Alternaprod Tchad SAS

E-Long Life Energies Nouvelles S.A.S of France (ELLEN|) is seeking MIGA guarantees for its equity and shareholder loan investment in Alternaprod Tchad S.A.S (“Alternaprod” or “the Project”) in Chad.

The project consists off (i) the storage of E-Longlife solar PV power kits with lithium-storage batteries of various capacities and high energy efficiency productive tools and appliances (together, “Solar Kits”) in the Project Enterprise’s warehouse located in N’Djamena, (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 N’Djamena and includes a GPS to protect against theft.

The Solar Kits are imported and the installation in a customer’s house typically involves placing a solar panel on the roof, and battery inside the house. As part of the installation, the customer is trained is 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 2018 in a pilot scale and is currently expanding its operations in Chad.   

The Project is categorized as B according to MIGA’s Policy on Environmental and Social Sustainability. Key environment and social 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; and (iii) community health and safety.

While all Performance Standards are applicable to this investment, our current information indicates that 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

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
• Manuel des Procedures Alternaprod, Alternaprod Chad, October 2016
• ELLEN Project Environmental Impact Matrix, August 2018.
• Sustainable E-Waste management and non-toxic battery technologies for the off-grid solar sector, ELLEN SAS, July 2018
• Alternaprod Chad Labor Code, August 2018.

MIGA’s review also included telephone conferences with ELLEN SAS and the Project.

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.

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

Policy:

ELLEN 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.

Environmental and Social Assessment and Management System:

An Environmental and Social Impact Assessment is not required for the Project. Alternaprod is implementing a Procedures Manual which is appropriate for the nature and scale of the project and includes management of environmental and social risks and impacts. On a corporate level, ELLEN has in place an Environmental and Social Management Plan (ESMP), applicable to the Project. The ESMP was developed in March 2019 and is suitable to the operations of the Project. It was developed according to the requirements of the Performance Standards and considering applicable regulations in Chad.

The Project will, as part of the ESAP, update the Procedures Manual for the operations in Chad to incorporate the requirements of the corporate ESMP, regulatory requirements in Chad, and the Performance Standards. The updated version of the Procedures Manual will inter alia include a monitoring program, roles and responsibilities, public awareness and consultation program, and reporting procedures.

Monitoring and Reporting:

The corporate-level ESMP includes a monitoring program for environmental and social parameters such as waste management and generation, and management of licenses and permits. The monitoring program also includes reporting procedures and responsibilities for implementation. The Project’s Procedures Manual will be updated to include the monitoring program.

MIGA will require Annual E&S Monitoring Reports throughout the guarantee period on EHS and social performance, in accordance with MIGA’s PSs and relevant World Bank Group (WBG) EHS Guidelines.

Organizational Capacity and Training:

ELLEN has a corporate level E&S Manager, overseeing the implementation of the ESMP. Overall responsibility for Environmental, Health, and Safety (EHS) issues in Alternaprod lies with the General Manager. All staff receive training in occupational health & safety, first aid and firefighting and the ESMP includes the implementation of a staff training program on environmental management, for both direct and third-party staff.

The Project will, as part of the ESAP, appoint an Environmental and Social Officer to coordinate the implementation of the ESMP.

Emergency Preparedness and Response:

As part of the Procedures Manual, the Project has emergency preparedness and response procedures for its operations, in particular the operations as further described under Performance Standard 2. For the warehouse and offices in N’Djamena, there is equipment and capacity in place to manage fire safety and medical emergencies.

Grievance management:

The ESMP includes an external communications and grievance mechanism which will be implemented in Chad, 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.

PS2:  Labor and Working Conditions

Alternaprod currently employs 30 staff, out of which 2 are expatriates. Once fully operational, the Project expects to have a staff count of around 160. All staff will be based in the main office in N’Djamena, with temporary travel for installation and maintenance to clients in rural areas.

