BBOXX Rwanda, Kenya, and DRC
Environmental and Social Review Summary
BBOXX Capital Ltd., Republic of Kenya
BBOXX Capital Ltd., Republic of Rwanda
BBOXX Capital DRC Sarl., Republic Democratic of Congo
This Environmental and Social Review Summary (ESRS) 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.
This Environmental and Social Review Summary (ESRS) covers the application of the African Infrastructure Investment Managers (AIIM) of South Africa via its fund investment vehicle AIIF3 Clean Energy, for its equity and shareholder/quasi equity loan investments into off-grid solar home systems (SHS) and Liquid Petroleum Gas (LPG) commercial operations located in Kenya (BBOXX Ltd.), Rwanda (BBOXX Ltd.) and DRC (BBOXX Sarl.), referred to as the “Projects”. The investor seeks cover for up to approximately US$42.5 million against the risk of expropriation, transfer restriction and war and civil disturbance for a guarantee period of up to 15 years.
The Projects consist of pay-as-you-go (PAYG) services, which include the storage, installation and operation and maintenance of a) off-grid solar home systems (SHS) and b) Liquefied Petroleum Gas (LPG) cylinders. The SHS kits are developed by BBOXX Capital Limited of the United Kingdom (a vertically integrated company), assembled and deployed by BBOXX Asia of China, through its Distribution Energy Service Companies (DESCOs) or Next Generation Utilities (NGUs) in Kenya, Rwanda, and DRC. BBOXX envisions to offer LPG kits to its customer base by financing equipment (2 burner stove, valve and hose) and cylinder deposit. The gas cylinder would remain the property of the LPG providers. LPG cylinders are likely to be the 6 Kilogram (kg) type cylinder, which are the most common in the markets currently. Some LPG flow remote monitoring technology may be added to the kit in the future. A trained technician would install the LPG kit at the customers house, and provide the necessary training in safe use of the stove. If required, BBOXX will facilitate the delivery of replacement LPG cylinders to customers, utilizing adapted motorcycles for delivery of the cylinders.
The Projects were initially launched and owned by BBOXX Capital Ltd. (BBOXX), a limited liability company incorporated in London, UK, a vertically integrated PAYG solar electricity service company that designs, manufactures and distributes plug and play SHS to off-grid communities. BBOXX provides funding, technology, and strategic advisory to the Projects while its actual commercial operations are carried out by three DESCOs (or “Project Enterprises” or “PEs”) namely: (i) BBOXX Capital Kenya Ltd.; (ii) BBOXX Capital Rwanda Ltd.; and (iii) BBOXX Capital DRC Sarl.
The SHS services are comprised of: (i) off-grid SHS equipment storage and display in the PEs warehouses and retail stores; (ii) transportation to and installation of the SHS kits at the end-user’s premises; and (iii) operation and maintenance of the installed equipment during the service period. The standalone SHS kits consist of: (i) a control unit (with sealed Lead-Acid battery or lithium ion battery), (ii) a central system with a printed circuit board, (iii) a 20Watt (W), 50W or 300W Solar Photovoltaic (PV) panels, and (iv) three to five light bulbs. In addition to the standard equipment, customers can purchase optional energy-efficient appliances such as rechargeable portable radios, televisions (15 or 24 inches), torches, men’s facial shavers, phone chargers and 90 liters refrigerators.
The PEs access, customer and equipment management is facilitated by machine-to-machine connectivity. A SIM-card embedded in the SHS enables two-way communication via GSM networks, allowing the PEs to remotely control and monitor customers’ equipment and consumption using a proprietary software (SMART Solar©). In addition to this software, the PEs also developed a business-flow platform (PULSE©) that integrates its back-office systems with mobile operators’ real-time billing platforms, thus allowing bill settlements through mobile money.
