Zrenjanin Wastewater Treatment Plant

Metito Utilities Limited (MUL), part of Metito Group, signed a Concession Agreement for 25 years with the City of Zrenjanin (“the City”) of Serbia on November 9, 2020, to design, construct, own, operate, finance, and maintain the first wastewater treatment plant (WWTP) in the City (“the Project”).  

MUL is a global investor and operator of water, wastewater, and alternative energy assets, offering expert project design, engineering and financial structures along with advanced management solutions. MUL is seeking MIGA’s political risk insurance to cover its equity/quasi-equity/shareholder loan investment into the Project.  

The Project will be implemented by Begej Water d.o.o. Beograd (the “Project Enterprise” or the “PE”), a private company in Serbia established and wholly owned by MUL. The Project construction will be under the responsibility of Metito Overseas Limited (MOL), the design and construction arm of the Metito Group. IFC has been a shareholder of the Metito Group since 2007. 

The current pollution levels in the Begej River represent a severe threat to public health and to the natural ecosystems. Untreated wastewater from the City of Zrenjanin and surrounding settlements is currently being discharged into the Begej River, via the Aleksandrovacki canal. With a capacity of up to 25,000 m3/day, the proposed WWTP will treat the wastewater of approximately 88,500 residents of the City (73,500 domestic users and 15,000 industrial users).  

The Project will be in an industrial district on the outskirts of Zrenjanin, and will be connected to the existing City sewage pipeline network, which extends over 400 km. The closest residential area is located 200m North of the proposed WWTP.  

The WWTP will use an Integrated Fixed Activated Sludge (IFAS) process for biological treatment, which is a combination of an activated sludge process where the microbial growth is suspended in an aerated water mixture, and a Moving Bed Biofilm Reactor (MBBR) where the microbial growth occurs on fixed films. Biological treatment will be followed by settling and ultraviolet disinfection, before the treated effluent water is discharged through piping works to the Aleksandrovacki Canal. Sludge will be dewatered on site and disposed of by a specialized contractor.  

Associated facilities to the Project include a 1.2 km pipeline to connect the WWTP to the existing pumping station and sewerage network, and a 150-meter access road. The pipeline and access road will be constructed, operated, and maintained by the City of Zrenjanin. As per the Concession Agreement, these associated facilities will be built and managed in compliance with the IFC Performance Standards. 

This is a Category B Project according to MIGA’s Policy on Environmental and Social Sustainability (2013) because the potential environmental and social (E&S) risks associated with the Project are expected to be limited in number, site-specific, largely reversible, and readily addressed through mitigation measures. These impacts can be avoided, minimized or mitigated by adhering to applicable Performance Standards (PSs), World Bank Group (WBG) Environmental Health and Safety (EHS) guidelines and design criteria. 

Key E&S issues associated with the Project include air emissions and odors, management of waste (including sludge) and effluent, and potential legacy issues related to the economic resettlement process for the proposed site. Other potential E&S impacts include those typically related to construction activities such as increased noise, surface water, soil and groundwater contamination, management of waste, wastewater and hazardous substances, occupational health and safety (including COVID-19 risks), labor and working conditions of employees and contracted workers, and community health and safety.   

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

• 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 

Applicability of PS6 on Biodiversity Conservation and Sustainable Management of Living Natural Resources was considered during due diligence as the proposed Project site is located approximately 6 km upstream of a designated wetland site of international importance under the Ramsar Convention. However, the proposed Project is located in Modified Habitat, and no adverse impacts related to the Project are expected on the Ramsar site or other significant biodiversity values, and PS6 is therefore not triggered. 

PS7 Indigenous Peoples is not applicable since there are no Indigenous People (as defined in MIGA’s Performance Standards) in the Republic of Serbia.  

The Environmental and Social Impact Assessment (ESIA) did not reveal cultural heritage within the Project footprint, therefore PS8 on Cultural Heritage is not applicable. The Project will develop a chance find procedure in case of the identification of cultural/archeological resources in the area during the construction phase. 

