Diamniadio VRD Urban Pole
Environmental and Social Review Summary
Diamniadio VRD Urban Pole
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 Deutsche Bank AG (“DB”, the “Guarantee Holder” or “GH”) request for MIGA to provide non-honoring of sovereign financial obligations guarantees on debt financing of up to US$ 200 million for up to 15 years. Proceeds from the facility are expected to be utilized by the Government of Senegal (“GoS”) to support the Emergency Program for the construction and integrated management of a water and sanitation system, and the primary road network at the Urban Pole of Diamniadio, along with various supporting infrastructure (the “Pôle Urbain de Diamniadio” or “PUD”, referred to as the “Project”). The Project will be executed by ECOTRA SA (“ECOTRA”) an international Engineering, Procurement and Construction (EPC) company. The Project is located approximately 30 kilometers (km) from Dakar and its primary purpose is to ease congestion and urbanization pressure on the city of Dakar. The Project covers 1,644 hectares (“ha”), and is surrounded by the municipalities of Diamniadio, Bargny, Bambilor and Keur Ndiaye Lô.
Project management is provided by the General Delegation for the Promotion of Urban Poles (“The DGPU”, referred to as the “Project Enterprise” or the “PE”) of Diamniadio and Lac Rose, under the supervision of the GoS Presidency. The DGPU has set up a Coordination unit responsible for the monitoring and supervision of the Project’s overall execution. The DPGU is mandated to implement the policies of the GoS, layout and promote the development of the urban poles of Diamniadio and Lac Rose.
The PUD combines residential and economic developments. The DGPU global project
consists of the construction of the following five sub-projects:
A road network which comprises of a total of 20,5 kilometer (km) of 2x2 lanes and 2x1 lane;
A sewage treatment network comprising of 29,7 km and a 40,000 cubic meters (m3) capacity treatment station;
A storm water drainage network of 24.7 km;
A drinking water supply system which includes 8 water towers with a cumulative capacity of 6000 m3, as well as two tarpaulin storage units with capacity of 22,000 m3 each and a network of 57,6 km; and
An electrical system comprising: (a) 14 medium voltage electrical substations that power 630 kilovolt-ampere (kVA) for delivery; (b) electrical distribution networks including medium voltage (15 km) and low voltage (20 km) and related remote management.
The MIGA Project consists of the following works within the Urban Pole of Diamniado:
i) A road network which comprises of a total of 10,4 km of 2x2 lanes and a 2x1 lane;
ii) A sewage treatment network comprising of 29,7 km linked to 15,000 m3 capacity treatment station;
iii) A storm water drainage network of 19,5 km;
iv) A drinking water supply system which includes water towers with a cumulative two
tarpaulin storage units with capacity of 22,000 m3 each;
An electrical system comprising: (a) 4 medium voltage electrical substations that power 630 kVA for delivery; and (b) electrical distribution networks including medium voltage and remote management;
Expansion of wastewater substation from 15000 Population Equivalent (PE) to 40000 PE; and
Laterite quarry in the Forest of Sebikotane for ECOTRA’s use.
ECOTRA began construction works in the Pole Urbain (PU) in August 2019.
The Project is classified as a Category A according to MIGA’s Policy on Environmental and Social (E&S) Sustainability (2013) due to potentially significant adverse E&S risks and irreversible impacts. Key E&S issues and risks include: (a) economic displacement of project affected persons (PAPs); (b) enhancing the PE’s organizational capacity and environmental and social management system (ESMS), to manage E&S risks and supervise ECOTRA’s activities; (c) increased occupational health and safety (OHS) risks associated with COVID-19; (d) community health and safety (H&S), including management of waste and dust associated with transport of material from the laterite quarry, located in Sébikotane 15 km away from ECOTRA’s base camp; and (e) stakeholder engagement and management of grievances.
While all Performance Standards (PSs) are applicable to this investment, based on our current information, this 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
PS5: Land Acquisition and Involuntary Resettlement
PS6: Biodiversity, Conservation of Living Natural Resources
There are no indigenous peoples in Senegal as defined by PS7: Indigenous Peoples, thus PS 7 is not applicable. The ESIA has not identified cultural heritage within the Project site. Therefore PS8: Cultural Heritage is not triggered however, ECOTRA’s ESMS will include a chance find procedure as a precautionary measure.