The LPG services are comprised of (i) storage of LPG cylinders in retail stores; (ii) the transportation to and installation of a LPG cylinder (typically 6kg or smaller) and 2 burner cookstove (the cookstoves meet ISO/IWA 11:2012 Guidelines for Evaluating Cookstove Performance, Tier 2-4 emission standards and fuel efficiency) at the end-users’ premises; and (iii) the operation and maintenance of the installed equipment during the service period. BBOXX would not be responsible for bulk storage or refilling of the LPG cylinders, but would be responsible for distribution to the customer base. The technicians installing the LPG kits would be appropriately trained, and would provide education to customers on fire risk, gas leakage and safe use of the cook stove at the point of installation and when the LPG cylinders are swapped, on a monthly basis.
The management of the LPG service is likely to follow a ‘low tech’ approach, with customers pre-paying for their gas, and the cylinder replaced when empty. Utilizing smaller cylinders may be considered, to reduce the upfront cost of gas for the customer. A smart metering system may be introduced in the future, previous BBOXX pilot projects have noted that households have faced challenges in utilizing the smart valve technology.
The Projects are categorized as Category B according to MIGA’s Policy on Environmental and Social Sustainability (2013). The Projects are expected to have limited site-specific environmental and social (E&S) impacts and risks. These impacts and risks can be avoided or mitigated by adhering to recognized Performance Standards (PSs), Environmental, Health and Safety (EHS) guidelines, and design criteria. Key E&S risks associated with this investment include: (i) corporate EHS management structure and systems; (ii) labor and working conditions including adequate occupational health and safety (OHS) and operational hazards related to transportation (at the community and worker level), installation and maintenance of the SHS kits and LPG cylinders; (iii) waste management (including e-waste); (iv) contractor management; (v) community health and safety along the transportation routes; (vi) and life, fire and safety and emergency response especially related to LPG cylinder transportation.
While all PSs are applicable to this investment, based on current information, the investment 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
There are no impacts related to the following PSs thus they do not apply to these Projects: to PS5 Land Acquisition and Involuntary Resettlement; PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7 Indigenous People’s or PS8 Cultural Heritage.
In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project:
- Environmental, Health and Safety (WBG EHS) General Guidelines (2007)
- Environmental, Health, and Safety (WBG EHS) Guidelines for Retail Petroleum Networks (2007)
The following additional Good Practice Notes (GPN) may serve as further guidance on E&S risk management:
- Guidelines for Good Safety Practices in the Liquified Petroleum Gas (LPG) Industry
- International Carriage of Dangerous Goods by Road (ADR)
The following documents were reviewed by MIGA:
- Final Report Environmental and Social Due Diligence of BBOXX Capital Ltd. for Africa Infrastructure Investment Managers (AIIM), IBIS, October 2018
- Beyond: Off Grid, DESCO Information for MIGA, AIIM August 2019
- MIGA E&S Due Diligence Questionnaire (Kenya, DRC and Rwanda), BBOXX, March 2019
- BBOXX Human Resources Policies and Procedures, November 2019
- Rwanda Utilities Regulatory Authority, Regulation No. 001/LPG/R/GP-EWS/RURA/2018 of 10/01/2018 Governing Liquified Petroleum Gas Business in Rwanda, October 2018
- Kenya, The Energy Act, 2006 (No. 12 of 2006), The Energy (Solar Photovoltaic Systems) Regulations, 2012
- Kenya, Energy Petroleum Regulatory Authority, The Petroleum Act, 2019
- BBOX DRC Sarl., Environmental, Social, Health and Safety Policy, 2019
In addition to reviewing the above documents, MIGA carried out an E&S due diligence visit January-February 2020 to the Projects which included meetings with key E&S staff and management, regulatory authorities, and communities, as well as visiting the Projects retail and warehouse sites.
MIGA’s due diligence review considered the E&S management planning process and documentation for the Projects, and identified gaps, if any, between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Projects are 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:
In all three countries, an Environmental and Social Impact Assessment (ESIA) is not required for solar PV projects and for retail LPG services. However, the PEs need to apply, comply and frequently renew permits to operate these services (details found below in the Environmental Permitting section). The PEs, as part of the ESAP, will develop and implement a Procedures Manual which is appropriate for the nature and scale of their Projects and includes management of E&S risks and impacts. The PEs have obtained the support of an independent international E&S firm, IBIS Consulting, who undertook an E&S due diligence process, and identified gaps that required the development of further E&S risk management policies and procedures aligned to MIGA’s PSs. IBIS is now supporting BBOXX in the development of a suite of E&S risk management policies and procedures which BBOXX will implement, such as an overarching Environmental and Social Management System (ESMS) for their Projects in line with PS1 requirements. The ESMS is expected to include approximately 10 policies/procedures/plans such as specific procedures on e-waste management, fire safety, supply chain management, and OHS. Relevant E&S reporting tools such as KPI dashboard, KPI definition and collection guidance, reporting template, etc., will also be included within the system. IBIS will also undertake training of key staff on how to implement the ESMS. The ESMS will need to be adapted to include the requirements of applicable E&S, solar PV and LPG regulations in Kenya, Rwanda and DRC. Moreover, the PEs will need to also include a monitoring program, roles and responsibilities, public awareness and consultation program, and reporting procedures in the ESMS. The development and implementation of the ESMS is being overseen by the Social and Ethics sub-committee of the board of directors of each of the PEs.
The PEs will need to adopt an Environmental Health and Safety (EHS) policy indicating the E&S management system comprising of operational procedures and other related documentation per MIGA’s PSs. The policy will also include the scope of application covering the Projects, its employees, contractors, subcontractors, offices, warehouses, retail shops, and any third parties involved in operations. The PEs will need to develop a separate OHS Procedure on stating the company’s commitment to ensuring a safe and secure working environment for all staff, along with appropriate signage around the offices, warehouses and retail shops, obtain adequate supply, distribution and monitoring of PPE usage and regular soft and technical skill trainings via the corporate training plan.
Identification of Risks and Impacts:
As mentioned previously, the PEs do not require ESIAs to be carried out to provide the SHS or LPG commercial operations. However, the SHS and LPG commercial operations requires the PEs to register with the national energy authorities to obtain operating licenses/permits or similar clearances for off-grid and LPG distribution operations. Moreover, the PEs will need to comply with regulations for both industries.
Environmental Permitting: The PEs SHS operations does not require an environmental license in Rwanda or DRC. However, the environmental licenses are required for SHS operations in Kenya, the PE has obtained these licenses and will renew as applicable. The PEs have obtained the relevant industry specific licenses/permits such as off-grid license/permits and will continue to comply with regulations for its SHS operations including prompt renewal of permits/licenses. The PEs are in the process of obtaining relevant LPG licenses/permits for their LPG operations. The PEs LPG operations are part of a regulated industry and these regulations govern the operations of LPG services, including cylinder storage, transportation and retail dispensing. The PEs will submit a copy of all permits/licenses obtained to MIGA prior to commencing LPG services and annually within the Annual Monitoring Report (AMR). The PEs will need to continue to comply with the licensing requirements and apply for renewal of any applicable permits.
As part of the ESMS and to further establish measures to mitigate environmental risks, the LPG operations will be required to develop an E&S risk management plan which should pay close attention to the point of use. As LPG cylinders may be a factor to an incident arising from deliberate misuse or through a faulty appliance or installation. The PEs will be required to obtain the appropriate authorizations to become a gas distributor and will recruit and train dedicated key gas personnel to perform services for the LPG operations.