 Human Resources Policies and Procedures:

The Project has a Labor Code and HR procedures in place governing terms of employment, working conditions, workers’ rights and responsibility, wages and benefits, equal opportunity and non-discrimination, etc. All employees are required to sign-off on having received and understood the provision of the Labor Code.

Workers Organization

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.

Grievance Mechanism

The Project has an internal grievance mechanism in place, based on ELLEN’s corporate procedures, the Chad labor code, and the Performance Standards. 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.

Occupational Health and Safety

The Project has a Health and Safety (H&S) policy and management plan in place, including identification of risks, mitigation measures and good practices, staff responsibilities and training, details on the use of personal protective equipment, and road safety.

In addition, the Project’s Procedures Manual includes a Security Plan with risk assessments and procedures governing activities related to the installation of the household solar systems, including travel in remote areas of Chad. The plan includes a description of responsibilities, rules for preparation, communication and managing equipment in the field, and travel guidance and requirements for different risk levels. The plan also includes hibernation and evacuation procedures in case of an emergency, including coordination with United Nations security resources when necessary. The Security Plan and related procedures adequately address contextual risks related to security.

Workers Engaged by Third Parties:

Contractors are primarily used for housekeeping and security purposes. At periods with large volumes of installations and new clients in an area or region, local companies may be contracted to support with transportation and installation activities. In such cases, labor management, security, health and safety and induction/training requirements will also apply to the contractor’s staff.

PS3:  Resource Efficiency and Pollution Prevention

In relation to this Performance Standard, the main concern is related to management of waste. Energy efficiency, water management and pollution prevention are not considered material to Alternaprod’s operations. The Project will bring benefits related to renewable energy production, such as displacing diesel generators and reducing emissions of greenhouse gases.

Solid waste management:

Solid wastes resulting from the Project’s operations primarily include packaging material such as cartons, plastics, polystyrene foam and pallets. Alternaprod has a waste management plan in place, based on the principles of reduction, reuse and disposal. Solid wastes and recyclables are separated at the warehouse and collected by a licensed third-party.

Hazardous waste management:

Impacts related to hazardous waste primarily relate to end-of-life management of batteries, appliances and solar panels from the solar kits. The waste management plan identifies specific risks, on-site sorting and storage conditions, internal and external processing chain and disposal, and possibility of recycling/resale.

The Alternaprod warehouse has a workshop for dismantling of batteries and solar panels, storage in designated and ventilated area, and handling for transportation back to factory or disposal site. In the case of batteries, there are two cases:

• In the case of batteries whose cells only have 30% energy left, the Group undertakes to reuse them for a secondary market.

• In the case of batteries with completely discharged cells, the Group undertakes to dismantle the generators to recover the cells, store them in secured areas and handling for transportation to a technical partner who will recycle the lithium-ion cells to make new raw materials.

The waste management plan will be updated as part of the ESAP to include procedures for end-of-life management of the solar panels, based on a model where the manufacturer takes responsibility for recycling of the decommissioned panels.

PS4:  Community Health, Safety and Security

The Project is not expected to have material impacts related to community health, safety and security. The key community safety concerns are in relation to the transportation of solar kits from N’Djamena to the site of installation and installation of the solar panels and the consumption of the electricity generated. The units are low capacity and are designed to ensure safe handling and minimize risks for the members of the household in which the equipment is installed.

Information and pre-installation consultation campaigns with communities and client households will be implemented as part of the ESMP, to provide on electrical safety. Awareness raising meetings are also regularly held with local authorities and village heads.

Security at the Project’s office and warehouse location will be managed by a licensed private security firm.

The Project operations does not require an environmental license, but has the relevant permits related to its operations in place, including waste management.

In addition to the public consultation program described above, the Project will be implementing a program to bring electricity to primary and secondary schools in rural areas of Chad. A pilot-phase involving one school has been carried out and is being evaluated.

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

The above listed documentation is available electronically as PDF attachments to this ESRS at www.miga.org.  It is also available for viewing at the following locations: