US Agency for International Development (USAID) / India

US Agency for International Development (USAID) / India

REQUEST FOR CATEGORICAL EXCLUSION

Swasti Health Resource Centre for the Knowledge Partner to USAID/ India

Program/Project/Activity Data:

Activity/Project Title: Knowledge Partner for Health / Solicitation #: 386-13-0000006
Contract /Award Number (if known): TBD
Geographic Location : India; 386,
Originating Bureau/Office: USAID/India, Health Office
Supplemental IEE: ☐ Yes ☒No
Amendment: ☐Yes ☒No
Programmatic IEE: ☐Yes ☒No / DCN and date of Original document: N.A
DCN and ECD link (s) of Amendment (s): N.A
Amendment No: N.A
Funding Amount: $1.55 Million / Life of Project Amount: 5 Million USD
Implementation Start/End: FY 2017 April/ FY 2021 April
Prepared By:Subrato Mondal, Health Unit / Date Prepared: April 11, 2017
Expiration Date (if any): / Reporting due dates (if any): N.A
Environmental Media and /or Human Health Potentially Impacted (check all that apply)
None ☒Air ☐ Water ☐ Land ☐ Biodiversity ☐Human Health ☐Other ☐
Recommended Threshold Determination:
☐Negative Determination ☐With Conditions
☒Categorical Exclusion
☐Positive Determination / ☐Deferral
☐Exemption
☐USG Domestic NEPA action
Climate Change
☐GCC/Adaptation ☐GCC/Mitigation ☐Climate Change Vulnerability Analysis (included)
Adaptation/Mitigation Measures: Not Applicable

SUMMARY OF FINDINGS

Pursuant to 22 CFR 216.2(a), environmental analysis/evaluation is required for new projects, programs or activities authorized by USAID.This Initial Environmental Examination (IEE) evaluates activities being undertaken by the Swasti Health Resource Centre, for the Knowledge Partner to USAID/ India program under the USAID/India Partnerships APS over a period of fouryears.

RECOMMENDED ACTION:

(i) Categorical Exclusion. Pursuant to 22 CFR 216.2(c) (3), the originator of the activities (USAID/India Health Office (HO)) has determined that “core” program activities,which includetechnical assistance, training and capacity building, are environmentally neutral actions (see Table I) and consist of interventions entirely within the categories listed in 216.2(c) (2) and are therefore recommended to be categorically excluded by falling under the following classes of actions:

The action does not have an effect on the natural or physical environment{22 CFR 216.2(c)(1)(i)};
Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.) {22 CFR 216.2(c)(2)(i)};
Document and information transfers {22 CFR 216.2(c)(2)(iv)}.

(ii)Climate Risk Screening: Based on the initial screening of the project against the climate change effects indicate that the activities don’t pose social or environmental risks that need to be further analyzed through additional steps of the identification process. Based on an analysis, none of the proposed project activities will effect climate change and eco-systems and cause GHG emissions. The project area is not exposed to climate hazards like cyclones, droughts, floods and storm surges. There are no demographic and socio-economic aspects of the project that increase the vulnerability of the project to climate change.

1. BACKGROUND AND ACTIVITY DESCRIPTION

1.1 Purpose and Scope of the IEE

The purpose of this RCE is to reflect on potential environmental impact under the India Partnership APS environmentactivity –the ‘Knowledge Partner to USAID/ India’to be implemented over four years.

1.2 Background

The U.S. Agency for International Development (USAID) is committed to increasing dramatically the sustainable impact of our development assistance programs in India through partnerships between the public and private sectors. Given that the flow of private resources far surpasses the flow of official development assistance, this Annual Program Statement (APS) recognizes and seeks to capitalize on this opportunity. Public-private Partnerships enable the Agency to leverage private sector innovation, markets, expertise, interests, and assets, along with public resources from a variety of contributors, in a manner that solves critical development problems and promotes effective, sustainable development, either through market-led solutions or public pathways. This India Partnership APS is designed to catalyze, facilitate, and support such collaboration.

