According to the Project Appraisal Document (PAD), this project poses high environmental and social risks and substantial risk of sexual exploitation, abuse and harassment (SEA/H). Children and adolescents are particularly vulnerable to SEA/H in large infrastructure projects. This can be exacerbated due to other existing risk factors around this project, including the high prevalence of SEA/H in the project area,the existing risks of child labor, and the presence of out of school children and street children in the project area.
Concerned about child SEA/H risks, BIC, along with UPENDO YA WAKONGOMANI ELEKEYA MWANAMKE NA MTOTO (UWEMA) ASBL, started to monitor this project in September 2022. In October 2022 and May 2023, UWEMA ASBL visited and conducted focus groups discussions with community members in the project site for the construction of the OZONE water catchment plant in the commune of Ngaliema and in the commune of N'djili, respectively. This included a particular focus on the construction of the Luemba and Maître Croquet avenues, the reconstruction of the Maison Communale de N'djili, and the development of public spaces, namely the Place Communale and Place Sainte Thérèse.
Based on findings and concerns arising from field work and meetings with Government officials, we provide the following recommendations to the Bank and the Borrower:
Implement SEA/H safeguarding measures. Project documents, including the PAD and the SEA/H Action Plan, list prevention and response measures to SEA/H, such as a grievance redress mechanism (GRM), hiring local workers to avoid labor influx; a mandatory Code of Conduct (CoC) for project workers to set clear expectations around gender-based violence (GBV), SEA/H, and child labor; and a GBV response protocol with details on service providers to which SEA/H survivors will be referred, among others. However, in some instances the implementation of certain SEA/H prevention measures has not yet been fully executed, and they are not being consistently applied across all locations. For instance, the GRM was not fully operational, as the organization responsible for managing cases of SEA/H had not been contracted and training on GBV did not deeply focus on SEA/H project-related risk and did not reach a significant amount of the population. It is crucial to put in place these SEA/H measures before project implementation begins in all project areas to prevent any potential harm.
Sensitize the community around GBV, SEA/H and violence against children (VAC). UWEMA ASBL's project monitoring work revealed a lack of community awareness regarding GBV and child SEA/H. UWEMA ASBL notes that some consultations were organized in N'djili in the context of the development of the Resettlement Plan and general concepts of GBV and SEA/H were shared. However, during the focus group organized by UWEMA ASBL, many of the participants, including those from local civil societies, seemed to only have basic knowledge of the concepts of GBV, SEA/H, and VAC. Additionally, UWEMA ASBL noted that those who have received some training have not necessarily replicated it with other community members. Moreover, many community members were unaware that the project plans to have a GRM and they claimed to not know where to report cases of SEA/H. This lack of awareness was compounded by the perception of SEA/H as a taboo issue, leading to underreporting of cases. The Bank should call the implementing unit to broaden the scope of awareness-raising among community members, strengthen sensitization by providing specific training on how to identify and prevent SEA/H, and develop awareness-raising materials using innovative children and youth communication channels, such as social media, to share key GVB and SEA/H prevention messages.
Expedite the recruitment process for the dedicated GBV/SEA/H CSO in charge of handling SEA/H cases. Until early September 2023, the recruitment process for the CSO that will handle SEA/H cases was still underway. UWEMA ASBL met with the two other CSOs hired by the project, REJEER (Réseau des Educateurs des Enfants et Jeunes de la Rue), and CODELT (Conseil pour la Défense Environnementale par la Légalité et la Traçabilité). CODELT is working in the community of N’djili. Both organizations indicated to have knowledge of GBV and SEA/H issues, and claimed to have incorporated SEA/H and GBV topics in their sensitization workshops. However, both noted they were recruited for stakeholder mobilization activities as part of the KIN ELENDA project, not specifically to handle SEA/H cases. So far, CODELT has received complaints regarding resettlement and compensation issues and has been informed it should immediately report any SEA/H case to the implementing agency and facilitate the referral of the victim to a healthcare facility. CODELT assured that they possess the necessary resources to provide comprehensive care in relation to such cases. However, it was acknowledged that once the specialized CSO is contracted, the duty of handling SEA/H complaints will be transferred to them.