In addition to the PSs, the WBG General EHS Guidelines and industry sector EHS Guidelines for Water and Sanitation apply to the Project.

The following documents were reviewed by MIGA: 

• Zrenjanin Wastewater Treatment Plant Environmental and Social Impact Assessment and Environmental and Social Management Plan prepared by WSP, October 2021; 

• Metito Group’s Quality, Health, Safety and Environment (QHSE) Policy (2019) and Group-level management plan documents; 

• Metito Group’s Employee Handbook (2011) and Human Resources Policy (2013).   

Due to COVID-19 travel restrictions, MIGA was not able to undertake a due diligence site visit. In addition to reviewing the above documentation, MIGA’s due diligence has included ongoing discussions with the Metito Project team, as well as meetings with the consultants who completed with ESIA and Representatives of the City of Zrenjanin.  

MIGA’s due diligence review considered the E&S 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 E&S Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards. Key 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: 

Metito Group (Metito) has an integrated E&S Management System (ESMS) which is certified according to  ISO 14001 (Environmental Management) and 45001 (Occupational Health and Safety). The management system was initially developed as part of IFC’s engagement with Metito.  

Metito will establish an ESMS for the Project (ESAP item), based on Metito’s Corporate policies and procedures, the findings of the Environmental and Social Impact Assessment (ESIA), applicable Serbian regulation, and the requirements of the PSs.  

Policy: 

Metito has an overarching QHSE Policy which lays out its E&S objectives and guides efforts to achieve satisfactory E&S performance. The Corporate QHSE Policy will apply to the Project. 

Identification of Risks and Impacts: 

An Environmental and Social Impact Assessment (ESIA) and corresponding Environmental Social Management Plan (ESMP) were prepared by WSP Group Africa Pty. Ltd. (WSP) to assess the potential risks and impacts of the Project and propose mitigation measures to avoid, minimize and/or control the identified risks throughout the lifespan of the Project. Due to COVID-19 travel restrictions, all field data collection and stakeholder engagement activities during the ESIA process were undertaken by a separate local Consultant, Eco-Vok 2017.  

In addition, a local Environmental Impact Assessment (EIA) compliant with national EIA requirements and processes was prepared in parallel to the ESIA. The EIA was submitted to the Serbian authorities for review and approval in January 2022, and the final version will consider any comments resulting from the authorities’ review (ESAP item). 

A climate risk screening was conducted for the Project using MIGA’s Climate Risk Screening Tool and supplementary World Bank climate datasets and materials. Based on this information, three climate hazards were identified as potential risks for the Project’s location: flooding, wildfires and extreme heat. Of these, flooding is classified as a high risk. It is expected that more floods will occur by the end of the century, with an increase of up to 20% in the frequency of 100-year floods. Hence, the design and operation of the proposed WWTP should integrate climate risks and flood alleviation measures. According to the ESIA, the Project design will incorporate features to address the flooding risk through the addition of a safety freeboard of 2.86m, having the finished ground level of 80m with an optimized backfilling requirement; however, there is no confirmation on how climate change impacts on flood-levels were assessed (ESAP item). 

The Project site is located in an industrial district and is classified as modified habitat, as the majority of the site has been altered by agricultural activities for several years. The ESIA indicates that no Critically Endangered or Endangered species were recorded in the Project area. The Vulnerable Common Carp (Cyprinus carpio), Near-Threatened Pond Turtle (Emys orbicularis) and Silver carp (Hypophthalmichthys molitrix), and Least Concern avifauna (Common Cuckoo Cuculus canorus and Black Headed Gull Larus ridibundus) and fish (Asp Leuciscus aspius) migratory species were observed, however no biodiversity value was found to be a Critical Habitat trigger. 

The Project site is located approximately 6 km upstream of the Carska Bara Special Nature Reserve, which is listed on the RAMSAR designated list of wetlands of international importance and considered as a Critical Habitat. No adverse impacts affecting the Nature Reserve are expected. 

