengthened to reflect the
requirements of the ESF. Beyond FIDIC’s general requirements discussed above, the Bank’s Particular
Conditions include a number of relevant requirements on the Contractor, including:
• to provide health and safety training for Contractor’s Personnel (which include project workers and
all personnel that the Contractor uses on site, including staff and other employees of the Contractor
and Subcontractors and any other personnel assisting the Contractor in carrying out project
activities)
• to put in place workplace processes for Contractor’s Personnel to report work situations that are
not safe or healthy
• gives Contractor’s Personnel the right to report work situations which they believe are not safe or
healthy, and to remove themselves from a work situation which they have a reasonable justification
36
to believe presents an imminent and serious danger to their life or health (with no reprisal for
reporting or removing themselves)
• requires measures to be in place to avoid or minimize the spread of diseases including measures to
avoid or minimize the transmission of communicable diseases that may be associated with the influx
of temporary or permanent contract-related labour
• to provide an easily accessible grievance mechanism to raise workplace concerns
Where the contract form used is FIDIC, the Borrower (as the Employer) will be represented by the
Engineer (also referred to in this note as the Supervising Engineer). The Engineer will be authorized
to exercise authority specified in or necessarily implied from the construction contract. In such
cases, the Engineer (through its staff on site) will be the interface between the PIU and the
Contractor. It is important therefore to understand the scope of the Engineer’s responsibilities. It is
also important to recognize that in the case of infectious diseases such as COVID-19, project
management – through the Contractor/subcontractor hierarchy – is only as effective as the weakest
link. A thorough review of management procedures/plans as they will be implemented through the
entire contractor hierarchy is important. Existing contracts provide the outline of this structure; they
form the basis for the Borrower to understand how proposed mitigation measures will be designed
and how adaptive management will be implemented, and to start a conversation with the
Contractor on measures to address COVID-19 in the project.
4. WHAT PLANNING SHOULD THE BORROWER BE DOING?

Task teams should work with Borrowers (PIUs) to confirm that projects (i) are taking adequate
precautions to prevent or minimize an outbreak of COVID-19, and (ii) have identified what to do in
the event of an outbreak. Suggestions on how to do this are set out below:
• The PIU, either directly or through the Supervising Engineer, should request details in writing from
the main Contractor of the measures being taken to address the risks. As stated in Section 3, the
construction contract should include health and safety requirements, and these can be used as the
basis for identification of, and requirements to implement, COVID-19 specific measures. The
measures may be presented as a contingency plan, as an extension of the existing project
emergency and preparedness plan or as standalone procedures. The measures may be reflected in
revisions to the project’s health and safety manual. This request should be made in writing
(following any relevant procedure set out in the contract between the Borrower and the contractor).
• In making the request, it may be helpful for the PIU to specify the areas that should be covered.
This should include the items set out in Section 5 below and take into account current and relevant
guidance provided by national authorities, WHO and other organizations. See the list of references in
the Annex to this note.
• The PIU should require the Contractor to convene regular meetings with the project health and
safety specialists and medical staff (and where appropriate the local health authorities), and to take
their advice in designing and implementing the agreed measures.
• Where possible, a senior person should be identified as a focal point to deal with COVID-19 issues.
This can be a work supervisor or a health and safety specialist. This person can be responsible for
coordinating preparation of the site and making sure that the measures taken are communicated to
the workers, those entering the site and the local community. It is also advisable to designate at
least one back-up person, in case the focal point becomes ill; that person should be aware of the
arrangements that are in place.
• On sites where there are a number of contractors and therefore (in effect) different work forces,
the request should emphasize the importance of coordination and communication between the
37
different parties. Where necessary, the PIU should request the main contractor to put in place a
protocol for regular meetings of the different contractors, requiring each to appoint a designated
staff member (with back up) to attend such meetings. If meetings cannot be held in person, they
should be conducted using whatever IT is available. The effectiveness of mitigation measures will
depend on the weakest implementation, and therefore it is important that all contractors and sub-
contractors understand the risks and the procedure to be followed.
• The PIU, either directly or through the Supervising Engineer, may provide support to projects in
identifying appropriate mitigation measures, particularly where these will involve interface with
local services, in particular health and emergency services. In many cases, the PIU can play a valuable
role in connecting project representatives with local Government agencies, and helping coordinate a
strategic response, which takes into account the availability of resources. To be most effective,
projects should consult and coordinate with relevant Government agencies and other projects in the
vicinity.
• Workers should be encouraged to use the existing project grievance mechanism to report concerns
relating to COVID-19, preparations being made by the project to address COVID-19 related issues,
how procedures are being implemented, and concerns about the health of their co-workers and
other staff.
5. WHAT SHOULD THE CONTRACTOR COVER?

