DP World Dakar SA

MIGA has been approached by the Government of Senegal (GoS) to underwrite a guarantee covering an up to € 290 million non-shareholder loan to be made by Credit Agricole Corporate & Investment Bank of France, J.P. Morgan Chase Bank N.A. London Branch of the United Kingdom, and Standard Chartered Bank of the United Kingdom (the Lenders). The loan refinances public debt contracted by the GoS and the Government-owned Société Nationale du Port Autonome de Dakar (PAD) to increase its shareholding in DP World Dakar S.A. (DPWD). GoS is requesting MIGA to provide an up to 18-year Non-Honoring of Sovereign Financial Obligation (NHSFO) guarantee of up to € 625 million to cover the GoS’ repayment obligations under the non-shareholder loan (including interest and MIGA premium and potential swap breakage costs associated to the loan).

In 2007, DP World FZE of Dubai, the United Arab Emirates (DPW) was awarded a concession to modernize, upgrade and operate the existing container terminal at the Port of Dakar (Phase 1, for an initial 25-year term) and to develop and operate a new terminal at an adjoining site (‘Port du Futur’ or Phase 2, for an initial 25-year term from the start of Phase 2’s commercial operations). DP World Dakar S.A. (DPWD or the Project Enterprise or PE) was created to implement DPW’s responsibilities under the concession agreement, and in 2008, the Concession Agreement was transferred to DPWD. DPWD is owned by the GoS, represented by the PAD, which, following the recent share issuances and transfers agreed by the PAD, DPW and DPWD, holds 40% of DPWD, and DPW, which indirectly holds the remaining 60% of DPWD and has operational control of the company. In 2020, the concession agreement was amended, as Phase 2, the new container terminal, is now proposed to be constructed in Ndayane, approximately 50 km from the Port of Dakar.

For Phase 1, MIGA underwrote separate guarantees totaling €90 ($90.9) million in 2010, which have now expired. DPWD’s current activities include the operation and maintenance of the existing container terminal of the Port of Dakar.

Phase 2, which covers the container terminal at the Port of Ndayane as well as common marine infrastructure and social and administrative facilities for the new port, is currently in the planning phase and the feasibility and environmental studies are well advanced, Tenders for majority of works were published, with expected submissions by the end of 2022. In addition to the marine infrastructure, social administrative facilities and container terminal, the Master Plan for the development of the Port of Ndayane also includes the development by third parties to be selected by the PAD of the surrounding area, including a Free Economic Zone. It is anticipated that the construction of the new port may start in 2023; however, the studies and permits are still pending. Once the port is operational, it is anticipated that DPWD will gradually shift of the container operations from Port of Dakar to the Port of Ndayane.

The current activities of DPWD are generally site-specific, largely reversible and readily addressed through mitigation measures; however, the Project is categorized as Category A according to MIGA’s Policy on Environmental and Social Sustainability (2013) due to the planned activities of DPWD, including the potential development of the new port.

Key risk includes the capacity of DPWD to continue to manage the E&S risks and impacts of operations at the Port of Dakar, and to identify and manage the E&S risks and impacts associated with the design, construction, and operation of a greenfield port facility. Risks and impacts associated with the existing operations include handling and storage of hazardous materials, oil, and chemicals; pollution (including dust and gaseous emissions, oil spills, and noise generation); wastewater (ship wastewater); workers’ health and safety; and community health, safety, and security. In addition to these risks, E&S screening indicates that the construction of the new port could include resettlement and land acquisition and impacts on biodiversity.

While all Performance Standards are applicable to this Project, based on our current information, the Project will have impacts which must be managed in a manner consistent with the following Performance Standards:

• PS1:  Assessment and Management of Environmental and Social Risks and Impacts
• PS2:  Labor and Working Conditions
• PS3:  Resource Efficiency and Pollution Prevention
• PS4:  Community Health, Safety and Security
• PS5:  Land Acquisition and Involuntary Resettlement
• PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource
• PS8:  Cultural Heritage

In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project:

• General EHS Guidelines (2007)
• EHS Guidelines for Ports, Harbors and Terminals (2017)

Other relevant guidance includes:

• Workers’ Accommodation: processes and standards. A Guidance Note by IFC and EBRD (2009)
• Good Practice Handbook: Use of Security Forces: Assessing and Managing Risks and Impacts (2017)
• Good Practice Note: Managing Contractors’ Environmental and Social Performance (2017)
• International Treaties as the International Convention for the Prevention of Pollution from Ships (MARPOL)
• Applicable host countries regulations, especially if include E&S limits and standards more stringent than the PSs.