The ESIA confirmed that the Project development would not result in any measurable effect on environmental flows of the Aleksandrovacki canal or the Begej River. Potential Project impacts include loss of modified habitat due to land clearance during construction, and leaks or discharges from the WWTP into the surrounding environment and Begej River during operations. Residual risks are expected to be low as the Project will adopt good international industry practices (GIIP) and implement mitigation measures in accordance with the ESMP. 

Management Programs: 

The Project construction will be under the responsibility of Metito Overseas Limited (MOL), part of Metito Group. The ESMP prepared as part of the ESIA provides a framework for implementation of mitigation measures throughout the life of the Project. Based on the framework ESMP, Metito Corporate policies and procedures, and the requirements of the PSs, MOL will develop an ESMP for the construction phase, which will be applicable to all contractors, subcontractors, and service providers conducting activities at the Project site (ESAP item). An ESMP for the operations phase will be developed by the PE prior to commencement of operations, as per the ESAP. 

Organizational Capacity and Competency: 

Metito has a Corporate QHSE Manager who oversees E&S matters at the group level and its subsidiaries, and who reports to the group’s management on a regular basis. Metito Corporate QHSE Manager will be responsible to ensure compliance of the Project with Metito’s policies, regulatory and MIGA E&S requirements, during construction and operations. Metito has contracted WSP to conduct the Project ESIA and handle Project-related E&S considerations during the planning phase. MOL will appoint a dedicated HSE Officer prior to the start of construction, and the Project Enterprise will hire a dedicated HSE Officer for the operations phase (ESAP item).  

  Emergency Preparedness and Response: 

As per Metito’s group-level Emergency Preparedness and Response Procedure (EPRP), an EPRP in line with good international industry requirements will be developed as part of the Project ESMS.  

Monitoring and Review: 

A monitoring and reporting system related to construction and operations will be established and implemented as part of the Project ESMS. Monitoring frequencies, methodology and indicators will reflect the risks and impacts identified in the ESIA and requirements of local regulation. In addition, the PE will prepare and submit to MIGA Annual environmental and social monitoring reports. 

Stakeholder Engagement: 

The public was informed of the Project during the ESIA process in 2021 through various channels, including posters in strategic locations and posts on the City of Zrenjanin website. As part of the ESIA process, the consultants undertook several community consultation activities with various stakeholders within the area of influence of the Project (approximately 2 km radius from the Project site), including vulnerable groups. Efforts were made towards equal representation of both men and women. Concerns raised by stakeholders included potential odors being released by the WWTP and related health impacts, the potential increase in wastewater service tariffs for communal users, and the lack of access to safe drinking water for residents. No directly affected people were identified in the ESIA. As detailed in the PS5 section, additional surveys will be undertaken to confirm whether there are any directly affected people who need to be consulted. If any directly affected people are identified, additional consultation activities will be undertaken by the Project Enterprise. 

A draft Stakeholder Engagement Plan (SEP) was developed as part of the ESIA. The Project Enterprise will update the SEP and appoint a Community Liaison Officer (CLO) prior to construction (ESAP item). 

External Communication and Grievance Mechanisms: 

The PE will establish an external grievance mechanism for the Project, based on the framework Grievance Redress Mechanism included in the ESMP and in line with PS1 (ESAP item). The grievance mechanism will include a process for communities to raise complaints related to gender-based violence and harassment, and provide avenues to submit complaints anonymously. 

Ongoing Reporting to Affected Communities: 

Reporting to affected communities will be conducted as part of the implementation of the SEP, and through the CLO.  

PS2: Labor and Working Conditions 

The Project construction will be under the responsibility of Metito Overseas Limited (MOL), part of Metito group. Construction activities will be sub-contracted to a local civil contractor. The number of sub-contracted employees at peak construction period is expected to be about a hundred, and there will be 3-5 MOL staff on site to provide guidance and oversight. Metito indicated that approximately 25-30 individuals will be employed during operations. Local labor will commute to work from their homes, while expatriates will make use of existing accommodation options in the area. No workforce accommodation will be provided. 