Under the new activity, USAID is partnering with theSwasti Health Resource Centre to systematically facilitate learning and knowledge sharing within, among and outside the USAID Health Portfolio partners. As Knowledge Partner to USAID India, Swasti will:

Understand learning and knowledge requirements of Projects/Programs, USAID and other global partners (emanating out of India);
Develop framework, mechanisms and capacities to capture learning and knowledge within and across Projects/Programs of health portfolio;
Facilitate learning and knowledge sharing through innovative methods, within and across Projects/Programs of health portfolio;
Conduct rapid, incisive and insightful studies and evaluations which answer clearly framed and context questions; and
Summarize, synthesize and distil key sectoral /knowledge at Portfolio level through a variety of products and platforms.

1.3Description of Activities

The program has the following components:

SI. / Products / Features / Will feed into
1 / Knowledge framework / Will include the Table of content, risk assessment framework, Process Quality Monitoring, Outcome Monitoring, and Learning Framework / Strengthening of USAID Health Portfolio investments
2 / Knowledge workshops with implementing partners (IP) / Two capacity building workshops will be conducted / Effective implementation of the knowledge framework
3 / Guidelines for implementing knowledge framework / Guidelines for developing and implementing the knowledge system will be developed / Effective implementation of the knowledge framework
4 / Virtual help-desk / The help desk will respond to queries regarding reporting, indicators, assessment design, and studies / Continuous hand holding and learning support to IPs
5 / Information Needs Assessment Report / Requirement of Intervention partners, USAID members and stakeholders on the areas of studies, research / Short Studies, Research areas and design
6 / Intervention level Impact Analysis and Reports / Key intervention focused result measures and costs on agreed indicators of performance / Scale up aninvestment decision, performance assessment of interventions
7 / Theme Based Economic Model Study Report / Cost structures, leverages, type and nature of costs, cost cluster wise assessment reports / Scale up and investment decisions
8 / Thematic Studies/ Operational research study reports / Reasons such as ‘how’ and ‘why’ of the progress and impact; other issues that may emerge from the result systems / To understand in-depth about a particular phenomenon or a strategy
9 / Online Sharing Platform and Resource Repository / Development of platform which uses different online formats (youtube videos, voice clips, discussion groups, webinars) for IP’s to share information and resources / Knowledge dissemination and sharing between IP’s,
10 / Knowledge Fair / An annual knowledge fair to showcase innovations, products, models and solutions under USAID’s health portfolio. / Knowledge sharing, Learning, Networking for implementing partners
11 / Deep Dive Workshops / A series of workshops to distill knowledge in key priority areas / In depth learning for IPs
12 / Communication Materials / Creation of infographics and learning materials / Knowledge sharing across IPs and broader audiences
13 / Publications and articles / Monthly articles distributed through online platforms to inform grantees on work in the field. / Cross learning across IPs and the broader global community in priority areas.
14 / Learning Sites / Development of materials for 1 -2 sites using best practices. These include manuals, facilitator's guide, documents for IPs to learn from. / Knowledge sharing across IPs to better understand best practices and ideal models, capacity building

Leverage: Swasti did not propose any leverage, since it was not the requirement under the APS.

Geography and Beneficiaries: N/A. This activity is mainly for the internal consumption of USAID’s health project.

2. RECOMMENDED THRESHOLD DECISIONS AND MITIGATION ACTIONS

Categorical Exclusion (Please refer to the Summary Section).

The justification for recommending a determination of Categorical Exclusion for all the activities under the project is due to their nature, such as analysis, capacity building, knowledge management and communication, and other similar types of environmentally neutral actions. These are all activities that fall under classes of actions not subject to the procedures set forth on 22 CFR 216.3.

The table below lists the major activities of the Program according to Reg. 216 requirements and recommends Threshold Decisions and environmental compliance actions.