The following documents were reviewed by MIGA:

• DP World Sustainability Impact Policy Statement
• DP World HSE Policy
• DP World Online Sustainability Report
• PAD Presentation of the Port of Dakar
• Concession Agreement and Amendments
• DPWD Integrated Management System – 2022
• DPWD OHS Management Procedure – 2021
• DPWD HSE Management Review meeting minutes Q1 2022
• DPWD HSE Management Review End year 2021
• DPWD Contractors Management Plan – 2021  
• DPWD Waste Management Procedure – 2021
• DPWD IMO Cargo Container Management Procedure – 2021
• DPWD Air Monitoring Report (Campagnes de mesures environnementales et sanitaires du Terminal a conteneurs de DP World)

In addition to reviewing the above documents, MIGA carried out an E&S due diligence visit in September 2022 to the Project which included meeting with key staff and management, regulatory authorities, as well as visiting the Dakar Terminal. MIGA also reviewed the E&S monitoring information available from the previous MIGA guarantee, which was in place from 2010 to 2017.

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS. While the current activities are properly managed in line with MIGA’s E&S Sustainability Policy requirements, the ESAP focuses largely on future planned activities. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards.

Key environmental and social (E&S) issues associated with the Project business activities are summarized in the paragraphs that follow.

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System:

DPWD has developed a robust Integrated Management System (IMS) in line with the requirements of the MIGA PSs, ISO 14001:2015 Environmental Management Systems and ISO 45001:2018Occupational Health and Safety. The IMS policies and procedures are described in the IMS Manual (2022) and include DP World Dakar Health Safety and Environment (HSE) Policy and Manual, Procedures for the HSE Risk Identification and Management, HSE Training, Internal and External communication, Document Control, HSE Emergency Management, Monitoring and Measurement, Conformity assessment, Internal Audit, and Management Review. The IMS is audited by an independent certification agency on an annual basis. The company’s environmental strategy has three focal areas: reduce carbon emissions and energy use; enhance and restore the oceans; promote renewable energy and responsible use of natural resources and waste management; reduce waste generation through prevention, reduction, reuse and recycling. DPW social impact, which also applies to DPWD, focuses on safety, gender equality, supporting the communities it operates in, employee wellbeing, people development and human rights. DPWD’s IMS applies to all of its activities, including planned developments. Observations during the site visit indicated a high standard of management of the E&S aspects both within the current port and for future developments. Review of the IMS indicates that it is aligned with the requirements of PS1. As included in the IMS and overall Environmental and Social Strategy, the PE plans all new developments in its portfolio to ensure compliance with the UN Sustainable Development Goals (UN SDGs) and the MIGA PSs.

Policy:

As part of the IMS, DPWD has an HSE Policy (in line with the requirements of PS1, which reflects its commitment to sustainable development and to the management of E&S risks and impacts. The Policy includes objectives, environment, social and governance components, and roles and responsibilities. As stated in the policy, DPWD is strongly committed to being a leader in sustainability and demonstrating this via reporting on the environmental, social and governance impacts of its business.

DPWD has also developed, among others, the following policy documents, which are integrated into the IMS: Corporate Social Responsibility Policy; Labor and Human Rights Policy; Code of Conduct; Forced Labor and Child Labor Policy.

Identification of Risks and Impacts:

DPWD updated and renovated the existing terminal during the first operation guaranteed by MIGA in 2010. Based on the MIGA E&S monitoring and the due diligence visit for the new development, the impacts associated with the current terminal are limited, mainly related to OHS, Labor, and Environmental Management, and are all properly managed and mitigated by DPWD. DPWD submitted an HSE Statistics report, showing positive outlook, with no fatalities or LTI accidents in the past 30 months.

Per DPWD’s IMS, an ESIA (Etude D'impact Environnemental Et Social Du Projet Port De Ndayane) has been prepared referencing National Standards. This ESIA is being complemented with additional ad-hoc studies to achieve compliance also with the IFC PSs. The draft national ESIA was submitted to the Ministry of Environment in December 2021 and is currently under review. The Ministry of Environment has arranged 3 public hearings for November 2022 and is expected to issue its response to ESIA afterwards. If required, DPWD will amend the ESIA to address any comments and then finalize it to be submitted again to the Ministry of Environment for approval and the Environmental License. The E&S risks and impacts likely to be associated with the new port are consistent with those for any greenfield port development, including terrestrial and aquatic habitat alteration and related impacts on biodiversity; land acquisition and resettlement; impacts on water quality; air emissions; noise and vibration (including underwater); waste management (including general solid waste, dredge material, ballast water and oily waste); and hazardous materials management. An early draft of the ESIA has been shared with MIGA for review. Once updated to include the results of the supplemental studies and the public consultation, the ESIA will be shared again, and MIGA will review to confirm that the requirements of the PS are incorporated and disclose the ESIA on MIGA’s website (ESAP item). MIGA will liaise with DPWD and their consultants throughout the review process to advise on the adequacy of the approach and studies, as necessary.

Climate risk:

DPWD recognizes and assesses the potential materiality of both physical and transition climate-related risks.  As part of the ESIA for the new port, a climate risk assessment has been conducted. The assessment considers present and future climate hazards, including overland, riverine and coastal flooding, sea-level rise, storm surge and extreme winds. It proposes adaptation measures which should be considered in the design and operation of the new port.  As reported by the PE, the site environmental conditions will be adjusted to account for the effects of climate change over the 50-year design life of the works and that sea-level rise will be accounted for by considering a 0.4 m increase to mean sea-level. The PE will continue to engage with MIGA on climate risk management topics to ensure both the existing and new port are resilient to the effects of climate change.

Management Programs:

The PE has a robust IMS that facilitate the implementation of the Environmental and Social Management Plan (ESMP) in line with the requirements of PS1. The IMS includes (i) the policies listed above; (ii) procedures for identification of risks and impacts; (iii) management programs and plans; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) monitoring and review; and (vii) stakeholder engagement. All management plans and programs have been developed and are properly implemented by the PE, especially within the existing terminal. Based on the documentation available for MIGA to review, ESMPs adequately address E&S risks including air pollution, noise and vibration, risks to marine ecology, waste management and social risks.

The IMS requires the development of the ESMPs for construction/port extension works and port operation in line with the requirements of the Senegalese legislation, IFC PSs (2012) and Equator Principles (2003). For the new port, as part of the ESIA process, a framework ESMP for both construction and operations will be developed, which will indicate the specific ESMPs required to address identified risks and impacts. These are likely to include (among others):  Biodiversity Management and Monitoring Plan; Biodiversity Action Plan; Resettlement Action Plan; Livelihood Restoration Plan; Dredging Management Plan; Alien/Invasive Species Management Plan; Oil Spill Contingency Plan; Shoreline Management Plan. The framework ESMP will be shared with MIGA with the ESIA, and the individual ESMPs will be shared as they become available for MIGA to review to confirm compliance with the PSs and international requirements (ESAP item).

Organizational Capacity and Competency:

The PE has currently two E&S teams: a team that follows the day-to-day operation of the container terminal at the Port of Dakar, and a team that is responsible for the studies and planning for the new developments. The first team is composed by the Health, Safety and Environment (HSE) Manager, the Community and Sustainability Manager, and eleven HSE officers. The HSE and Community and Sustainability Managers report to DPWD CEO, and DPW Regional and Global HSE Managers. The team responsible for the new development includes DPWD HSE Manager and Community and Sustainability Manager, as well as one environmental, and one social specialist from PAD. Jointly, they coordinate a team of environmental and social specialists in the field. In addition, the PE has hired two external consulting firms – one local (Tropica) and one international (AECOM) – to develop all necessary studies to ensure the Project is designed, built, and operated in accordance with national law and international E&S standards and practices.

At the existing terminal, DPWD undertakes regular HSE training to ensure that all personnel and contractors have the necessary environmental awareness and competency to carry out their responsibilities. The site induction covers HSE aspects of DPWD’s activities. The site induction is undertaken before employees or contractors commence work and is renewed periodically. Records of induction training attendance are maintained. Additional training is provided where required based on the responsibilities of a role. Contractors employed by DPWD to undertake activities which have the potential to affect environmental health and safety compliance of the company, or otherwise impact upon the environment, are made aware of DPWD’s environmental health and safety management requirements. Contracts include clauses on HSE compliance and termination rights and penalties for non-compliance, if appropriate.

