AMEA Power Portfolio

MIGA’s ESDD considered AMEA’s E&S risk management and documentation of projects in the Portfolio to identify gaps between implementation of AMEA’s E&S management system 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 E&S Action Plan (ESAP) attached to this ESRS. Through the implementation of those measures, the Portfolio is expected to operate in accordance with the PSs. Key potential E&S issues associated with the Portfolio are summarized in the paragraphs herein.

Key potential E&S issues associated with the Portfolio are summarized in the paragraphs herein. 

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

Environmental and Social Assessment and Management System: AMEA has established a corporate Environmental and Social Management System (ESMS) aligned with the requirements of the PS that is supported by a set of corporate policies that articulate the company’s commitment to E&S sustainability and risk management. The corporate ESMS is implemented through an ESMS manual which describes the E&S management measures to be applied by Project Companies across the Portfolio. AMEA’s management systems are also certified to ISO 14001 (environmental management), ISO 9001 (quality management), and ISO 45001 (occupational health and safety) with validity through 2027. During project development, AMEA generally leads on the E&S aspects (e.g. preparation of the E&S impact assessment and development of relevant E&S management plans) of Projects on behalf of Project Companies. During construction, responsibility on E&S management transitions to the respective Project Company, which is responsible for providing oversight and ensuring that Contractors carry out the works in line with AMEA’s ESMS. Each Project Company is required to manage E&S risks in accordance with host country’s laws and regulations, lender’s E&S standards and requirements, and the AMEA Corporate E&S Management Systems (ESMS Manual). This is achieved by each Project Company developing and implementing its own project-level ESMS, as demonstrated in the sample of Projects reviewed.

AMEA has developed an E&S Employer Requirements document that sets out AMEA’s minimum expectations for the management of E&S matters and specify the Environmental, Social, Health and Safety, and Security management plans/procedures to be developed. These Requirements are included in EPC and O&M contracts and must be implemented by the Contractors, who are also required to cascade these Requirements to all subcontractors throughout the contract term. The E&S Employer Requirements specify that Projects shall meet the requirements of the PSs.  In line with the E&S Employer requirements, the Contractors are required to establish and maintain a Project-specific ESMS. 

Policy: Policy: AMEA has developed a set of overarching corporate policies, including those on Quality, Health and Safety, Gender Equality, Security, and Environmental and Social Sustainability, which reflect its commitment to quality, environmental protection, and the health and safety of its personnel and stakeholders, including communities potentially affected by the Projects. These policies apply across all Projects. At the project level, each Project Company is required to develop and implement E&S policies that are aligned with AMEA’s corporate policies and comply with applicable national regulations.

Identification of Risks and Impacts: AMEA’s ESMS recognizes that E&S risks and impacts are project-specific and vary according to factors such as project type and scale, location, baseline environmental conditions, social context, and potentially affected communities. AMEA assesses E&S risks and impacts on a case-by-case basis and integrates these considerations into each stage of its investment process. During early development, AMEA conducts a high-level desktop country and project screening, including E&S due diligence for potential acquisitions. At the advanced development stage, AMEA commissions an independent consultant to undertake the necessary E&S studies, including an Environmental and Social Impact Assessment (ESIA) in line with PS 1 requirements and any additional assessments identified during screening and ESIA scoping. For projects with minor E&S risks, such as brownfield acquisitions or those classified as Category C, AMEA will undertake a focused E&S assessment, rather than a full ESIA. The scope and depth of this assessment will be proportionate to the nature and scale of risks and impacts identified during project screening. AMEA oversees and manages the ESIA process, including the review of the ESIA and associated studies such as resettlement action plans, livelihood restoration plans, and biodiversity management or action plans. An ESIA is carried out for each Project and complemented by additional studies where necessary. ESIAs are typically also reviewed by project lenders and / or lenders independent E&S consultants. When completed, the ESIAs are disclosed on AMEA’s website, and will also be disclosed on MIGA’s website as they become available (see ‘AMEA Portfolio Projects’).