The LPG operations have higher risks and impacts at: (i) the filling process, as inefficiency could lead to complications and affect the eyes and skin of the operators, however, BBOXX will not have a role in the filling process but will ensure that suppliers responsible for filling follow national regulations; (ii) distribution, due to the potential of accidents occurring through leakages, collision with other vehicles, and possible inefficiencies in loading and unloading of cylinders; and (iii) the end-user stage, due to accidents caused by possible sources of open fire. BBOXX LPG operations are in nascent stage and filling process will not be done by BBOXX. PEs will only focus on step (ii) and (iii) as described above. Thus, mitigation measures will be put in place to ensure safety around the immediate vicinity of warehouses and retail shops where LPG cylinders are stored. The PEs will ensure that they distribute LPG cylinders which meet the specifications under the host country regulations. LPG installation will be performed by trained technicians and safety trainings will be conducted at the customer premises. The PEs will ensure that the warehouses and retail shops meet stringent fire protection standards and staff are trained on life fire and safety measures. To that end, the PEs will aim to mitigate by implementing the E&S Risk Management Plan for LPG Operations, following strict EHS legislation and international guidelines, as well as regular monitoring of LPG equipment.
The PEs will need to update and adapt the Environmental, Social, Health and Safety Policy to align with the requirements of PS1 and national regulations. The implementation and compliance with the ESMS and adherence with the E&S requirements of the PSs, will be made part of any contractor’s agreements. The ESMS will include sub-management plans for issues such as OHS; community health and safety; pollution prevention; waste and hazardous materials management; emergency response and preparedness, and traffic management. The PEs will develop specific plans regarding stakeholder engagement and grievance mechanism, and inspection and auditing of contractors.
The ESMS will need to be developed prior to commencement of LPG operations, as per the ESAP. At the group level, the PEs will: (i) commit to developing an ESMS; (ii) appoint and provide training to a dedicated resource at both the group level and in each country; (iii) introduce provisions related to non-discrimination, child and forced labor as part of its Human Resources policy. In addition, develop a group level community grievance mechanism and adapt and implement at PEs level. A procedure for receiving and resolving internal grievances is already included in BBOXX’s Staff Handbook which will need to be updated to reflect PS2 and PS4 requirements.
Organizational Capacity and Competency:
Currently the overall responsibility for EHS issues at the PEs lies with the respective Managing Directors. All staff receive training in OHS, first aid and firefighting and the ESMS will include 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 EHS Safety Manager and EHS officers to coordinate the implementation and monitoring of the ESMS.
Emergency Preparedness and Response:
The PEs will develop Emergency Preparedness and Response (EPR) procedures for their operations, in particular the operations as further described under PS 2. For the offices, warehouses, and retail shops in each country there should be regularly inspected fire extinguisher equipment, frequent ad hoc drills and capacity in place to manage fire safety and medical emergencies. The procedure will include provisions for establishing emergency areas; roles and responsibilities, communication systems, resources, and training. For the PEs LPG operations, they will include in the EPR descriptions of potential emergency scenarios related to this operation including subcontractor’s personnel in the event of an emergency (i.e. include monitoring actions and an overarching system for reporting and tracking non-compliances). As well as include on-route EPR procedures for LPG distribution phase and on-route EPR drills; and set minimum EPR drill qualifications for contractor’s cylinder truck drivers as part of the transportation management plan.
Monitoring and Review:
As part of the ESMS, the PEs will develop and implement a monitoring program for E&S parameters such as waste management and generation, and management of licenses and permits. The monitoring program will also include reporting procedures and responsibilities for implementation. Moreover, MIGA will closely monitor the grievance mechanism to ensure alignment with PS2 and PS4. In line with MIGA’s Environmental and Social Review Procedures (ESRP), MIGA will periodically review the PEs performance to ensure ongoing compliance with the PS. MIGA will also require the PEs to submit AMRs throughout the guarantee period on EHS and social performance.
The PEs will also be required to obtain, maintain and comply with respective host country regulations for monitoring (i.e. licenses, permits and any applicable audits), in accordance with MIGA’s PSs and relevant World Bank Group (WBG) EHS Guidelines.