Emergency Preparedness and Response:

The PE has in place a full-fledged Emergency Preparedness and Response Plan. The Plan identifies proper emergency response actions, and trainings/drills are periodically held by the PE. Per the IMS’ continuous improvement process, the Plan is regularly reviewed and revised as necessary.    

Monitoring and Review:

The IMS includes a Management Review Procedure which describes the quarterly management review of the E&S aspects. Actions identified during the review are monitored by the HSE Manager with the status reported on at follow-up meetings. The internal audit program is in place and the corrective/preventive actions from the audits are systematically addressed. An internal audit by the DPW Regional HSE Manager is also conducted on the annual basis.

IMS also contains a series of monitoring plans for tracking environmental and social impacts from its operations. As reported during the site visit, periodic air quality, noise, soil, water quality monitoring is carried out at various points within the terminal. The project also monitors internal and external grievances, workers health and performance, and interactions and activities with the communities and stakeholders. DPWD currently prepares Annual Environmental and Social Performance Reports, which cover all of its activities and are submitted to DPW Headquarters for review. DPWD will also submit Annual Monitoring Reports to MIGA. During the construction phase of any new developments, frequency of reporting may be increased.

 Stakeholder Engagement:

The IMS includes a Stakeholder Engagement Plan (SEP), that identifies Project stakeholders and includes activities to engage and consult with these parties. For the existing terminal, the PE carries out continuous engagement activities with interested and affected stakeholders. Records of stakeholder engagement are maintained and the results of the implementation of the SEP are reported in the Annual Environmental and Social Performance Report to DPW.

Regarding the new developments, stakeholder engagement is incorporated into the ESIA process per national law in Senegal. For the Port of Ndayane, some engagement has been undertaken as part of the ESIA process, and full consultation on the draft ESIA is pending the review by the Ministry of Environment. As part of the draft ESIA, a preliminary SEP has been prepared which is in line with PS1 requirements. It includes stakeholder mapping and assessment, consultation and engagement strategies, grievance mechanism, roles, and responsibilities (ESAP item).

External Communication and Grievance Mechanisms & Ongoing Reporting to Affected Communities:

The IMS includes an Internal and External Communications Procedure. The PE manages and evaluates external communications based on PS1 and ISO 14001 requirements. DPWD actively participates in roundtable with the other stakeholders in the port area.

PS2:  Labor and Working Conditions

DPWD current workforce for the operation of the existing terminal comprises approximately 968 employees of which 531 are permanent DPWD employees, while 455 are outsourced and temporary workers. The same workforce it is expected to be retained once the activities will shift to the new development.  For construction of the new port, DPWD will engage an Engineering, Procurement and Construction (EPC) contractor to undertake the work.  The EPC contractor and sub-contractors are likely to have an estimated workforce of almost 500 workers. As part of the ESIA, a Local Procurement and Employment Plan, Occupational Health and Safety Plan, Workers Management, and Influx Management Plan have been prepared for construction of the new port, in line with DPWD IMS.

Working Conditions and Management of Worker Relationship:

The Project’s IMS and Labor Policy states the Project’s commitment to contractual and working conditions compliant with national legislation and PS2. The Human Resource Policy states DPWD’s commitment to: (i) comply with all labor laws; (ii) fair recruitment, promotion, and compensation; (iii) freedom of association and right to collective bargaining; (iv) investigate workplace complaints and take corrective action; (v) fair and transparent performance management; (vi) prohibit child, forced and / or compulsory labor; and (vii) non-discrimination and equal opportunity. As PS2 requirements apply to both the Project and its contractors, the Project has developed explicit provisions in the Labor Management and Human Rights Policy to ensure that the Project’s own policies and the PS requirements are implemented by the contractors, sub-contractors, and suppliers. The IMS contains procedures for grievance management in cases related to sexual harassment and industrial safety.

Protecting the Work Force:

DPWD IMS includes a general commitment to the protection of workers’ rights as well as specific guarantees related to freedom of association and non-discriminatory management practices. DPWD polices states its commitment to prohibition of forced labor and child labor, and its acceptance of organized labor and collective bargaining. The IMS also explicitly mentions the Project´s commitment to United Nations and International Labor Organization principles, including equal pay and non-discriminatory labor practices.