AMEA’s Gender Equality Policy outlines its commitment to promoting equality, diversity, and inclusion in the workforce, and to preventing all forms of discrimination, violence, and harassment. AMEA’s ESMS manual further recognizes the risks of gender-based violence and harassment (GBVH) to both workers and community members and requires Projects to assess and manage GBVH risks and implement preventative and response measures. Under the E&S Employer Requirements, Contractors are responsible for carrying out a GBVH risk assessment covering work sites and community interactions. Based on the risks identified, the Contractors may be required to develop a Project-specific GBVH management plan that includes, among others, prevention and response measures.  Project-level GRMs are available for reporting GBVH incidents and include protocols for investigation, protection of complainants and referrals to support services. AMEA’s ESG Team provides oversight of GBVH risk management and is responsible for overseeing the implementation of prevention and response measures across Projects. GBVH related grievances are escalated directly to the ESG Team, trained in handling GBVH matters, which leads the investigation process, tracks corrective actions and coordinates with authorities and service providers.

Management Programs: AMEA’s corporate ESMS is supported by a set of E&S procedures and management tools that apply to AMEA’s corporate activities as well as to activities carried out by AMEA staff at the Project level. During the development phase and prior to commencement of the construction works, AMEA requires the Project to have an ESMS in place. The Project-level ESMS is typically developed by the EPC contractors, who are ultimately responsible for its implementation, but it may also be developed by the Project Company. The Project-level ESMS is required to be aligned with AMEA’s E&S Employer Requirements, which are included in tender and contract documentation for each Project. E&S plans/procedures developed by the Contractors are required to take into account Project E&S documentation developed by AMEA, including, but not limited to, the ESIA report, the Environmental and Social Management Plan (ESMP), and associated aspect-specific management plans. Based on the sample of Projects reviewed, the EPC contractor develops a Project-specific ESMS, supported by management plans and procedures, with oversight from the Project Company’s E&S team to ensure that Project E&S assessments were taken into consideration.

Organizational Capacity and Competency: AMEA has a dedicated corporate Environment, Social and Governance (ESG) team led by the Head of ESG, who is responsible for implementing AMEA’s E&S commitments and reports to the Chief Technical Officer (CTO), a member of the Executive Committee. The Head of ESG is supported by a team of five ESG professionals and four in-house subject matter experts on resettlement, biodiversity, supply chain and health & safety. External E&S advisors are engaged as needed. AMEA’s ESG team with the support of the corporate Human Resources Department, is responsible for recruiting the Project Company’s E&S team, who oversee implementation of the Project ESMS during construction and operation. The Project Company E&S team is trained and supported by AMEA’s corporate ESG team. Typical project-level roles include a Health, Safety and Environment (HSE) Manager or Specialist, Social Manager or Specialist, and Community Liaison Officer (CLO), with additional specialists (e.g., biodiversity or resettlement) added depending on project-specific needs. The Contractors are also required to appoint qualified E&S personnel, including, as a minimum, an Environmental Manager, Social Manager, H&S Manager, and Security Manager. The Project Company’s E&S team is responsible for overseeing and managing the Contractor’s E&S performance. 

Emergency Preparedness and Response: AMEA has an Emergency Preparedness and Response Procedure (EPRP) that outlines the minimum requirements for the EPRP to be developed by the Contractors in line with the E&S Employer Requirements. The procedure also specifies the Project Company’s role in overseeing the EPRP’s implementation as well as its obligations in an emergency scenario. The EPRP to be developed by the Contractors must address the following key elements: (i) prevention and minimization; (ii) emergency preparedness; (iii) emergency response; (iv) recovery and (v) debriefing. Based on Project-specific documentation reviewed by MIGA, the EPRPs prepared are consistent with PS and AMEA’s E&S requirements.

Monitoring and Review: AMEA’s ESMS requires Project Companies to report monthly to AMEA in accordance with the E&S Employer requirements. Each Project Company compiles E&S data and information which is populated in a Quality Health Safety and Environment (QHSE) statistics spreadsheet. The QHSE statistics cover, among others: (i) incidents; (ii) non-conformities and associated corrective and preventive actions; (iii) implementation of management plans; (iv) training activities; (v) stakeholder engagement; (vi) grievances; and (vii) performance against agreed KPIs. The Project Company’s E&S unit also conducts monthly health, safety, and social audits. Project Companies prepare annual or quarterly monitoring reports. To further strengthen portfolio-level E&S risk monitoring, AMEA will develop and implement a standardized E&S performance rating system for the Projects to assess and report on Project-specific E&S performance and which will be included in its periodic reporting to MIGA (ESAP #1). 