The Contractor should identify measures to address the COVID-19 situation. What will be possible
will depend on the context of the project: the location, existing project resources, availability of
supplies, capacity of local emergency/health services, the extent to which the virus already exist in
the area. A systematic approach to planning, recognizing the challenges associated with rapidly
changing circumstances, will help the project put in place the best measures possible to address the
situation. As discussed above, measures to address COVID-19 may be presented in different ways (as
a contingency plan, as an extension of the existing project emergency and preparedness plan or as
standalone procedures). PIUs and contractors should refer to guidance issued by relevant
authorities, both national and international (e.g. WHO), which is regularly updated (see sample
References and links provided in the Annex).
Addressing COVID-19 at a project site goes beyond occupational health and safety, and is a broader
project issue which will require the involvement of different members of a project management
team. In many cases, the most effective approach will be to establish procedures to address the
issues, and then to ensure that these procedures are implemented systematically. Where
appropriate given the project context, a designated team should be established to address COVID-19
issues, including PIU representatives, the Supervising Engineer, management (e.g. the project
manager) of the contractor and sub-contractors, security, and medical and OHS professionals.
Procedures should be clear and straightforward, improved as necessary, and supervised and
monitored by the COVID-19 focal point(s). Procedures should be documented, distributed to all
contractors, and discussed at regular meetings to facilitate adaptive management. The issues set out
below include a number that represent expected good workplace management but are especially
pertinent in preparing the project response to COVID-19.
(a) ASSESSING WORKFORCE CHARACTERISTICS

Many construction sites will have a mix of workers e.g. workers from the local communities; workers
from a different part of the country; workers from another country. Workers will be employed under
different terms and conditions and be accommodated in different ways. Assessing these different
aspects of the workforce will help in identifying appropriate mitigation measures:
38
• The Contractor should prepare a detailed profile of the project work force, key work activities,
schedule for carrying out such activities, different durations of contract and rotations (e.g. 4 weeks
on, 4 weeks off).
• This should include a breakdown of workers who reside at home (i.e. workers from the
community), workers who lodge within the local community and workers in on-site accommodation.
Where possible, it should also identify workers that may be more at risk from COVID-19, those with
underlying health issues or who may be otherwise at risk.
• Consideration should be given to ways in which to minimize movement in and out of site. This
could include lengthening the term of existing contracts, to avoid workers returning home to
affected areas, or returning to site from affected areas.
• Workers accommodated on site should be required to minimize contact with people near the site,
and in certain cases be prohibited from leaving the site for the duration of their contract, so that
contact with local communities is avoided.
• Consideration should be given to requiring workers lodging in the local community to move to site
accommodation (subject to availability) where they would be subject to the same restrictions.
• Workers from local communities, who return home daily, weekly or monthly, will be more difficult
to manage. They should be subject to health checks at entry to the site (as set out above) and at
some point, circumstances may make it necessary to require them to either use accommodation on
site or not to come to work.
(b) ENTRY/EXIT TO THE WORK SITE AND CHECKS ON COMMENCEMENT OF WORK

Entry/exit to the work site should be controlled and documented for both workers and other parties,
including support staff and suppliers. Possible measures may include:
• Establishing a system for controlling entry/exit to the site, securing the boundaries of the site, and
establishing designating entry/exit points (if they do not already exist). Entry/exit to the site should
be documented.
• Training security staff on the (enhanced) system that has been put in place for securing the site
and controlling entry and exit, the behaviors required of them in enforcing such system and any
COVID -19 specific considerations.
• Training staff who will be monitoring entry to the site, providing them with the resources they
need to document entry of workers, conducting temperature checks and recording details of any
worker that is denied entry.
• Confirming that workers are fit for work before they enter the site or start work. While procedures
should already be in place for this, special attention should be paid to workers with underlying
health issues or who may be otherwise at risk. Consideration should be given to demobilization of
staff with underlying health issues.
• Checking and recording temperatures of workers and other people entering the site or requiring
self-reporting prior to or on entering the site.
• Providing daily briefings to workers prior to commencing work, focusing on COVID-19 specific
considerations including cough etiquette, hand hygiene and distancing measures, using
demonstrations and participatory methods.
• During the daily briefings, reminding workers to self-monitor for possible symptoms (fever, cough)
and to report to their supervisor or the COVID-19 focal point if they have symptoms or are feeling
unwell.
• Preventing a worker from an affected area or who has been in contact with an infected person
from returning to the site for 14 days or (if that is not possible) isolating such worker for 14 days.
• Preventing a sick worker from entering the site, referring them to local health facilities if necessary
or requiring them to isolate at home for 14 days.
(c) GENERAL HYGIENE

Requirements on general hygiene should be communicated and monitored, to include:
39
• Training workers and staff on site on the signs and symptoms of COVID-19, how it is spread, how to
protect themselves (including regular handwashing and social distancing) and what to do if they or
other people have symptoms (for further information see WHO COVID-19 advice for the public).
• Placing posters and signs around the site, with images and text in local languages.
• Ensuring handwashing facilities supplied with soap, disposable paper towels and closed waste bins
exist at key places throughout site, including at entrances/exits to work areas; where there is a
toilet, canteen or food distribution, or provision of drinking water; in worker accommodation; at
waste stations; at stores; and in common spaces. Where handwashing facilities do not exist or are
not adequate, arrangements should be made to set them up. Alcohol based sanitizer (if available,
60-95% alcohol) can also be used.
• Review worker accommodations, and assess them in light of the requirements set out in IFC/EBRD
guidance on Workers’ Accommodation: processes and standards, which provides valuable guidance
as to good practice for accommodation.
• Setting aside part of worker accommodation for precautionary self-quarantine as well as more
formal isolation of staff who may be infected (see paragraph (f)).
(d) CLEANING AND WASTE DISPOSAL

Conduct regular and thorough cleaning of all site facilities, including offices, accommodation,
canteens, common spaces. Review cleaning protocols for key construction equipment (particularly if
it is being operated by different workers). This should include:
• Providing cleaning staff with adequate cleaning equipment, materials and disinfectant.
• Review general cleaning systems, training cleaning staff on appropriate cleaning procedures and
appropriate frequency in high use or high-risk areas.
• Where it is anticipated that cleaners will be required to clean areas that have been or are
suspected to have been contaminated with COVID-19, providing them with appropriate PPE: gowns
or aprons, gloves, eye protection (masks, goggles or face screens) and boots or closed work shoes. If
appropriate PPE is not available, cleaners should be provided with best available alternatives.
• Training cleaners in proper hygiene (including handwashing) prior to, during and after conducting
cleaning activities; how to safely use PPE (where required); in waste control (including for used PPE
and cleaning materials).
• Any medical waste produced during the care of ill workers should be collected safely in designated
containers or bags and treated and disposed of following relevant requirements (e.g., national,
WHO). If open burning and incineration of medical wastes is necessary, this should be for as limited
a duration as possible. Waste should be reduced and segregated, so that only the smallest amount
of waste is incinerated (for further information see WHO interim guidance on water, sanitation and
waste management for COVID-19).
(e) ADJUSTING WORK PRACTICES