Occupational Health and Safety:

The IMS reportedly includes a Worker Health and Safety Management Plan describing how the Project addresses risks and impacts during operations. The goal of the Plan is “zero workplace incidents”. The Project has also developed an OHS Manual to address in more detail the specific risks that workers face, including detailed procedures for investigating and analyzing any accidents that may occur during Project construction or operation. As it was possible to observe in the field, the commitment of DPWD to OHS is very high, demonstrated also by the excellent OHS statistics of the last 30 months (zero LTIs or fatalities).

Workers Engaged by Third Parties:

In its IMS, the Contractors Management Plan expresses the DPWD’s commitment to ensuring that subcontractors have recognized integrity and the capacity to implement an E&S management system compatible with the Project’s policies and the PS requirements. The Contractor Management Plan ensures contractor compliance with national laws and the PE’s Labor Management and Local Hiring policies; access to the worker grievance mechanism by contractors´ workers; and overall compliance with PS2 requirements by contractors.

PS3:  Resource Efficiency and Pollution Prevention

Resource Efficiency:

DPWD has developed within the IMS a Sustainability and Resource Efficiency Strategy in line with UNSDGs covering the following thematic areas: increase energy efficiency within the buildings, shift from diesel powered cranes to electrical ones (both Ship to Shore (STS) gantry cranes and rubber tyred gantry (RTG) cranes). These changes will be implemented at both terminals (existing and future one). DPWD is currently evaluating other possible resource efficiency strategies. DPWD has a decarbonization strategy with carbon neutrality target by 2040 and net zero carbon emissions by 2050, with an intermediate target of 28% reduction of carbon footprint by 2030. The approach to decarbonize the operations goes through implementing current and future reduction measure, which are grouped into five pillars: 1) equipment electrification and efficiency 2) process efficiency and digitalization 3) renewable energy supply 4) low carbon fuel supply 5) carbon compensation.

For the existing terminal, operation greenhouse gas (GHG) emissions are mainly associated to the cranes operation and to the to refer containers storage. Reportedly, GHG increased during the past two years, and it is expected to be around 25,000 tonnes of carbon dioxide equivalent per year (tCO2e/year). DPWD will share current GHG emission quantification for the existing terminal and the expected ones for the new development (ESAP item).

Pollution Prevention:

As indicated under PS1, DPWD IMS includes management plans and mitigation measures to ensure pollution preventions.  

At the existing port operations, main impacts are associated with waste (both hazardous and non), wastewater, noise, and air emissions. As observed on site, all impacts are properly managed by DPWD through the application of its IMS. Tee DPWD air quality monitoring results (May 2020) show non-compliances with World Bank Group EHS General Guidelines for Particulate Matters (PM) 2.5 (averaging levels higher than 75 µg/m3 at 7 out of 11 locations, with peaks of 160 µg/m3 and 217 µg/m3 on the 24h averaging period) and 10 (averaging levels higher than 150 µg/m3 at 8 out of 11 locations, with peaks of 350 µg/m3 and 400 µg/m3 on the 24h averaging period), however, as observed also on site, these values are due to the nearby, unrelated coal and bulk material import/export dock. In any case, DPWD is continuing to monitor PM values, investigating those non compliances, proposing a health monitoring campaign for its workers, and defining other mitigation measures (ESAP item).

Project waste streams generated at the Port of Dakar are properly managed through the implementation of the IMS, as it was also possible to observe while visiting the waste management facility of the terminal during the site visit. Hazardous wastes and materials include large volumes of fuels, solvents, lubricants, and other hazardous substances used in port activities by vessels, vehicles, and equipment. The IMS includes a comprehensive waste and hazardous waste management plans in line with international requirements. In addition, to control potential spills that may occur from accidents, equipment failures, or improper operating procedures during cargo transfers or fueling activities, the Project has developed specific set of plans and procedures that are consistent with PS3 and International Convention for the Prevention of Pollution from Ships (MARPOL).

Project waste streams generated during construction will include non-hazardous solid waste such as the following: food, paper, cardboard, and other scraps generated by workers; soils from earth-leveling activities; trees and limbs removed to open roads and for facilities construction; general construction debris; and concrete. Hazardous wastes will include oily wastes and solvents typical of large construction projects. During operation, DPWD IMS will apply to the management of all waste streams and hazardous materials.