Stakeholder Engagement: At the corporate level, a Stakeholder Engagement Plan will be developed and implemented by the DESCOs with the aim to examine stakeholder structure and ensure the establishment of good relationships with key stakeholders. Neighboring businesses/industries to the warehouses and retail shops, communities along the transportation routes and end-users are among the key stakeholders of the PEs and as such will be included in the SEP. The PEs have established or are in the process of establishing a Corporate Social Responsibility (CSR) program with a specified budget for community development which is implemented on a yearly basis.
External Communication and Grievance Mechanisms:
The PEs have developed and will continue to implement their external communications and awareness raising on their services, which included information on EHS. The PEs will continue to update their communications to provide stakeholders and end-users with various channels (including anonymously) to provide grievances. The PEs will build on the existing information found in the HR Policies and Procedures Manual that includes communications and grievances and is currently being implemented. The PEs will develop an external communications and grievance mechanism procedure, which will be available to the public via several channels, including a contact form on the PEs website, complaint forms and registry in the communities neighboring retails shops (where SHS and LPG services are installed) and their existing call center that serves as a customer service hotline.
The PEs will ensure that the external grievance mechanism procedures have a system to ensure that all complaints or other communications received from communities or other stakeholders are responded to and managed appropriately. This includes recording any stakeholder comments or complaints and ensuring that they are passed on to the PEs for response and resolution, as soon as practicable. If the grievance is related to the PEs or contractor’s activity, the contractor will work with the PEs to address the complaint.
Information Disclosure and Ongoing Reporting to Affected Communities
As part of this project, the PEs will publish sustainability information on the BBOXX website, such as E&S policies, key performance indicators (KPIs), onsite safety features, transportation safety and emergency response.
PS2: Labor and Working Conditions
The PEs currently employ a total of 529 staff (i.e. 253 Kenya, 190 in Rwanda and 86 in DRC) of which 135 are female staff (out of the total number of staff 6 are expatriates. Staff are based across rural, peri-urban and urban locations which is aligned to the location of offices, warehouses and retail shops in the respective PEs.
Human Resources Policies and Procedures:
The PEs have Human Resources (HR) Policies and Procedures in place are aligned with the respective national labor codes, which govern the terms of employment, working conditions, workers’ rights and responsibility, wages and benefits, equal opportunity and non-discrimination, among others. All employees are required to sign-off on having received and understood the provision of the respective Labor Codes. The HR Policies and Procedures will be updated to align with requirements under PS2.
Working Conditions and Management of Worker Relationship:
As mentioned previously, the PEs have a corporate HR Policy and various procedures that specifies the terms of employment and working conditions. The procedures are related to recruitment, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and dismissal, vacation, grievances, retirement, sexual harassment, code of conduct, and applicable local HR laws. The company conducts training about HR policy as part of the new employee induction, and all employees have access to this policy. The HR issues are managed by the corporate HR department as well at HR Managers based in the respective PEs.
Working Conditions and Terms of Employment
The PEs provide suitable working conditions and personal protective equipment (PPE) to employees as appropriate to their assigned roles and responsibilities. The type(s) of PPE issued is based on a risk assessment carried out in specific areas of employment, such as transportation, installation of solar PV panels (working at heights) and LPG cylinders and during the refurbishment of SHS equipment, to ensure that employees are safe and any inherent risk to health is minimized by adequate control. Individual job contracts for the PEs incorporate the requirements of national HR regulations and as per the ESAP, will be updated to incorporate the requirements of MIGA’s PS2, where required. The PEs have established HR Policies and Procedures Manuals based on the recruitment, dismissal, performance appraisal, equal opportunity and non-discrimination, sexual harassment, commitment to health & safety at work and compensation systems. These policies will continue to be implemented in line with respective national laws and MIGA’s PS2. Any contractor/third party will be required to adhere to the PEs HR Policies and Procedures Manuals and these requirements will also flow down to sub-contractors. The PEs will put in place a mechanism to monitor the HR Policy and Procedures of their suppliers and sub-contractors to ensure these are consistent with requirements of MIGA PS2. .