In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project:
General EHS Guidelines (2007)
EHS Guidelines for Waste Management (2007)
Industry Specific EHS Guidelines include:
EHS Guidelines for Construction Materials Extraction (2007)
EHS Guidelines for Electric Power Transmission and Distribution (2007)
EHS Guidelines for Water and Sanitation (2007)
Other relevant guidance documents include:
International Finance Corporation (IFC) Good Practice Note: Managing Contractors’ Environmental and Social Performance (2017).
IFC Use of Security Forces: Assessing and managing risks and impact (2017).
Interim Advice for IFC Clients on Preventing and Managing Health Risks of COVID-19 in the Workplace (2020).
Interim Advice for IFC Clients on Developing a COVID-19 Emergency Preparedness and Response Plan (2020).
Interim Advice for IFC Clients on Supporting Workers in the Context of COVID-19 (2020).
Interim Advice for IFC Clients on Safe Stakeholder Engagement in the Context of COVID-19 (2020).
COVID-19 and Gender-Based Violence: Workplace Risks and Responses: A Guidance Note for Employers (2020)
In preparing this ESRS MIGA reviewed a wide range of Project-related information; a
complete list of documents and data reviewed is presented in Annex 2. Key documents reviewed included:
ECOTRA - Engineering and Environment Service: ECOTRA Environmental and Social Impact Assessment (ESIA), July 2019.
DGPU - The DGPU Draft Strategic Environmental and Social Assessment (SESA), December 2019.
Due to the ongoing COVID-19 global pandemic, MIGA was unable to carry out a physical E&S site visit of the Project. However, with the support of an in-country independent E&S consultant (IESC), site visits were carried out between April - June 2020. In addition, the IESC also held teleconferences and face to face meetings during that period with the following stakeholders: the DGPU, ECOTRA, Prefecture of Rufisque Commune, SENELEC (National Electricity Agency), ONAS (National Wastewater Treatment Agency), Direction de l'Environnement et des Etablissements Classés (DEEC, , the implementing Department of the Ministry of Environment and Sustainable Development), SONES (National Water Agency ), and a random sample of PAPs in the Project site, as well as other individuals who have experienced economic displacement under a land acquisition process within the PUD.
MIGA’s due diligence review considered the E&S management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures intended to close these gaps within a reasonable time period are summarized in the paragraphs that follow and in the 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 objectives of the applicable PSs.
Key E&S risks and impacts associated with ECOTRA’s operations, as well as the DGPU’s ESMS and organizational capacity to manage ECOTRA are summarized in the following Sections:
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment and Management System
Both the DGPU and ECOTRA have undertaken in coordination with the DEEC a process of E&S assessment. DGPU and ECOTRA’s ESMSs will be strengthened to include the themes listed in the paragraphs below under PS1.
The DGPU does not have a written E&S Policy guiding the Project. However, it has established several divisions involved in sustainability, including: (a) Smart City division, an initiative to turn PUD into a ‘digital’ city; (b) Project Coordination division (which is ad-hoc and linked to the ECOTRA project), a structure set up by the DGPU to monitor all aspects of the Project including environmental matters; (c) Communications and Gender division ; and (d) Strategy and Sustainable Development department, which is a newly-created department to meet the expectations of turning PUD into a resilient city that respects national environmental standards. The Strategy and Sustainable Development division is further divided into the following sub-units: (i) Strategy, Planning and Assessment; (ii) Innovation Technology and Sustainable Development; and (iii) Urban Planning and Land Development (responsible for land acquisition).
To ensure alignment and effective delivery on these objectives, the DGPU will develop an integrated E&S Policy that applies to all its divisions, while incorporating commitments to: (i) national E&S laws; and (ii) contractual obligations related to E&S risks and management of its operations in line with the PSs (ESAP action item #1).