Working Conditions and Management of Worker Relationship: 

Metito has Human Resource (HR) policies and procedures in place at a Corporate level and indicated that Group HR policies will apply to the Project. These policies are generally aligned with the requirements of PS2. The PE will ensure that all Project-specific HR policies are consistent with PS2 and Serbian labor regulation, notably with respect to freedom of association, principles of non-discrimination and equal opportunity, sexual harassment in the workplace, wages and benefits, hours of work, parental leave, and retrenchment (ESAP item). In addition, the Corporate workplace grievance mechanism will be amended to allow Project employees to raise anonymous complaints and include a process to manage potential complaints related to gender-based violence and harassment (ESAP item).  

Protecting the Work Force:  

Metito’s commitments in relation to prohibiting child and forced labor are outlined in the Corporate Employee Handbook. The minimum employment age for Metito employees and subcontractors is 18 years.  

Occupational Health and Safety: 

The ESMP developed as part of the ESIA includes a description of occupational health & safety (OHS) risks and impacts during construction and operations, with a set of preventive measures. MOL will develop and implement an OHS Management Plan for the Project, consistent with Metito's policies and procedures, local regulatory requirements, and the framework ESMP (ESAP item). Specific measures will be included to prevent, minimize, and control exposure to chemicals, pathogens, and hazardous atmospheres during the operations phase. All employees will undergo OHS training at induction and subsequently as relevant to their job activity. As the ESIA indicated that the municipal water supply is not potable, bottles or tanks of safe drinking water will be provided to all workers.  

Workers Engaged by Third Parties: 

MOL will ensure that all sub-contractors’ activities at the Project site are undertaken in compliance with the ESMP and the Performance Standards. The PE will include E&S provisions in contracts with sub-contractors (ESAP item). As a minimum, provisions will include compliance with Serbian labor legislation, terms of OHS management (including access to safe drinking water), and access to a workers’ grievance mechanism. 

Supply Chain: 

Metito Corporate Employee Handbook includes a statement that Metito does not allow any person under the age of 18 to perform any work on behalf of a supplier or subcontractor. No high risk of child or forced labor in the Project’s primary supply chain has been identified.  

PS3: Resource Efficiency and Pollution Prevention 

Resource Efficiency: 

Metito has a Policy on the Efficient Use of Power and Water in place at Corporate level. Power will be supplied to the Project via an underground cable provided by the municipal electricity supply company. The Greenhouse Gas (GHG) emissions associated with the operations phase of the Project are not expected to be significant and therefore reporting GHG emissions to MIGA is not required.  

Pollution Prevention: 

Risks and impacts identified and evaluated in the ESIA for construction and operation of the WWTP are related to air emissions, odors, noise, effluent, and waste management. These risks and impacts are expected to be managed through Project design and mitigation measures provided in the ESMP and Project ESMS. 

Considering that the proposed Project site is small, potential impacts related to air emissions during construction are anticipated to be limited through the implementation of standard mitigation measures, as provided in the ESMP. Odor-causing air emissions of hydrogen sulphide (H2S) are expected to be generated during Project operations. Based on modelling, the ESIA predicts H2S concentrations to exceed the World Health Organization (WHO) 30-minute nuisance guideline at three of the four proximate sensitive receptors, and that more than 70% of H2S emissions are predicted to be emitted from the grit and grease removal tank. The Project Enterprise will conduct continuous H2S monitoring during operations. Should ambient air quality monitoring results indicate that H2S concentrations exceed the WHO standards, the PE will implement mitigation measures as necessary to ensure compliance with the relevant standards (ESAP item). 