Stakeholder Engagement and External Communication: A Stakeholder Engagement Plan (SEP) is typically prepared as part of the ESIA process. In line with AMEA’s ESMS, each Project Company is required to develop and implement a Project‐specific SEP consistent with AMEA’s stakeholder engagement procedure. Engagement activities are documented in the Project‐specific SEP and stakeholder engagement log. In accordance with AMEA’s ESMS, SEPs are reviewed regularly and updated as necessary. AMEA also discloses key E&S Project information on its website, typically in English and other relevant local languages, including documents such as the ESIA. Based on the sample of Projects reviewed, Project-specific SEPs are prepared by the Project Companies in line with AMEA’s SEP and the requirements of PS1.

Grievance Mechanisms: An external grievance redress mechanism (GRM) is available on the AMEA Power website for use by external stakeholders such as project affected people, NGOs and CSOs, government entities, investors, and the general public to submit feedback, complaints, and grievances. In line with AMEA’s ESMS, each Project Company is also required to establish and implement a Project‐specific GRM for Project‐affected communities and local stakeholders. The Project‐specific GRM is typically established and managed by the Project Company in line with AMEA’s Grievance Mechanism Procedure and follows structured seven-step process: receiving the grievance, recording it, screening its relevance, acknowledging receipt, investigating, taking appropriate action, and finally closing out the case with follow-up. Based on the sample of Projects reviewed, Project-specific GRMs are established and managed by the Project Company, with grievances logged, addressed, and their status reported to AMEA’s corporate ESG team. The GRMs also include survivor-centered protocols for reporting and investigating GBVH incidents.

PS2: Labor and Working Conditions

In December 2025, AMEA’s corporate workforce consisted of 110 direct employees and 3 temporary employees. Across the portfolio, AMEA had invested in 10 project companies (6 in operation / 4 in construction), which together employed 73 direct employees.  Based on current estimates, solar projects employ approximately 6,500 EPC workers and 25 O&M workers. Wind projects have no EPC workforce and approximately 49 O&M workers while standalone BESS projects currently have no associated EPC or O&M workforce. These figures are indicative and will vary as projects progress through construction, commissioning, and operation.

Working Conditions and Management of Worker Relationship: AMEA has a corporate People Policy which outlines its commitments to its employees. Project Companies develop Project-specific Labor Codes of Conduct (CoC) which set out protocols on workplace ethics, recruitment, human resources (HR) management, health, safety and security, environment, and discipline. The Labor CoC comprises Project-level HR procedures which align with PS2 and the Corporate ESMS’s procedure on Labor and Working Conditions.   The Labor CoC also has a zero-tolerance policy on gender-based violence (GBV) which specifies that all employees are entitled to a respectful and dignified workplace. 

In line with the E&S Employer Requirements, the Contractors are required to develop a Project-specific Labor and Working Conditions Management Plan (LWCMP) that addresses employment terms, non-discrimination, local hiring and termination processes, working hours and compensation, grievance mechanisms, retrenchment, and worker welfare provisions. The LWCMP is required to align with AMEA E&S Employer Requirements (including the PS) and host country labor laws. The LWCMP applies to the Contractors’ workers and subcontractors, and includes provisions for extending applicable requirements to suppliers. Based on a sample of Projects reviewed, the Contractors had developed a LWCMP or equivalent management plan. In addition, AMEA has established an Employment and Procurement Management Plan to promote a systematic, fair, and transparent approach to workforce recruitment and procurement of goods and services by the Contractors.

Project Companies ensure that workers, whether employed directly or through contractors and subcontractors, are provided with written employment contracts at the start of the work relationship. These contracts are consistent with PS2 requirements, as per the Labor CoC and E&S Employer Requirements.

AMEA respects employees’ freedom of association and their right to form or join workers’ organizations or unions for collective bargaining. This commitment is also reflected in the Project-specific Labor CoCs and the E&S Employer Requirements. 

AMEA has an accommodation management procedure to address risks relating to worker accommodation in its Projects, in line with the IFC and EBRD Workers’ Accommodation: Processes and Standards Guidance Note. In accordance with the E&S Employer Requirements, where the Contractors provides worker accommodation, they are required to follow the Guidance Note.

AMEA’s Local Employment and Equal Opportunity Policy articulates its commitment to non-discrimination and equal opportunity which is further reinforced in the Project Labor CoCs.  The E&S Employer Requirements also include provisions on non-discrimination, equal opportunity and anti-harassment that the Contractors are required to adopt. 

