Small Investment Program (SIP)
Environmental and Social Review Summary
This Environmental and Social Review Summary (ESRS) for Small Investment Program (SIP) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only.
Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content.
FinEU-ELLEN SARL of France (FinEU|) is seeking MIGA guarantees for its equity and shareholder loan investment in Alternaprod Mali SASU (“Alternaprod” or “the Project Enterprise”) in Mali.
The Project consists of: (i) the storage of E-Longlife solar PV power kits of various capacities, and high energy efficiency productive tools and appliances (together, “Solar Kits”) in Alternaprod’s warehouses; (ii) transportation of Solar Kits to the end users’ sites, and (iii) installation, operation, and maintenance of Solar Kits in the end users’ sites (the “Project”). The Solar Kits are remotely operated from the Alternaprod office in Bamako and include a GPS to protect against theft.
The Solar Kits are owned by Alternaprod and the installation in a customer’s house typically involves placing a solar panel on the roof, and a Solar inverter inside the house. As part of the installation, the customer is trained on electrical safety. The customer is not allowed to conduct any type of maintenance work on the Solar Kit, apart from a commitment to keep the solar panel clean.
The Project has been operational since 2020 on a pilot scale and is currently expanding its operations in Mali. Project facilities in Mali include a warehouse and office in Bamako, as well as regional sales offices in the towns of Kita, Bougouni, and Kayes. There are currently around 30 employees, and once fully operational the Project is expected to employ up to 60 staff.
The EU Electrification Financing Initiative (ElectriFI) provided a loan to the Project in December 2019, and conducted E&S due diligence against the requirements of the IFC Performance Standards (PSs). An Environmental and Social Action Plan (ESAP) was agreed between the Project and ElectriFI, which has been implemented and completed by the Project.
The Project is categorized as B according to MIGA’s Policy on Environmental and Social (E&S) Sustainability (2013). Key E&S risks associated with this Project include (i) labor and occupational health and safety issues related to installation and maintenance of the solar kits; (ii) waste management including disposal of used solar panels and batteries; and (iii) community health and safety.
While all Performance Standards are applicable to this investment, based on our current information the investment will have impacts that 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
There are no impacts related to land acquisition, biodiversity, indigenous people’s or cultural heritage, and Performance Standards 5 – 8 does therefore not apply.
In addition, the World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines apply to this project.
The following documents were reviewed by MIGA:
- Environmental and Social Management Plan, ELLEN SAS, March 2019
- Occupational Health and Safety Policy, ELLEN SAS, 2019
- Waste Management Procedure, ELLEN SAS, 2019
- Grievance Management Procedure, ELLEN SAS, February 2019
- Annual Environmental Report, Alternaprod Mali, February 2021
- Administrative Procedures Manual, Alternaprod Mali, April 2019
Due to COVID-19 travel restrictions, MIGA was not able to undertake a due diligence site visit. In addition to reviewing the above documents, MIGA carried out virtual E&S due diligence between March – May 2021, which included meetings with the Guarantee Holder, Project Company and FinEU.
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 period, are summarized in the paragraphs that follow and in the Environmental and Social 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.
Assessment and Management of Environmental and Social Risks and Impacts
Key Environmental, Social, Occupational and Labor Risks and Impacts
FinEU has adopted a corporate level EHS policy statement indicating the three main priority areas for the business which include: energy management & climate protection, water management and sustainable packaging. The corporate policy also includes the scope of application covering the Project, its employees, contractors, subcontractors, sales and distribution agencies, and third parties involved in operations.
There is also a separate Policy on Occupational Health and Safety, stating the company’s commitment to ensuring a safe and secure working environment for all staff.
An Environmental and Social Impact Assessment is not required for the Project according to applicable regulation in Mali since associated risks and impacts are not material. Management of E&S impacts is addressed through the management plans described below.
Management Program and Monitoring:
Mitigation Measures (or Environmental, Social, and Occupational Management Plan)
Alternaprod is implementing an Environmental and Social Management Plan (ESMP) based on the requirements of national regulations, the WBG EHS Guidelines, and the PSs. The ESMP is appropriate for the nature and scale of the Project and includes a set of sub-management plans covering for example occupational health and safety, waste management and stakeholder engagement, a monitoring program, and description of role and responsibilities, public awareness and consultation program, and reporting procedures. The ESMP includes a Waste Management Plan, with separate procedures for general waste (mainly packaging, plastics, pallets) and hazardous waste (mainly batteries, disposed solar panels). General waste is collected and recycled by a licensed contractor. Disposed solar panels are returned to the factory for dismantling, while disposed batteries will be shipped to a contractor based in Europe for recycling.
The overall responsibility for the implementation of the ESMP lies with the General Manager in Mali.
In addition to the ESMP, the Project’s Procedures Manual includes provisions and management procedures related to for example security, human resources, code of conduct, as further described in the sections below.
Responding to the COVID-19 pandemic, the Project has established mitigatory procedures including provisions of additional personal protective equipment (PPE) and sanitizers, health screens for staff, and response measures in case of an infection among staff including for example ensuring access to health care.
Human Resources Policy and Procedures:
The Project’s Procedures Manual includes a Labor Code and HR procedures in line with PS2 and local regulations, governing terms of employment, working conditions, workers’ rights and responsibility, wages and benefits, equal opportunity and non-discrimination,. All employees are required to sign-off on having received and understood the provisions of the Labor Code.
The Project’s Procedures Manual allows for employees to join or form worker’s organizations, but none of the staff are currently member of a union. A staff representative has been appointed, responsible for bringing employee’s concerns or requests to the management.
The Project has an internal grievance mechanism in place, based on ELLEN’s corporate procedures, and the Mali labor code. The mechanism includes a commitment statement to acknowledge and respond to complaints, several channels for raising a complaint, handling procedures with specific procedures for anonymous complaints, and monitoring and reporting of outcomes and resolutions.
Emergency Preparedness and Response:
As part of the ESMP, the Project has emergency preparedness and response procedures for its operations, in particular the operations as further described under PS 2. For the warehouse and offices in Bamako, there is equipment and capacity in place to manage fire safety and medical emergencies.
In addition to the Project’s internal procedures, emergency response capacity and equipment is also provided by Bollore, from which the Project rents office and storage facilities in Bamako.
External Communications and Grievance Mechanisms:
The ESMP includes procedures for public information and consultation related to Alternaprod’s business activities, including information campaigns, public meetings, and reporting to authorities and other stakeholders. An external communications and grievance mechanism is also in place, available to the public through a contact form on the Project website, complaint forms and registry in the communities where Solar Kits are installed, and a telephone hotline.
The security of the Project’s offices and warehouse is provided by a local security company certified by the Ministry of Security. In localities where the security company does not have operational staff, Alternaprod uses independent security agents and refers the support of the local police agency that provide human resources to secure its facilities.
The Procedures Manual also includes security related emergency management procedures, including threat analysis, security procedures, and response and preservative measures including evacuation and shelter-in-place procedures.
The Project will revise the Procedures Manual to include provisions for security management, including a Code of Conduct for security providers, protocol for use of force and commitment to the Voluntary Principles of Security and Human Rights (ESAP item).
The Project has obtained the necessary permits and licenses for its operations in Mali, which includes permits from the Ministry of Energy and the Renewable Energy Agency.
For additional information on the Project, please contact:
- Alternaprod Mali
Phone: +223 93 00 54 54
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:
International Finance Corporation
2121 Pennsylvania Avenue NW
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400