A noise impact assessment was undertaken as part of the ESIA. During construction, changes in noise levels at the modelled receptor locations were all predicted to be above the 3 dB(A) threshold for annoyance as per the WBG General EHS Guidelines. The Project Enterprise will implement mitigation measures as listed in the ESMP, to avoid and reduce noise generated from construction equipment. The PE will conduct noise monitoring during the construction phase and implement additional mitigation measures as needed to comply with the WBG EHS guidelines (ESAP item). During the operational phase, the ESIA predicts noise levels to be low at nearby receptor locations. The PE will conduct annual noise monitoring in the first year of operations to confirm any impacts on receptors and assess the need for any additional mitigation measures. Results will be reported in the Annual E&S monitoring report to be prepared for MIGA. 

The ESIA mentions that the Project will use wastewater treatment technology aligned with best available techniques. The quality of influent will be monitored using an online analyzer for COD as primary indicator. Daily on-site laboratory analysis will also be conducted for key parameters. The WWTP has been designed to ensure that the treated effluent quality complies with the standards set in the Serbian legislation and the WBG General EHS guidelines, resulting in improved water quality in the Begej River downstream of the WWTP discharge point. Compliance with applicable effluent standards will be monitored daily during operations and reported to MIGA in the Annual E&S Monitoring Report.   

The WWTP includes various containment structures for wastewater along the treatment process. Leaks could permeate into the sub-soil environment, resulting in potential ground and groundwater contamination. Potential impacts of leaks due to a loss of containment or overflows are mitigated by the design of the WWTP. If an incoming flow exceeds the peak flow, the untreated effluent will discharge via an overflow back into the Aleksandrovacki Canal. Measures to mitigate these risks and impacts, including the development and implementation of an Infrastructure Maintenance and Monitoring and Service Plan and a Groundwater Monitoring Plan, were included in the framework ESMP. 

Settled organic matter generated in the WWTP will be partially recirculated to maintain the biological mass in the treatment process. The wastewater treatment process will still generate significant quantities of sludge, which will be dewatered on site before disposal. According to the ESIA, the WWTP is expected to generate approximately 13 tons of sludge per day after dewatering. Metito has included design measures to limit the release of odor from the sludge handling system, including aeration of the sludge holding tank to dilute potential emissions and maintain aerobic conditions, and the enclosure of the sludge handling systems. A Sludge and Residues Management Plan will be prepared prior to the start of operations (ESAP item). 

The Project will generate both hazardous and non-hazardous waste. Hazardous waste includes sludge and the flocculation agent (Iron trichloride). All waste generated by the WWTP will be disposed at a permitted waste disposal facility. The PE is currently considering the Sremska Mitrovica disposal facility in Serbia, which includes provision for disposal of all waste types (including sludge) that will be generated by the WWTP. As per the ESAP, the Project Enterprise will seek alternatives to sludge disposal, such as the use in agriculture, in accordance with WHO guidelines, national and European regulations.  

The ESIA indicates that groundwater in the area where the Project is located is known to contain naturally high levels of arsenic. The two groundwater samples analyzed as part of the ESIA did not comply with Serbian regulations due to exceeding concentrations of arsenic. No evidence was found to suggest groundwater contamination due to historical site activities. According to the ESIA, the high levels of arsenic in the tested groundwater samples are almost certainly related to natural occurrence. 
PS4: Community Health, Safety and Security 

Community Health and Safety: 

Potential impacts to community health, safety and security from the Project activities are expected to be readily addressed through control measures. A local civil contractor will be appointed for the construction works, and it is anticipated that most of the workers will be sourced from the local area. As the Project is relatively small in size and associated employment opportunities limited, risks related to labor influx, including Community Gender-Based Violence and communicable diseases (including Covid-19), are considered to be low.  

The main impact on community health and safety during construction relates to an increase in traffic along public roads. MOL has developed and will implement a Traffic Management Plan during the construction. During operations, risks related to the transportation of sludge to the site of final disposal will also need to be mitigated. Community traffic safety risks during operations will be addressed in a Traffic Safety Management Plan (ESAP item).  