Consider changes to work processes and timings to reduce or minimize contact between workers,
recognizing that this is likely to impact the project schedule. Such measures could include:
• Decreasing the size of work teams.
• Limiting the number of workers on site at any one time.
• Changing to a 24-hour work rotation.
• Adapting or redesigning work processes for specific work activities and tasks to enable social
distancing, and training workers on these processes.
• Continuing with the usual safety trainings, adding COVID-19 specific considerations. Training
should include proper use of normal PPE. While as of the date of this note, general advice is that
construction workers do not require COVID-19 specific PPE, this should be kept under review (for
further information see WHO interim guidance on rational use of personal protective equipment
(PPE) for COVID-19).
40
• Reviewing work methods to reduce use of construction PPE, in case supplies become scarce or the
PPE is needed for medical workers or cleaners. This could include, e.g. trying to reduce the need for
dust masks by checking that water sprinkling systems are in good working order and are maintained
or reducing the speed limit for haul trucks.
• Arranging (where possible) for work breaks to be taken in outdoor areas within the site.
• Consider changing canteen layouts and phasing meal times to allow for social distancing and
phasing access to and/or temporarily restricting access to leisure facilities that may exist on site,
including gyms.
• At some point, it may be necessary to review the overall project schedule, to assess the extent to
which it needs to be adjusted (or work stopped completely) to reflect prudent work practices,
potential exposure of both workers and the community and availability of supplies, taking into
account Government advice and instructions.
(f) PROJECT MEDICAL SERVICES

Consider whether existing project medical services are adequate, taking into account existing
infrastructure (size of clinic/medical post, number of beds, isolation facilities), medical staff,
equipment and supplies, procedures and training. Where these are not adequate, consider
upgrading services where possible, including:
• Expanding medical infrastructure and preparing areas where patients can be isolated. Guidance on
setting up isolation facilities is set out in WHO interim guidance on considerations for quarantine of
individuals in the context of containment for COVID-19). Isolation facilities should be located away
from worker accommodation and ongoing work activities. Where possible, workers should be
provided with a single well-ventilated room (open windows and door). Where this is not possible,
isolation facilities should allow at least 1 meter between workers in the same room, separating
workers with curtains, if possible. Sick workers should limit their movements, avoiding common
areas and facilities and not be allowed visitors until they have been clear of symptoms for 14 days. If
they need to use common areas and facilities (e.g. kitchens or canteens), they should only do so
when unaffected workers are not present and the area/facilities should be cleaned prior to and after
such use.
• Training medical staff, which should include current WHO advice on COVID-19 and
recommendations on the specifics of COVID-19. Where COVID-19 infection is suspected, medical
providers on site should follow WHO interim guidance on infection prevention and control during
health care when novel coronavirus (nCoV) infection is suspected.
• Training medical staff in testing, if testing is available.
• Assessing the current stock of equipment, supplies and medicines on site, and obtaining additional
stock, where required and possible. This could include medical PPE, such as gowns, aprons, medical
masks, gloves, and eye protection. Refer to WHO guidance as to what is advised (for further
information see WHO interim guidance on rational use of personal protective equipment (PPE) for
COVID-19).
• If PPE items are unavailable due to world-wide shortages, medical staff on the project should agree
on alternatives and try to procure them. Alternatives that may commonly be found on constructions
sites include dust masks, construction gloves and eye goggles. While these items are not
recommended, they should be used as a last resort if no medical PPE is available.
• Ventilators will not normally be available on work sites, and in any event, intubation should only be
conducted by experienced medical staff. If a worker is extremely ill and unable to breathe properly
on his or her own, they should be referred immediately to the local hospital (see (g) below).
• Review existing methods for dealing with medical waste, including systems for storage and
disposal (for further information see WHO interim guidance on water, sanitation and waste
management for COVID-19, and WHO guidance on safe management of wastes from health-care
activities).
41
(g) LOCAL MEDICAL AND OTHER SERVICES
Given the limited scope of project medical services, the project may need to refer sick workers to
local medical services. Preparation for this includes:
• Obtaining information as to the resources and capacity of local medical services (e.g. number of
beds, availability of trained staff and essential supplies).
• Conducting preliminary discussions with specific medical facilities, to agree what should be done in
the event of ill workers needing to be referred.
• Considering ways in which the project may be able to support local medical services in preparing
for members of the community becoming ill, recognizing that the elderly or those with pre-existing
medical conditions require additional support to access appropriate treatment if they become ill.
• Clarifying the way in which an ill worker will be transported to the medical facility, and checking
availability of such transportation.
• Establishing an agreed protocol for communications with local emergency/medical services.
• Agreeing with the local medical services/specific medical facilities the scope of services to be
provided, the procedure for in-take of patients and (where relevant) any costs or payments that may
be involved.
• A procedure should also be prepared so that project management knows what to do in the
unfortunate event that a worker ill with COVID-19 dies. While normal project procedures will
continue to apply, COVID-19 may raise other issues because of the infectious nature of the disease.
The project should liaise with the relevant local authorities to coordinate what should be done,
including any reporting or other requirements under national law.
(h) INSTANCES OR SPREAD OF THE VIRUS