The Labor CoCs and E&S Employer Requirements require preparation of demobilization plans with appropriate measures to aid in worker transition on conclusion of construction phases. The demobilization plan is required to be communicated and comprises provisions for an implementation schedule, procedures in line with legal requirements, communication strategy, resource and financial management, support services for workers, and contingency management.

Workers’ GRMs are maintained at both corporate and project levels. At the former, AMEA can receive grievances through its web-based whistleblowing platform, via dedicated emails, and directly through line managers and AMEA’s Compliance Manager. At Project level, Project Companies can receive grievances verbally, and via suggestion boxes, email and telephone. Both corporate and project GRMs allow for anonymity, and AMEA Whistleblowing Policy and the Labor CoCs prohibit retaliation against parties who submit grievances. Both corporate and project level GRMs include reporting and response to GBVH incidents (see PS1). The E&S Employer Requirements further require Contractors to develop workers GRM which must also be accessible to subcontractors’ workforces. Similarly, contractors’ and subcontractors’ workers can access AMEA’s and the Project Companies’ GRMs. At the project level in Togo and Djibouti, Contractors have established workers GRMs which align with AMEA’s E&S requirements. 

AMEA’s monitoring on labor and working conditions at the Project level comprises its E&S teams evaluating compliance with labor standards through periodic audits, inspections and document reviews. The corporate ESG team provides oversight and commissions independent reviews where needed.

Protecting the Work Force: AMEA’s Anti-Modern Slavery Policy and Project-level Labor CoCs prohibit the use of harmful child labor and forced labor, in line with PS 2 requirements. Contractors and suppliers are also contractually bound to comply with this requirement through the E&S Employer Requirements.

Occupational Health and Safety:  OHS risks during construction and O&M pertain to combustible/flammable substances, confined spaces, electric hazards (electrocution and fire), hazardous and toxic substances and gases, hot work, lifting operations and elevated objects, manual handling, moving equipment and machinery, noise and vibration, road transport accidents, slips, trips and falls, temperate extremes (heat and cold stress), and working at height. OHS risk management is integrated into the corporate ESMS, including through procedures on occupational health management (OHM) and OHS management and is overseen by the in-house Health & Safety expert who sits in the ESG team. The OHM procedures provide management measures for protecting and promoting workers’ health and the OHS procedures provide mitigation measures for health and safety risks. The Labor CoCs and E&S Employer Requirements require Contractors to develop OHS management plans (OHSMPs). A review of the sampled Projects in Togo and Djibouti demonstrates compliance with the requirements through OHSMPs with provisions on references and standards, responsibilities, risk assessment, operational control, training and education, communication and consultation, accommodation and site management, record keeping, emergency preparedness, performance evaluation and improvement, and monitoring and review.

Workers Engaged by Third Parties: In AMEA’s portfolio, third parties provide construction, O&M, security, site management, transport and cleaning services. Contractors usually have overall responsibility for their respective project phase and engage subcontractors for specific services. AMEA’s controls on risks relating to third parties span from conducting due diligence and screening, to integrating E&S requirements in procurement documents and the E&S Employment Requirements in EPC and O&M contracts. AMEA tracks corrective actions from monitoring third parties’ performance on labor aspects. The E&S Employer Requirements additionally require Contractors to pass AMEA’s labor requirements to their subcontractors and maintain oversight on performance.

Supply Chain: The Projects are not anticipated to have significant risks relating to primary suppliers, as defined by PS2. The E&S Employer Requirements include supply chain risk management provisions. The Requirements include prohibitions on using child and forced labor, and ensuring the safety of workers in supply chains. Those requirements cascade from AMEA’s policies on Human Rights, Anti-Modern Slavery and Responsible Sourcing, and Third Parties and Suppliers CoCs. Contractors involve, and report to, AMEA during procurement and conduct due diligence on suppliers. The due diligence entails screening and conducting reputation risk assessments, mapping supply chains and maintaining documentation, and conducting monitoring, auditing and review. Additionally, AMEA maintains rights to monitor suppliers’ and contractors’ performance and intervene on non-compliances and/or implement mitigation measures on high risks. The in-house Supply Chain expert on the ESG team provides oversight of project-level implementation of AMEA’s policies and CoCs. 

PS3: Resource Efficiency and Pollution Prevention

AMEA’s ESMS requires Contractors to develop and implement project specific management plans for resource efficiency and pollution prevention, including water management, hazardous materials, air quality, noise, soil, and waste. These plans are guided by ESIA commitments, lender ESAP items where applicable, and the E&S Employer Requirements, and are subject to oversight by AMEA and Project Companies.

Resource Efficiency: AMEA’s Resource Efficiency and Pollution Prevention Procedure outlines its commitment to implement technically and financially feasible, cost-effective measures to improve efficiency in the use of energy, water, and other resources and material inputs, both across its Projects and at the corporate level. 

MIGA’s review of a sample of Projects confirms that Projects in the Portfolio develop water management plans that define water requirements, sources, and monitoring protocols and consumption tracking for cleaning, construction, and workforce needs. Projects are also required to assess the sustainability of water supply and implement measures to minimize consumption, for example through the use of dry-cleaning technologies for PV panels where feasible. Construction and O&M activities generally rely on electricity from the grid and petroleum products for generators and vehicles. 

AMEA monitors and discloses its greenhouse gas emissions annually, covering direct (Scope 1)) emissions from its Projects.  For the Portfolio covered by this ESRS, cumulative annual emissions are expected to remain below 25,000 tCO2e.

Pollution Prevention: Project specific pollution prevention measures are developed by the Contractors in line with the mitigation measures stipulated in AMEA’s Resource Efficiency and Pollution Prevention Procedure, the relevant ESIA, and WBG EHS guidelines, and national standards. In line with these requirements and confirmed by the review of a sample of projects, solid waste is managed by licensed handlers, domestic effluents are collected for off-site treatment, and hazardous and non-hazardous waste are segregated and disposed of through licensed facilities, in accordance with Project-specific waste management plans.

AMEA requires Original Equipment Manufacturer (OEM) suppliers to confirm that BESS and PV modules do not contain polychlorinated biphenyls (PCBs) and to provide written confirmation regarding decommissioning, recycling, and safe disposal at designated recycling facilities. In addition, AMEA’s Waste Electrical and Electronic Equipment (WEEE) Disposal Procedure sets requirements for serial and inventory tracking of mid-life replacements, mandatory training, secure storage and handling of fire-damaged PV and BESS modules, chain-of-custody documentation and licensed disposal. 

PS4: Community Health, Safety and Security

Community Health and Safety: AMEA’s ESMS addresses community health and safety risks across its Portfolio in alignment with PS 4. For every Project, contractors are required to develop three core plans: a Community Health and Safety & Worker Influx Plan, a Traffic and Transportation Management Plan and an Emergency Preparedness and Response Plan (EPRP), and if flagged as a risk a GBVH Plan (see PS1) to address collaboration and information disclosure with affected communities and local government agencies related to emergency response. 

Security Personnel: During Project development, AMEA conducts security risk assessments (SRA) to identify internal and external risks, including those related to local socio-economic conditions, community unrest, and vulnerable groups. Based on the findings of these assessments, AMEA requires contractors to develop project-specific Security Management Plans (SMPs) that address both private and public security arrangements. 

In accordance with the E&S Employer requirements, the SMP is to be prepared in line with PS4 and the IFC Security Forces Good Practice Handbook, incorporating the mitigation measures identified in the SRA, and guided by the principles of proportionality, good international practice, applicable laws. The SMP is submitted to the Project Company for review prior to commencement of works.

Based on the sample of Projects reviewed, Project-Specific SMPs are aligned with PS 4 requirements and among others, include provisions for incident reporting, community engagement, and regular audits. Security incidents, including allegations of abuse or excessive use of force, are required to be investigated by the Contractor and reported to AMEA. Grievance mechanisms are maintained for workers and communities. 

AMEA will review and update the corporate Security Management Procedure (ESAP #2) to strengthen provisions related to Project Company role and responsibilities when there is a deployment of public security and/or military forces by host governments. The update will include protocols and rules of engagement, delineation of roles and responsibilities, and alignment with PS 4 requirements and monitoring measures.

PS5: Land Acquisition and Involuntary Resettlement

As indicated in the Project Description, the Projects are primarily greenfield, with a few brownfield expansions, and therefore, most of the Portfolio will require land acquisition with the potential for physical and economic displacement. 

In most cases, land is made available to AMEA by the host government. During Project development, AMEA conducts country and site screening to assess potential resettlement risks and impacts. Where involuntary resettlement cannot be avoided (including expropriation or government-led acquisition), AMEA’s Land Acquisition and Resettlement (LAR) procedure sets out detailed requirements for planning, consultation, compensation, and grievance management, in line with PS5 and national law. 

The process begins with impact scoping and stakeholder consultation to define potentially affected persons and establish community working groups. Project Companies then undertake land and asset inventories and socioeconomic baseline studies, including identification of vulnerable groups. AMEA prepares Resettlement Action Plans (RAPs) for Projects that result in physical displacement, and Livelihood Restoration Plans (LRPs) for Projects that only cause economic displacement; where both occur, a RAP is prepared that integrates livelihood restoration measures. Eligibility criteria and entitlements are set, valuations are prepared, with provisions for replacement cost compensation and transitional support. Implementation includes resettlement and livelihood restoration measures, provision of land titles or replacement housing where applicable, and targeted assistance for vulnerable people. Resettlement activities (compensation, delivery of entitlement) are undertaken by Project companies’ E&S team, with the support of the Contractors. The Project Companies’ E&S team monitors RAP/LRP implementation through periodic field surveys and reports to AMEA. Project affected people are also informed of the Project’s GRM, Oversight is provided by AMEA’s ESG corporate team.

The LAR procedure defines monitoring, auditing and reporting protocols for the RAP and LRPs. These entail monthly monitoring and commissioning external experts to audit LRPs and RAPs annually. The frequency of external monitoring can be increased depending on the complexity of resettlement. To confirm consistency of resettlement outcomes against PS5 objectives, AMEA will update the LAR procedure to require completion audits for RAPs within two years of compensation payments and physical relocation, and for LRPs within two years after the start of implementation. (ESAP #3).

In the Annual Monitoring Report (AMR), AMEA will provide the status of land acquisition (both voluntary and involuntary transactions), resettlement, compensation, livelihood restoration, and completion for each Project, as well as outstanding grievances and corrective actions.

 Based on current information, the following Projects in the Portfolio have resulted, or are expected to result, in involuntary resettlement involving economic displacement : Ituka West Nile Solar in Uganda, 28 project affected persons (PAPs) on 51 hectares of land; Bondoukou in Côte d’Ivoire, 56 PAPs on 82 hectares; Blitta in Togo, 54 PAPs on 137 hectares; and Aysha 1 in Ethiopia, 909 PAPs who are seasonal dwellers present for approximately three months each year on 1,521 hectares of land. No Projects have resulted in physical displacement. For the sampled Projects that included resettlement, the Project Companies prepared and implemented RAPs/LRPs in line with PS5, and PAPs were resettled accordingly. 

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

General: AMEA has established a Biodiversity Management procedure that is intended to comply with PS6, as well as associated procedures applicable to biodiversity risk management (e.g., Project Screening, ESMS Manual). This includes requirements for early screening, baseline assessments commensurate with project risks, development of management and monitoring plans with support of appropriate external experts, and completion of additional studies where existing Project documentation is inadequate. Implementation of these measures was confirmed at sampled Projects. Project-level compliance is also supported in practice by AMEA’s corporate-level biodiversity specialist advisor and additional Project-level staff and consultants. Approval of lending by IFC and/or other DFIs on high-risk biodiversity Projects in the AMEA Portfolio demonstrates that adequate compliance measures and capacity are either in place or considered feasible. 

Key gaps in AMEA’s current corporate approach include lack of formalization of several aspects required to ensure consistent PS6 compliance (e.g., identification of natural and critical habitats in screening, clear biodiversity specialist roles and responsibilities, biodiversity KPIs). AMEA will (i) develop one or more standardized terms of reference (TOR) to formalize roles and responsibilities for biodiversity specialists at both corporate and, as needed, at Project-level; and (ii) update the existing Biodiversity Management procedures by formalizing some aspects of current practice (e.g., oversight by corporate biodiversity specialist) and/or including additional requirements (e.g.,  identification of critical habitats as per PS6) to facilitate PS6 compliance (ESAP #4).