An air quality study was performed as part of the ESIA to determine potential human health risks, related to potential emissions of hazardous air pollutants during the operational phase. None of the modelled pollutants were predicted to exceed identified relevant health standards or guidelines at any of the sensitive receptors for any of the averaging periods assessed. As detailed in the PS3 section, the PE will conduct continuous H2S monitoring during operations and will implement mitigation measures as needed to comply with the applicable WBG EHS Guidelines and WHO standards. 

The development of the Project is expected to have positive community health benefits by improving the quality of water in the Begej River downstream of the Aleksandrovacki canal discharge point. To prevent the risk of direct and indirect community exposure, the Project EPRP will include a communication system to inform the communities of a potential situation where the WWTP is bypassed resulting in the discharge of untreated wastewater directly to the Begej River. 

Security Personnel: 

Security arrangements are expected to include a perimeter fence around the Project site and access control by two unarmed guards. The PE will develop a site access and security procedure, including training requirements and code of conduct for security guards (ESAP item).  

PS5: Land Acquisition and Involuntary Resettlement 

The Project site, which was identified for the Project in the General Urban Plan 2006 – 2026, covers 1.89 hectares. It was originally owned by the Government of Serbia (GoS) and was transferred free of charge to the City of Zrenjanin in February 2020 for the development of the Project. The Project Enterprise will sign a land lease agreement with the City to develop the Project. The ESIA indicates that the site is currently vacant, devoid of any structures, and that there is no evidence of any economic activities being undertaken. 

Historically, the site was used as a disposal area for sugar beet processing waste and then for cultivation of corn.  Review of satellite imagery indicates that, while the land was owned by the GoS, it was used for farming from approximately 2010 to 2019. The land was no longer being used for farming at the time of transfer from GoS to the City of Zrenjanin. Consultation undertaken for the ESIA study was not able to determine why farming activities ceased in 2019. Despite efforts, Metito and the City have not been able to identify these previous land users, and no comments or grievances related to previous land use, compensation and loss of livelihoods were raised during the ESIA stakeholder engagement process.   

A study is currently being undertaken to review previous land use (including informal use) and the process of land acquisition for the Project. In accordance with Performance Standard 5 provisions on private sector responsibilities under government-managed resettlement, if affected informal land users are identified, measures will be developed and implemented by the PE to compensate and restore lost livelihoods of affected people (ESAP item).  

The design and routing for the associated facilities to the Project have not yet been finalized. PS5 may be triggered for such facilities; however, impact is likely to be limited as the associated facilities are limited to a 150 m access road and 1.2 km pipeline. Any land acquisition or compensation process related to the development of these facilities would be led by the City of Zrenjanin in accordance with local law. In addition, in the Concession Agreement between Metito and the City of Zrenjanin, the City committed to build and operate these associated facilities in compliance with the IFC Performance Standards. The Project Enterprise will work with the City, to the extent permitted by the City, to identify and address risks and impacts related to the construction of the associated facilities. The PE will also review the process undertaken for land acquisition and compensation measures, and where gaps with PS5 are identified, the PE will implement complementary actions,  to achieve outcomes that are consistent with the PSs (ESAP item). 

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

The following documentation is available electronically as PDF attachment to this ESRS at www.miga.org: 

• Environmental impact assessment study of the project: construction of a wastewater treatment plant of the city of Zrenjanin on cadastral parcel 15392/5 KO (“Studija o proceni uticaja na zivotnu sredinu projekta: izgradnja postrojenja za preciscavanje otadnih voda grada zrenjanina na katastarskoj parceli 15392/5 KO Zrenjanin”), January 2022. Original document in Serbian language and English translation of the non-technical summary. 

For more information, please see the company’s website at http://www.metito.com  or contact: 

• Contact Name: Walid Madwar 
  Address: Metito Utilities Limited- UAE 
  Tel: +971 4 810 3333 
  Email: walid.madwar@metito.com 

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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