Set up a GRM to handle SEA/H, including child SEA/H, in a sensitive manner. Project documents commit to set up a GRM that treats SEA/H complaints ethically, safely, and confidentially. The SEA/H Action Plan also sets special provisions on how to treat child SEA/H complaints and to provide all SEA/H victims with referral to appropriate services. Yet, as of early September 2023, the GRM was not yet fully operational, and lacked capacity to handle SEA/H cases. The GBV specialist of the implementing unit informed us that no case of SEA/H has been reported and that the GRM is being piloted, pending contracting of the specialized CSO that will handle SEA/H cases. Some members of the community indicated that they knew of other GBV case management services where they could report cases of SEA/H and receive psychosocial support, such as the One Stop Center system that is set up in a number of referral hospitals, including the N’djili referral hospital and the PANZI foundation, although these are not directly linked to the project. It is also important to acknowledge that a certain degree of reluctance exists within the local community when it comes to utilizing these services, primarily due to stigmatization concerns. Awareness raising around reporting should be heightened and there should be multiple reporting methods available (including the provision of a toll-free hotline and community focal points).
Strengthen local capacities to handle SEA/H cases. According to UWEMA ASBL’s findings, healthcare facilities within the project's geographic areas are insufficient and often lack the personnel and resources to adequately support victims of GBV and SEA/H. In order to guarantee effective and permanent care for survivors throughout the project cycle, investment in training personnel and equipping health centers with the necessary means to handle these cases is urgent.
Address gender inequality and employment challenges identified in the project documentation in project implementation. The PAD recognizes that labor influx poses a serious risk to the project and acknowledges social risks are related to “conflicts arising from non-utilization of local manual labor, and the potential exclusion of, or discrimination against, certain groups (such as women and youth) in employment opportunities.” Additionally, it indicates that the project will contribute to “extensive skill development, with a focus on vulnerable groups” and “address structural sources of inequality throughout, by targeting activities to empower and integrate vulnerable groups and left-behind neighborhoods.” However, during the field visits, UWEMA ASBL received several complaints from the local community about their lack of participation in the project's workforce. It seems that job information is only spread through word of mouth, and men are more likely to hear about these opportunities than women, who are at home taking care of domestic work. Additionally, when UWEMA ASBL met with the Chinese company working in the OZONE project water treatment plant in October 2022, it noted a low number of female staff (one woman in charge of GBV issues, a Chinese language interpreter, and two female cleaners). When asked about this issue, UWEMA ASBL was told that women lacked the needed expertise (including in electricity and construction). Therefore, it is important to implement the project as outlined in project documents and focus on training women and youth to join this project’s workforce and making job opportunities available to everyone, as outlined in project documents.
Enhance awareness and strengthen measures to prevent child labor. During focus group discussions, UWEMA ASBL observed a lack of comprehensive understanding among participants regarding the definition of child labor and that children should not be engaged in project-related activities. The Social Affairs Department of the Commune of N'djili informed UWEMA ASBL that they are setting up mechanisms to oversee compliance to prevent child labor around the project. Moving forward, the efficiency of these measures should be assessed on an ongoing basis and awareness campaigns should be intensified, particularly considering the unique characteristics prevalent in the communities where the project is slated for implementation that include high population density, elevated poverty rates, and the existence of unaccompanied street children.
Accelerate compensation and promote economic empowerment and gender equity in compensation and resettlement strategies. Although some community members received compensation before the project began, a significant number of people affected by the project reported that they have yet to receive it. During interviews, UWEMA ASBL found out that some women who received compensation from the project lacked the necessary support and training to manage their funds effectively, resulting in the loss of their compensation money. This underscores the need for targeted financial management support and training in women's economic empowerment.
Improve stakeholder engagement and consult with children. While there have been consultations at both institutional and community levels in some project areas, interviews with community members suggest that the engagement process was inadequate. Many participants reported that they were not involved in any consultation and, as per UWMEMA’s knowledge, children were not engaged in meaningful consultations at any point. This lack of stakeholder engagement highlights the need for more inclusive and transparent engagement processes that actively involve all relevant stakeholders, especially those who are most negatively impacted by the project.
Demarcate project sites. UWEMA ASBL found no project sign in the N’djili community indicating the name of the project, the possible start of rehabilitation work, and a place or number to report SEA/H cases and other project complaints. The lack of signage highlighting current and future project sites impedes community awareness of the project and can potentially lead to obstacles in community engagement, access to potential job opportunities, and access to information.