The Port of Dakar currently produce wastewater effluents that are managed through a dedicated treatment facility and the implementation of a Wastewater and Effluents Management Plan. The plan will need to be provided to MIGA for review to ensure it is in line with PS3 (ESAP item).

During construction of the new development, wastewater effluents will be mainly generated from portable bathrooms and the worker camp. Wastewater from portable bathrooms will be treated by a service provider authorized to carry out this activity. A wastewater treatment plant might be installed for the camp and overall new development. The ESIA includes a preliminary Wastewater Management Plan. During operations, the Project will implement DPWD’s IMS to ensure proper management of wastewater in line with PS3 and International Requirements.

PS4:  Community Health, Safety and Security

Community Health and Safety  

Potential community health and safety impacts associated with the operation of the existing terminal are limited. DPWD’s policies and IMS state the company’s commitment to community health and safety. Under its IMS, DPWD defines the minimum requirements to identify, prevent, mitigate, track and report on how the operations risks to community are addressed. The IMS also defines the minimum requirements for supporting and promoting human rights.

Regarding the new development, community health and safety risks are likely to be consistent with those typically expected for a large construction project (e.g., traffic, nuisance noise and dust, population influx). To address community health and safety risks, the Project has developed draft Community Health and Safety and Worker Influx Management Plans which will be updated to address any comments from MIGA prior to the start of any construction activities (ESAP item).

DPWD’s Emergency Preparedness and Response Plan includes consideration of emergencies that could affect surrounding communities. 

Security Personnel:

DPWD IMS indicate the company’s commitment to the Voluntary Principles on Security and Human Rights (VPSHR). All security personnel contracted by DPWD are required to abide by the VPSHR and must be trained in their implementation before starting duties.

PS5:  Land Acquisition and Involuntary Resettlement

No land acquisition or resettlement is required for the existing operations. The planned development will require land acquisition and involuntary resettlement. As part of the ESIA process, DWPD and PAD are currently developing a Resettlement Action Plan (RAP) in line with the requirements of PS 5 (ESAP item). In addition, DPWD will develop a resettlement policy/framework to ensure any future development will be in line with the requirements of PS5 (ESAP item).

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource:

The current operations at the existing terminal have limited impacts on biodiversity, especially associated with maintenance dredging, wastewater and water quality management, noise and vibrations (including underwater). However, the construction of a new terminal is likely to affect marine and estuarine habitat. Potential impacts will be properly assessed through a biodiversity assessment, which will include a Critical Habitats Assessment (ESAP item). If needed, a biodiversity action plan and biodiversity offset strategy will also be prepared (ESAP item). In addition, DPWD will develop a biodiversity management policy/framework to ensure any future development will be in line with the requirements of PS6 (ESAP item).

DPWD, through DPW, has publicly committed to the UN SDGs and to reduce and mitigate impacts of its operation on biodiversity, especially on the oceans. As part of this commitment, beyond mitigation of impacts associated with its operations, DPW supports conservation efforts, such as restoration of blue carbon ecosystems (mangroves, salt marshes and seagrasses) and coral reefs; the establishment of oyster/clam habitats to reduce ocean acidification; and the conservation of marine and coastal areas which protect biodiversity.

PS8:  Cultural Heritage

The activities at the existing terminal are unlikely to have any impact on cultural heritage. Regarding the new development, the potential for impacts on cultural heritage are being considered as part of the ESIA process. Once the Project footprint is finalized and the ESIA completed, a specific Cultural Resources Management Plan and Chance Find Procedure will need to be developed according to national regulation and international standards (ESAP item). In addition, DPWD will develop a cultural heritage management policy/framework to ensure any future development will be in line with the requirements of PS8 (ESAP item).

A Broad Community Support determination is not required for the Project.

The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org or at the hyperlinks below. 

• DP World Sustainability Impact Policy Statement
• DP World HSE Policy
• DP World Online Sustainability Report
• PAD Presentation of the Port of Dakar
• DPWD Integrated Management System – 2022
• DPWD OHS Management Procedure – 2021
• DPWD Contractors Management Plan – 2021 
• DPWD Waste Management Procedure – 2021
• DPWD IMO Cargo Container Management Procedure – 2021
• DPWD Air Monitoring Report (Campagnes de mesures environnementales et sanitaires du Terminal a conteneurs de DP World)

MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:

Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
E-mail: cao-compliance@ifc.org