Components and illustrative activities / Effect on Natural or Physical environment / Threshold decisions and Reg.216 actions required
1 / Knowledge Partner to USAID/ India’ program / No effect / Categorical Exclusion: No action required.
2 / Training of partner employees / No effect / Categorical Exclusion: No action required.
3 / Building efficiency program involving technical assistance and capacity building of stakeholders / No effect / Categorical Exclusion: No action required.
4 / Building energy design support training and software tools / No effect / Categorical Exclusion: No action required.

3. REVISIONS

Pursuant to 22 CFR 216.3(a) (9), if new information becomes available which indicates that activities to be funded by the project might be “major” and their effects “significant,” this determination will be reviewed and revised by USAID/India and submitted to the Bureau Environmental Officer (BEO) for approval, and, if appropriate, an environmental assessment will be prepared in accordance with the procedures stipulated in 22 CFR 216. It is the responsibility of the AOR to timely inform the Mission Environment Officer and BEO of any changes in the scope and nature of the approved activities, which may require the revision of the approved Threshold Decision.

APPROVAL OF ENVIRONMENT ACTION RECOMMENDED

Clearances:
Activity Manager: / Date:
Mission Environmental Officer / Subroto Mondal
Regional Environmental Advisor for Central and South Asia and OAPA / Monali Zeya Hazra
Cleared by Email / Date:
Date: / April 27, 2017
Regional Legal Advisor: / Andrei Barannik / Date:
Deputy Mission Director: / Diana Weed / Date:
Approval:
Mission Director: / Idris Diaz / Date:
Mark A.White
Concurrence:
Bureau Environmental Officer: / Date:
William Gibson

Attachment 1

Due Diligence on Swasti Health Resource Centre for the Knowledge Partner to USAID/ India

As per the Global Development Alliance (GDA) requirements, a due diligence was conducted in accordance with ADS 204 on the partner Swasti Health Resource Centre, as the implementing partner under the ‘Knowledge Partner to USAID/ India’ program to evaluate the risks and benefits.

Per ADS 204.3.9(a), as part of the due diligence investigation of a potential alliance partner, it is essential to investigate what is often called the “triple bottom line”, whether the prospective partner is socially responsible, environmentally accountable and financially sound. Information was gathered from resources such as Factiva, and Dun & Bradstreet through USAID’s Knowledge Service Centre. Desk research was also undertaken by the technical office covering the various aspects of the due diligence. The due diligence covered five areas including corporate image, social responsibility, environmental accountability, financial soundness, and policy compatibility. The details of the assessment are provided below for each partner respectively:

Environmental Design Solutions (EDS):

Brief summary of the due diligence is produced below:

Corporate Image/Reputation:A Nexis database search returned 62 news articles since 2013 on Swasti’s projects in India. None of the articles discussed the environmental impact of Swasti’s work in India. None of the articles had any adverse reporting on Swasti.

Swasti enjoys a good public image with robust and healthy relationship with all the communities it works with. Swasti also works closely with the government both in India and in other countries as well as other non-profits, UN agencies and academia. For more on our partners visit:

It is not seeking this partnership for any PR opportunities. USAID and Swasti’s objectives are closely aligned and this partnership will help improve the performance of USAID’s health portfolio. Swasti is not expecting an exclusive partnership with USAID and understands that the program must follow USAID branding and marketing practices.

No negative information was found about the company in print or electronic media. Swasti is in not involved in any litigation. There is no evidence of tensions between Swasti and the community where it works.

Social Responsibility:Swasti is a part of the Catalyst Group. The Catalyst Group is comprised of four separate organizations: the Catalyst Management Services (CMS) a profit company, Swasti, a non-profit organization, Fuzio, a profit organization and Vrutti, non-profit organization.

Swasti has a regular health and safety plan like fire hazard safety and even conducts life skills training on emergency plans. However it does not have any plan for handling of hazardous material and prevention of environmental accidents as this is out of the Scope of the company’s work. Swasti provides accident and medical insurance to their staff, and has a strong support system to help employees in trouble.