WHO provides detailed advice on what should be done to treat a person who becomes sick or
displays symptoms that could be associated with the COVID-19 virus (for further information see
WHO interim guidance on infection prevention and control during health care when novel
coronavirus (nCoV) infection is suspected). The project should set out risk-based procedures to be
followed, with differentiated approaches based on case severity (mild, moderate, severe, critical)
and risk factors (such as age, hypertension, diabetes) (for further information see WHO interim
guidance on operational considerations for case management of COVID-19 in health facility and
community). These may include the following:
• If a worker has symptoms of COVID-19 (e.g. fever, dry cough, fatigue) the worker should be
removed immediately from work activities and isolated on site.
• If testing is available on site, the worker should be tested on site. If a test is not available at site,
the worker should be transported to the local health facilities to be tested (if testing is available).
• If the test is positive for COVID-19 or no testing is available, the worker should continue to be
isolated. This will either be at the work site or at home. If at home, the worker should be transported
to their home in transportation provided by the project.
• Extensive cleaning procedures with high-alcohol content disinfectant should be undertaken in the
area where the worker was present, prior to any further work being undertaken in that area. Tools
used by the worker should be cleaned using disinfectant and PPE disposed of.
• Co-workers (i.e. workers with whom the sick worker was in close contact) should be required to
stop work, and be required to quarantine themselves for 14 days, even if they have no symptoms.
• Family and other close contacts of the worker should be required to quarantine themselves for 14
days, even if they have no symptoms.
• If a case of COVID-19 is confirmed in a worker on the site, visitors should be restricted from
entering the site and worker groups should be isolated from each other as much as possible.
• If workers live at home and has a family member who has a confirmed or suspected case of COVID-
19, the worker should quarantine themselves and not be allowed on the project site for 14 days,
even if they have no symptoms.
42
• Workers should continue to be paid throughout periods of illness, isolation or quarantine, or if
they are required to stop work, in accordance with national law.
• Medical care (whether on site or in a local hospital or clinic) required by a worker should be paid
for by the employer.
(i) CONTINUITY OF SUPPLIES AND PROJECT ACTIVITIES

