Environmental and Social Sustainability Policy

Effective Date: October 2019
This policy supersedes all previous environmental policies.

Purpose
To reinforce Pact's commitment to be an environmentally and socially conscious organization that operates in an environmentally and socially sustainable way.

Applicability
All Pact staff and subsidiaries must comply with the corporate impact components of this policy. All Pact and subsidiary programs must comply with the environmental and social standards required by the relevant funder, as outlined below.

General Guidelines
Pact acknowledges that the world's natural resources are fragile and finite and that there is increased pressure to derive economic benefits from these resources. Economic development can also have unwanted and unforeseen consequences on communities if not planned appropriately and participatorily. To this end, Pact considers environmental and social sustainability to be important components of our corporate responsibility and consistent with our overall mission and values. We are committed to providing quality services in a manner that minimizes potential harmful environmental and social impacts.

We realize this goal by:

• Reducing Pact’s Negative Corporate Environmental and Social Impact, focused on ensuring our offices and individual staff members work in environmentally and socially sustainable ways
• Ensuring Environmental and Social Sustainability in Our Programs through the design and implementation of programs that minimize harmful environmental and social impacts while following funder rules and regulations

Reducing Pact’s Negative Corporate Environmental Impact
Pact is committed to reducing our corporate impact on the environment to the greatest extent possible and to encouraging our staff to do the same. We seek to continuously improve our environmental stewardship and to reduce the environmental footprint of our activities both at headquarters and in our country offices.

To achieve this, each Pact office, to the best of their abilities, will designate an environmental sustainability officer to ensure Pact offices and staff:

• Promote responsible and efficient use of office materials and resources throughout our offices, including paper, water, electricity, and other resources;
• Give preference to renewable over non-renewable energy sources, when feasible;
• Reduce, reuse and recycle, to eliminate waste and conserve natural resources;
• Dispose of waste safely and responsibly, including waste separation and recycling;
• Encourage increasing energy efficiency and reducing energy consumption by using energy saving devices and appliances;
• Promote environmental awareness among our employees and encourage them to work in an environmentally responsible manner;
• Encourage the use of video conferencing and virtual work, and the use of fewer flight legs on travel, when appropriate, to reduce the amount of unnecessary travel and therefore Pact's carbon footprint;
• Comply with all applicable environmental laws/regulations both in the US and in the countries where we work;
• Conduct due diligence on all funding partners’ environmental, labor, human rights, and social responsibility actions.

Reducing Pact’s Negative Corporate Social Impact
Pact safeguards its employees from subpar working conditions and affords them labor rights as per US labor laws (for Pact’s US-based staff) and applicable labor laws in each of our Country Offices. We do so through a suite of policies and manuals including:

• Affirmative Action Policy
• Anti-Discrimination and Anti-Harassment Policy
• Code of Ethics
• General Employment Practices Policy summarizing Pact’s approach to recruitment, employment of minors, work authorization, drug- and tobacco-free workplace, violence and security in the workplace, and work hours. Each of Pact’s Country Offices adapts these practices to their local laws and context.
• HIV/AIDS Policy 
• Whistleblower Protection Policy

Pact’s Risk Management team will include a review of Country Office environmental and social sustainability documentation during internal control reviews to ensure adherence.

Acknowledging and Addressing Social Sustainability Issues in Pact’s Programming
Pact is committed to identifying and addressing social issues that impact the people we serve. Specifically, Pact has established policies, guidance, and standards in the following areas:

• Labor and working conditions: Pact follows the World Bank’s Environmental and Social Framework Standard #2—related to labor and working conditions—when applicable in our programming. Pact’s own Child Protection and Combatting Trafficking in Humans policies safeguard against child and forced labor in Pact and sub-recipient projects and activities.   
• Community, health, and safety and security: Pact’s duty of care resources outline our safety and security principals and procedures. In addition, Pact is a founding member of the Voluntary Principles on Security and Human Rights in the artisanal mining sector. 
• Land acquisition and involuntary resettlement: Pact follows the International Finance Corporations (IFC) Performance Standard No.5 on Land Acquisition and Involuntary Resettlement to minimize impact on displaced peoples through mitigation measures such as fair compensation and improvements to living conditions.
• Indigenous peoples: Pact follows the principles of Free, Prior, Informed Consent (FPIC) and various human rights policies and legislation including ILO Indigenous and Tribal Peoples Convention 169 and co-developed the Applying Rights Based Approach Practical Guide under the USAID Human Rights Support Mechanism.  
• Cultural heritage: Pact follows the World Bank’s Environmental and Social Framework Standard #8—related to cultural heritage—when applicable in our programming. Pact, per project-specific Environmental Mitigation and Monitoring Plans (EMMP), takes into consideration culturally sensitive sites to minimize impact on these.  

Note that Pact has a separate Gender Mainstreaming in Programming Policy that addresses Pact’s commitment to gender equity and equality in its programming.

Ensuring Environmental and Social Sustainability in Our Programs
Pact is committed to ensuring our programs are designed and implemented in a manner that minimizes harmful environmental and social impacts while following funder rules and regulations and local laws.

Depending on the requirements of the funder and local laws, Pact may complete the following actions when designing and implementing programs. In each case the exact response will be tailored to the program’s specific requirements.

• Environmental and Social Risk Assessment: Pact will conduct a quick environmental and social risk assessment on the Opportunity Justification Form to document the potential environmental implications of the proposed activities and develop mitigation strategies in response to the risks (e.g., the development of a USAID Environmental Mitigation and Monitoring Plan or a Global Affairs Canada Environmental Assessment), including climate risk management where applicable. 
• Environmental and Social Monitoring and Reporting: Where potential negative impacts are identified in the environmental and social risk assessment, Pact will develop and implement a plan to regularly monitor the mitigation measures implemented in its programs. Reports will be shared with stakeholders according to the funder’s direction.

External Communication and Awareness
Pact will make this policy and any relevant environmental and social sustainability reports available on its public website and will manage an email inbox for the public to report environmental issues caused by Pact program operations.

Enforcement
As referenced above, Pact’s Risk Management team will include a review of country office environmental and social sustainability documentation during internal control reviews to ensure adherence to this policy. Any non-compliance will be flagged for improvement and reported to Pact’s Senior Leadership Team for resolution.