Sampled Projects are located in Africa and the Middle East, within a range of modified, natural and critical habitats. These Projects generally demonstrate reasonable implementation of applicable corporate procedures on biodiversity at the Project-level, including some PS6 compliant practice not explicitly required by current AMEA corporate procedures. Various biodiversity assessments and plans compliant with PS6 have been completed and implemented (e.g., baseline assessments, Critical Habitat Assessments, Cumulative Effects Assessments, Biodiversity Management Plans, and Biodiversity Action Plan). A range of risks typical of the sectors have been identified (e.g., collision-related bird fatalities from wind power turbines and associated overhead transmission lines). Mitigation measures are generally commensurate with Project risks and apply the mitigation hierarchy, including avoidance (e.g., no construction within Key Biodiversity Areas), minimization (e.g., shutdown on demand protocols, bird diverters), and rehabilitation (e.g., reinstatement of disturbed areas). For some Projects, significant residual impacts to priority biodiversity values are expected (e.g., Amunet WPP) and as such, biodiversity offsets have been proposed. Engagement with international specialist consultants and relevant NGO experts (e.g., Nature Conservation Egypt, Birdlife International) has supported assessment and implementation of PS6 aligned measures. Invasive alien species have been assessed and are being managed, where applicable, as part of the Project ESMPs. No priority ecosystem services were identified.  All sampled Projects are, however, subject to Project-specific lender ESAPs that include some biodiversity items required to close Project-level compliance gaps with PS6 (e.g., shutdown on demand and monitoring protocols at Abour WPP).

PS7: Indigenous Peoples

As of December 2025, AMEA has no Projects that have impacted Indigenous Peoples (IPs) as defined in PS7. However, given the early stage of some Projects in the Portfolio, the potential risk to IPs cannot be excluded. AMEA’s ESMS provides for the identification of IPs and management of potential impacts on IPs in line with PS7. If the presence of IPs within a Project area is indicated during E&S screening, a specialized assessment will be undertaken as part of AMEA’s due diligence to confirm the presence of IP communities and assess potential risks and impacts. Where IPs are confirmed, AMEA’s ESMS requires the following steps: (i) the ESIA consultant must include qualified expertise in IP impact assessment, including local knowledge where relevant; (ii) the ESIA scope must include a dedicated assessment of the IP community, consistent with AMEA’s Indigenous Peoples Management Plant (IPMP); and (iii) if warranted by the ESIA findings, an Indigenous Peoples Plan (IPP) will be developed, and the Project Company will be required to seek free, prior, and informed consent (FPIC) of affected IP groups prior to  implementation of the Project. Additional guidance is provided in AMEA’s Indigenous Peoples Management Plan.

PS8: Cultural Heritage

Construction and O&M activities associated with the Projects in the Portfolio may result in direct and indirect impacts on cultural heritage. Construction activities may also restrict local stakeholders’ access to culturally significant sites such as modern, historic or prehistoric graves. AMEA developed a Cultural Resources Management procedure that sets out the steps for identifying and managing risks and impacts to cultural heritage in line with the requirements of PS8. Where required, during the ESIA process, a cultural heritage survey is undertaken to assess the Project’s exposure to risks related to access restrictions or disturbance of sites of cultural significance. If the ESIA identified potential significant impacts on cultural heritage, the Contractors will be required, per the E&S Employer requirements, to prepare an Archaeological and Cultural Heritage Management Plan, tailored to the Project context and in consultation with relevant interested parties and local authorities. If the ESIA does not identify any cultural heritage resources within or near the Project footprint, a Chance Find Procedure will be developed. A Chance Find Procedure is a minimum requirement for all AMEA Projects. Of the sample Projects reviewed by MIGA, only the Abour WPP in Jordan triggered PS8. As part of the ESIA, a field-based archaeological assessment was undertaken which identified four potentially sensitive cultural heritage sites. In response, the Project’s turbine layout was adjusted to avoid physical impacts on these archaeological resources.  

Broad Community Support (BCS) is not applicable for category B Projects. For each Category A project, MIGA will assess whether the ICP process has been carried out effectively and the level of support among Affected Communities to determine BCS. This section will be updated to reflect MIGA’s assessment of BCS.

AMEA’s ESMS incorporates Informed Consultation and Participation (ICP) from early Project development, beginning with stakeholder mapping and E&S risk screening during country/site screening, project screening, and ESIA preparation to identify potential opposition and community concerns before development. Project Companies undertake regular and structured consultations in line with Project-specific SEPs. Additional targeted consultations are carried out when specific issues arise. Based on the sample of Projects reviewed, AMEA’s community engagement practices reflect ICP and support participation of affected communities.

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