Where COVID-19 occurs, either in the project site or the community, access to the project site may
be restricted, and movement of supplies may be affected.
• Identify back-up individuals, in case key people within the project management team (PIU,
Supervising Engineer, Contractor, sub-contractors) become ill, and communicate who these are so
that people are aware of the arrangements that have been put in place.
• Document procedures, so that people know what they are, and are not reliant on one person’s
knowledge.
• Understand the supply chain for necessary supplies of energy, water, food, medical supplies and
cleaning equipment, consider how it could be impacted, and what alternatives are available. Early
pro-active review of international, regional and national supply chains, especially for those supplies
that are critical for the project, is important (e.g. fuel, food, medical, cleaning and other essential
supplies). Planning for a 1-2 month interruption of critical goods may be appropriate for projects in
more remote areas.
• Place orders for/procure critical supplies. If not available, consider alternatives (where feasible).
• Consider existing security arrangements, and whether these will be adequate in the event of
interruption to normal project operations.
• Consider at what point it may become necessary for the project to significantly reduce activities or
to stop work completely, and what should be done to prepare for this, and to re-start work when it
becomes possible or feasible.
(j) TRAINING AND COMMUNICATION WITH WORKERS

Workers need to be provided with regular opportunities to understand their situation, and how they
can best protect themselves, their families and the community. They should be made aware of the
procedures that have been put in place by the project, and their own responsibilities in
implementing them.
• It is important to be aware that in communities close to the site and amongst workers without
access to project management, social media is likely to be a major source of information. This raises
the importance of regular information and engagement with workers (e.g. through training, town
halls, tool boxes) that emphasizes what management is doing to deal with the risks of COVID-19.
Allaying fear is an important aspect of work force peace of mind and business continuity. Workers
should be given an opportunity to ask questions, express their concerns, and make suggestions.
• Training of workers should be conducted regularly, as discussed in the sections above, providing
workers with a clear understanding of how they are expected to behave and carry out their work
duties.
• Training should address issues of discrimination or prejudice if a worker becomes ill and provide an
understanding of the trajectory of the virus, where workers return to work.
• Training should cover all issues that would normally be required on the work site, including use of
safety procedures, use of construction PPE, occupational health and safety issues, and code of
conduct, taking into account that work practices may have been adjusted.
• Communications should be clear, based on fact and designed to be easily understood by workers,
for example by displaying posters on handwashing and social distancing, and what to do if a worker
displays symptoms.
43
(k) COMMUNICATION AND CONTACT WITH THE COMMUNITY
Relations with the community should be carefully managed, with a focus on measures that are being
implemented to safeguard both workers and the community. The community may be concerned
about the presence of non-local workers, or the risks posed to the community by local workers
presence on the project site. The project should set out risk-based procedures to be followed , which
may reflect WHO guidance (for further information see WHO Risk Communication and Community
Engagement (RCCE) Action Plan Guidance COVID-19 Preparedness and Response). The following
good practice should be considered:
• Communications should be clear, regular, based on fact and designed to be easily understood by
community members.
• Communications should utilize available means. In most cases, face-to-face meetings with the
community or community representatives will not be possible. Other forms of communication
should be used; posters, pamphlets, radio, text message, electronic meetings. The means used
should take into account the ability of different members of the community to access them, to make
sure that communication reaches these groups.
• The community should be made aware of procedures put in place at site to address issues related
to COVID-19. This should include all measures being implemented to limit or prohibit contact
between workers and the community. These need to be communicated clearly, as some measures
will have financial implications for the community (e.g. if workers are paying for lodging or using
local facilities). The community should be made aware of the procedure for entry/exit to the site, the
training being given to workers and the procedure that will be followed by the project if a worker
becomes sick.
• If project representatives, contractors or workers are interacting with the community, they should
practice social distancing and follow other COVID-19 guidance issued by relevant authorities, both
national and international (e.g. WHO).
6. EMERGENCY POWERS AND LEGISLATION

Many Borrowers are enacting emergency legislation. The scope of such legislation, and the way it
interacts with other legal requirements, will vary from country to country. Such legislation can cover
a range of issues, for example:
• Declaring a public health emergency
• Authorizing the use of police or military in certain activities (e.g. enforcing curfews or restrictions
on movement)
• Ordering certain categories of employees to work longer hours, not to take holiday or not to leave
their job (e.g. health workers)
• Ordering non-essential workers to stay at home, for reduced pay or compulsory holiday
Except in exceptional circumstances (after referral to the World Bank’s Operations Environmental
and Social Review Committee (OESRC)), projects will need to follow emergency legislation to the
extent that these are mandatory or advisable. It is important that the Borrower understands how
mandatory requirements of the legislation will impact the project. Teams should require Borrowers
(and in turn, Borrowers should request Contractors) to consider how the emergency legislation will
impact the obligations of the Borrower set out in the legal agreement and the obligations set out in
the construction contracts. Where the legislation requires a material departure from existing
contractual obligations, this should be documented, setting out the relevant provisions.
RESOURCES
WHO Guidance
Advice for the public
44
WHO advice for the public, including on social distancing, respiratory hygiene, self-quarantine, and
seeking medical advice, can be consulted on this WHO website:
https://www.who.int/emergencies/diseases/novel-coronavirus-2019/advice-for-public
Technical guidance
Infection prevention and control during health care when novel coronavirus (nCoV) infection is
suspected, issued on 19 March 2020
Coronavirus disease (COVID-19) outbreak: rights, roles and responsibilities of health workers,
including key considerations for occupational safety and health, issued on 18 March 2020
Risk Communication and Community Engagement (RCCE) Action Plan Guidance COVID-19
Preparedness and Response, issued on 16 March 2020
Considerations for quarantine of individuals in the context of containment for coronavirus disease
(COVID-19), issued on 19 March 2020
Operational considerations for case management of COVID-19 in health facility and community,
issued on 19 March 2020
Rational use of personal protective equipment for coronavirus disease 2019 (COVID-19), issued on
27 February 2020
Getting your workplace ready for COVID-19, issued on 19 March 2020
Water, sanitation, hygiene and waste management for COVID-19, issued on 19 March 2020
Safe management of wastes from health-care activities issued in 2014
Advice on the use of masks in the community, during home care and in healthcare settings in the
context of the novel coronavirus (COVID-19) outbreak, issued on March 19, 2020
ILO GUIDANCE
ILO Standards and COVID-19 FAQ, issued on March 23, 2020 (provides a compilation of answers to
most frequently asked questions related to international labor standards and COVID-19)
MFI GUIDANCE
IDB Invest Guidance for Infrastructure Projects on COVID-19: A Rapid Risk Profile and Decision
Framework
KfW DEG COVID-19 Guidance for employers, issued on 31 March 2020
CDC Group COVID-19 Guidance for Employers, issued on 23 March 2020
45
LMP Resources
 World Bank. 2020. Labor Management Procedures. Caribbean Digital Transformation Program
(P171528). Dominica, Grenada, Saint Lucia, Saint Vincent and the Grenadines. April 29, 2020
 World Bank. 2018. Good Practice Note Addressing Gender Based Violence in Investment Project
Financing involving Major Civil Works.
http://documents1.worldbank.org/curated/en/399881538336159607/Environment-and-Social-
Framework-ESF-Good-Practice-Note-on-Gender-based-Violence-English.pdf
 World Bank. Guidance Note for Borrowers. Environmental & Social Framework for IPF
Operations ESS2: Labor and Working Conditions.
http://documents1.worldbank.org/curated/en/149761530216793411/ESF-Guidance-Note-2-
Labor-and-Working-Conditions-English.pdf
 World Bank. Interim Note. Covid-19 Considerations in Construction and Civil Works Projects
 World Bank. Labour Management Procedures for Western Economic Corridor and Regional
Enhancement Program (WeCARE) April 2020. Local Government Engineering Department (LGED)
Ministry of Local Government, Rural Development & Cooperatives, Bangladesh.
http://documents1.worldbank.org/curated/en/447451587417825874/pdf/Labor-Management-
Procedures-Western-Economic-Corridor-and-Regional-Enhancement-Program-P169880.pdf
 World Bank. The World Bank Labor Management Procedures Template: Version 1.0 – September
6, 2018 http://pubdocs.worldbank.org/en/755121538513950752/Labor-Management-
Procedures.docx
 World Health Organisation. 2020. Getting Your Workplace Ready for COVID-19.
https://www.who.int/docs/default-source/coronaviruse/getting-workplace-ready-for-covid-
19.pdf
46

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World Bank

Unleashing the Blue Economy of the Caribbean (UBEC)

Labour Management Procedures (LMP)

1. Promote safety and health at work;

COMPONENT 1: STRENGTHENING GOVERNANCE, POLICIES AND CAPACITY BUILDING FOR KEY

Subcomponent 1.1 Strengthening Regional Policies, Institutions and Coordination: This

COMPONENT 2 - SCALE UP ACCESS TO FINANCE AND INFRASTRUCTURE INVESTMENTS IN

COMPONENT 3: CONTINGENT EMERGENCY RESPONSE COMPONENT (CERC)

COMPONENT 4 - PROJECT MANAGEMENT, COMMUNICATION AND REGIONAL COORDINATION

Institutional Structure for Project Implementation

3. OVERVIEW OF LABOUR USE ON THE PROJECT

Project Labour Requirements

4. ASSESSMENT OF KEY POTENTIAL LABOUR RISKS

Table 1 Summary of Project Risks and Proposed Mitigation Measures

5. OVERVIEW OF LABOUR RELATIONS AND OCCUPATIONAL HEALTH

Table 2 Summary of National Legal Frameworks and Gaps related to ESS2

All three countries have legislation

Labour Relations and OCH Legislation in Grenada

Table 3 Grenada National Labour Legislation6

Labour Relations and OCH Legislation in Saint Lucia

Table 4 Saint Lucia National Labour Legislation

Table 5 Saint Vincent and the Grenadines National Labour Legislation

7. OHS POLICIES AND PROCEDURES

7.1 OHS Purpose

7.3 OHS Measures /procedures

There will be no retaliation to project workers for stop-work whistle blowing.

7.4 OHS Policy Dissemination and Awareness

Table 6 The age of employment in the project countries

Grenada - Minimum Working Age National Legislation

Saint Lucia – Minimum Working Age National Legislation

9 TERMS AND CONDITIONS OF EMPLOYMENT

SAINT VINCENT AND THE GRENADINES

Protection against dismissal without good cause

Termination after fixed term of employment

Terms of employment in writing

10 GRIEVANCE REDRESS MECHANISM

GRM Point of Contact

Table 7 GRM Points of Contact (TO BE COMPLETED)

Addressing gender-based violence

12. PRIMARY SUPPLY WORKERS

National government, OECS, contractor and beneficiary employees involved in project

13. COMMUNITY WORKERS

I, ______________________________, staff at the PIU in [name of Ministry/Agency where the PIU

1. carry out my duties competently and diligently.

Regarding equality of opportunity and treatment

Regarding discrimination and violence based on gender

Regarding children under the age of 18

Infringements sanctioned with verbal notification

Infringements sanctioned with written notification

Infringements sanctioned with termination of employment

Printed Name: _________________________

Name of GBV Service provided Contact

Cedars Home Shelter facility Undisclosed. But information on services

Civil Society Organisations

Grenada Sexual and reproductive health services and Grenville, Grenada

Name GBV Service Contact

Gender Affairs Receives reports and provides http://mobilization.gov.vc/mobilization/index.php/ge

Royal Saint Emergency response, Criminal Investigation Division (CID)