Swasti has a comprehensive Code of Professional Practice and Conduct to promote lawful and ethical behavior by all its employees. Issues covered within the code include professional practice ethics, workplace safety, conflicts of interest, and use of company assets, non-discrimination policies, employee harassment and protection of employee information. The company’s hiring, promotion, job assignment and compensation policies are merit based. It does not discriminate because of race, color, religion, sex, national origin, age or disability. Recruitment of people with disabilities and women is encouraged in the company. Additionally, Swasti and its group affiliates have a Child Protection Policy.

Swasti does not have a union. It is not involved inthe manufacture or sale or handling of firearms or narcotics.

Environmental accountability:

Knowledge Partner for Health program has a positive impact on the environment. It is not engaged in the manufacturing of any products.

Swasti works in the technical, social and management space using human resources. Since Swasti is not involved in the infrastructural programs barring Community Water Plants and Toilet building (which have their own due diligence), they do not have this system as this is out of scope. However, Swasti have a waste disposal program under which its electronic waste, dry waste and wet waste are segregated and disposed in accordance to local safe disposal guidelines. Swasti also consciously works towards reducing carbon footprint through shared transportation, reduction of paper related work by using technology. These practiceswill be articulated into a policy during the implementation of the project.

Swasti is not ISO certified. The quality of its work is periodically reviewed and monitored through its MEL framework (Monitoring Evaluation and Learning), as well as through various reviews by operations teams, program teams as well as the governing board. As of now, there are no plans to be ISO certified.

Financial Soundness: Swasti is a registered society under the Societies Registration Act, 1960. Swasti is headquartered and registered in Bangalore. Swasti is a "local organization" and has all licenses and permits to operate as a Society and is complying with the local laws of the country like Income Tax etc.

Swasti has their own Board, which is governed by a set of By-Laws. The By-Laws consist of a Memorandum of Association and Rules and Regulations. Swasti's Memorandum of Association contains the Aims and Objects (sic.) for the establishment of Swasti. The Rules and Regulations contain the rules of conduct under which the Swasti board operates. The By-Laws identify a two tier Board consisting of a General Body and a Governing Body. The General Body membership is limited to no more than 17 members and a minimum membership of 7 members. There are 10 members of the current General Body. Swasti's Board also has a Governing Body consisting of a Chairperson, a Vice-Chairperson, a Secretary and a Treasurer.

Swasti publishes an annual report that covers the company’s earnings and expenditure, tax returns, and an independent auditor’s report. The company’s financial transactions and revenues are audited annually by certified chartered accountants and no discrepancy has ever been reported.

Policy Compatibility: Company is not listed in any United Nations sanction lists or United States Government restricted lists. It maintains a transparent account of its operations, revenue streams and human resource management. Its policies are in conformance with Indian laws for private sector enterprises.

Attachment 2

PARTNER QUESTIONNAIRE FOR INITIAL ENVIRONMENTAL EXAMINATION (IEE)

Please provide answers for your organization’s policies and practices on all the areas listed below. Please include website links if available in public domain/website such as policies, newspaper articles, etc. Please also note any written organizational policies mentioned in this questionnaire must be submitted for USAID records.

If your organization does not currently have a written policy in the areas listed below, please provide a detailed explanation on how your organization will address the topic.

A. Corporate Image

What is the company’s public image? Have there been any tensions between the community and the company?

Swasti enjoys a good public image. The organization has a robust and healthy relationship with all the communities it works with. All programs and community interventions involve active participation from the communities and led by committees and leadership in the communities. Swasti takes on a facilitator and a catalyst role, which has been much appreciated.

Swasti also works closely with the government both in India and in other countries as well as other non-profits, UN agencies and academia. For more on our partners visit:

Has there been anything in the media that would reflect negatively upon the company? If so, how has the company dealt with significant negative publicity?

No. Swasti has never been projected negatively in the media. However, we do have a Risk Mitigation plan and a mechanism to address adverse incidents in both public and social media.

Are there any pending lawsuits against the company?

Is the company looking solely for PR opportunities by aligning itself with USAID?

Is the company only or primarily looking for procurement opportunities or money from USAID?