The Projects’ 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 may be appointed and can responsible for bringing employee’s concerns or requests to the management.
Child and Forced Labor
The PEs do not employ forced labor or children as, consistent with respective national labor codes. The nature of the work generally precludes unskilled workers, and so the risk of child or forced labor is negligible. All employees are above the age of 18. Age verification is done via birth certificate/national ID.
Occupational Health and Safety:
There is only one PE with a Health and Safety (H&S) policy in place (DRC). The H&S policy will need to be developed for the other two PEs and updated for all PEs to include identification of risks, mitigation measures and good practices, staff responsibilities and training, details on the use of PPE, and road safety.
Workers Engaged by Third Parties:
Contractors are primarily used for purposes of supply of SHS kits, housekeeping, security, waste management and gas suppliers. 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 and as per the ESAP, labor management, security, health and safety and induction/training requirements will also apply to the contractor’s staff.
The PEs will develop requirements and signed gas supply contracts with suppliers and sub-contractors. To ensure that suppliers meet international standards, the PEs will regularly visit selected suppliers to monitor E&S performance regarding quality, EHS, labor conditions and environmental management in line with the requirements of MIGA’s PS2. The PEs will provide adequate resources for E&S management, monitoring and compliance of BBOXX subcontractors.
As mentioned previously, the PEs have established an internal grievance mechanism (GM), based on their corporate procedures and the respective labor codes. The mechanism includes a commitment statement to acknowledge and respond to complaints, channel for raising a complaint and appeal process. The internal GM will need to be updated to align with the requirements of MIGA’s PS2 such as handling procedures for anonymous complaints and monitoring and reporting of outcomes and resolutions etc.
PS3: Resource Efficiency and Pollution Prevention
As the PEs business activities primarily include SHS kits and LPG storage installation and distribution, there are no manufacturing processes and resource consumption is very limited. The main resource consumption is electricity, which is supplied from the respective national grids and used for offices, warehouses and retail shops. Sanitary, cleaning, and firefighting water is sourced from groundwater, while filtered bottled water is used for drinking.
According to the information obtained during the E&S due diligence, the PEs operations will not exceed 35,000 tons of carbon dioxide per year of greenhouse gas emissions.
In line with the ESAP, the PEs will need to develop, maintain and implement an appropriate Waste Management Plan (WMP). In addition, the SHS operation will bring benefits related to renewable energy production, such as displacing diesel generators and reducing emissions of greenhouse gases. The LPG operations aim to improve the health of household members, primarily women, through the adoption of clean cooking by moving from harmful charcoal cooking to a modern clean fuel (LPG).
Solid waste management:
Solid wastes resulting from the Project’s operations primarily include packaging material such as cartons, plastics, polystyrene foam and pallets. The WMP will therefore be based on the principles of reduction, reuse and disposal and aligned to PS3. Solid waste and recyclables should be separated at the warehouses and collected by a licensed third-party, in line with the WMP.
Hazardous waste management:
Impacts related to hazardous waste for the SHS operations are primarily related to end-of-life management of batteries, appliances and solar panels from SHS kits. The WMP should therefore identify specific risks, on-site sorting and storage conditions, internal and external processing chain and disposal, and possibility of recycling/resale.
The PEs warehouses have a workshop where they can perform different activities under the refurbishment process for the SHS operations such as dismantling batteries, solar panels and other SHS equipment. The warehouses are ventilated with designated space that serve as storage for SHS. The PEs also use the warehouses for transportation of SHS equipment to retails shops or for pick up for disposals. The WMP will be developed as part of the ESAP to include procedures for end-of-life management of the solar panels.
PS4: Community Health, Safety and Security
Community Health and Safety
The PEs strictly prohibits and has a zero-tolerance policy on sexual harassment both in the workplace and outside the workplace against other people including current and former employees, job applicants, clients, customers, suppliers and visitors. All complaints of sexual harassment will be seriously investigated and disciplinary sanctions will be implemented.
While the Projects are not expected to have material impacts related to community health, safety and security in relation to the SHS activities, the key community safety concerns identified are in relation to: (i) the transportation of SHS kits from retail shops to the site of installation; (ii) installation of the solar panels; and (iii) 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 households in which the equipment is installed.
The PEs key risks posed to the community are related to the LPG operations, specifically those risks related to transportation of gas cylinders during distribution on poor-quality roads and inclement weather conditions particularly in rural areas. In line with the ESAP, all staff including third parties will be provided with training on safe handling and traffic safety, to avoid any accidents. The PEs will further provide training on how to proceed in the event of an accident. Full procedures and mitigation measures will be included in the ESMS. Information and pre-installation awareness campaigns with communities and end-users will be implemented as part of the ESMS and customer education, to provide safety information on electrical and LPG usage safety. Awareness raising meetings are also regularly held with local authorities and village heads and summary of these meeting will be provided to MIGA as part of the AMRs.
The PEs will develop a Community Health and Safety Plan (including COVID-19, Ebola and Malaria prevention) to mitigate for community exposure to diseases. The PEs will implement worker’s health programs to screen the health of workers and such information will not be used in discriminatory manner and will not exclude workers from employment opportunities.
Infrastructure and Equipment Design and Safety
The LPG operations present a greater risk than the SHS operations as the LPG operations are more hazardous. In addition, most LPG-related incidents occur at or close to the point of use. As part of the Community Health and Safety Plan, the PEs will need to ensure that they create safety awareness for the end-users’ and enlist the support of national regulatory authorities, where applicable. The existing customer education training component should also include details on the steps which consumers should take, and those to avoid, in the interest of safety, i.e. by providing material/safety data sheets etc. End-user safety will depend on appliance and installation. To maintain awareness, messages and presentations should be refreshed from time to time.
The PEs will be required to implement a worker’s health program to screen the health of workers, and a Communicable Diseases Awareness Campaign as part of the Community Health and Safety Plan will be put in place as part of the PEs customer education training component. The PEs have included in their HR Policies and Procedures Manual language on HIV/AIDS, sexual harassment as part of the code of conduct of employees. While the HR Policies and Procedures Manual also covers rules of interaction with customers, the code of conduct will be amended to reflect respect for local beliefs and customs and with special attention for risks related to sexual harassment, sexual exploitation and abuse and gender-based violence (GBV). The PEs have committed that all complaints of sexual harassment and GBV will be seriously investigated and disciplinary action will be taken.
Security at the PEs warehouses, retail shops and offices are managed by a licensed private security firm. The PEs screen security contractors for past complaints of gender-based violence. The PE’s security staff oversee the gate security as well as use of video surveillance via closed circuit TV (CCTV). If the PEs face serious security issues, they will report directly to the local police stations.
Moreover, the PEs Procedures Manual will need to be updated to include a Security Plan with risk assessments and procedures governing activities related to the installation of the SHS and LPG operations, particularly travel to remote locations in conflicted affected areas. The plan will include a description of responsibilities, rules for preparation, communication and management of equipment in the field, and travel guidance and requirements for different risk levels. The plan should also include hibernation and evacuation procedures in case of an emergency, including coordination with United Nations security resources when necessary. The Security Plan and related procedures should adequately address contextual risks related to security.
There are no documents to attach to this ESRS.
Questions on the above Projects can be addressed to the Managing Directors at the following locations:
Mr. Jeff Vanden Berghe, Managing Director
+254 798 983 189
BBOXX Capital Kenya Ltd.,
P.O. BOX 14616-00800,
Mr. Justus Mucyo, Managing Director
+250 7 88 31 77 02
BBOXX Capital Rwanda Ltd.,
BBOXX - DEMOCRATIC REPUBLIC OF CONGO
Mr. Max Gopfert, Managing Director
BBOXX Capital DRC Sarl.,
+243 8 90 03 11 90
Avenue Ishasha Numéro 20,
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