ECOTRA has an EHS policy that outlines its objectives to protect workers from health and safety incidents, maintains a strong safety culture, communicates with stakeholders to meet their expectations in terms of EHS, and aligns to international EHS and occupational health and safety (OHS) standards, such as Occupational Health and Safety Assessment Series (OHSAS) 180011. The DGPU will ensure that ECOTRA’s senior management develops and signs an overarching policy defining the E&S objectives and principles that guide the Project to achieve sound E&S performance aligned to applicable PSs (ESAP action item #2).
Identification of Risks and Impacts
In 2019, the DGPU developed a Strategic E&S Assessment (SESA) for the entire PUD, which while still in draft form, will be finalized and implemented. The SESA includes: an analysis of the risks and impacts associated with multiple projects, an E&S management framework and an E&S monitoring plan.
As mentioned previously, ECOTRA commissioned an ESIA undertaken by a local consultancy firm prior to the start of the Project and in line with national legislation. The ESIA study, which was completed in July 2019 includes an analysis of risks and impacts associated with the Project. An E&S management plan (ESMP), which also includes an E&S monitoring plan was included as part of the ESIA. The ESIA received its certificate of conformity from Senegal’s Environmental Authority, the DEEC, in July 2019. A laterite quarry (operating permit issued in February 2020) requires a subsequent ESIA to be undertaken (see PS6 for additional details).
After completion of the ESIA, ECOTRA developed its ESMS, which comprises of the development of a series of E&S action plans and a set of EHS management procedures limited to current works which have been undertaken. A number of risks and impacts were not assessed in the context of the ESIA, including: (a) ECOTRA’s second site, where the concrete batching plant was moved, approximately 1km away from the base camp; (b) impacts related to wastewater generated by construction sites (i.e. washing water, concrete slurry, runoff water); (c) impacts linked to the gaseous releases when operating equipment (i.e. construction machinery, generators, trucks, etc.); (d) potential risk of accidents related to machinery/equipment (i.e. concrete plant, generator and concrete mixer); (e) risk of cave-in linked to excavations and trenches; (f) risk of accidents related to maintenance activities; and (g) E&S impacts and risks of accidents linked to the mining at the laterite quarry, which was not included as part of the ESIA. During the IESC’s site visits, these aspects were observed and discussed with the EHS Manager and will be addressed in the ESMS. ECOTRA will develop a comprehensive ESMS that applies to the entire Project. The DGPU will ensure that ECOTRA: a) addresses the risks and impacts omitted in the ESIA; b) develops a comprehensive ESMS that identifies the E&S risks of the Project; and c) develops associated management programs in line with PS1 (ESAP action item #3).
The ESMS will include a management-of-change process and procedures that cover ordinary and hazardous waste management procedures for dangerous materials, a traffic management plan, fuel unloading, as well as additional risks and impacts described above and not addressed in the ESIA.
As previously described, ECOTRA will operate a laterite quarry, for which it has an operating license, to supply construction materials. The quarry is located 15 km from the Urban Pole in the peripheries of the Sébikotane forest reserve. Furthermore, it will have sand delivered from an approved sand quarry. The construction demand for these quarries are estimated at 1,030,000m3 for the laterite and 1,000,000m3 for sand over the period of the Project. Laterite will be transported by ECOTRA’s fleet of 73 trucks (30-ton capacity), approximately 15 of which are operated daily for the Project while others are dispatched when needed. The company employs 170 drivers for different types of vehicles (e.g. trucks, vehicles, skips and light trucks, etc.).
Measures taken by ECOTRA on previous quarry operations and which will be undertaken to mitigate E&S impacts of the laterite quarry and transportation of material include: (a) watering of quarries and access tracks to suppress dust; (b) covering of trucks transporting construction materials; (c) driver awareness training; (d) maximum speed limit of 30km/h; (e) installation of the ‘Easy Track app2 in most trucks; and (f) control system to regulate the quantity of materials removed from quarry.
ECOTRA will develop a reforestation plan and rehabilitate the quarry as per the signed protocol with the Water and Forest Management agency to in time restore degraded areas. The DGPU will ensure that ECOTRA respects the conditions of the protocol which include an ESIA to be undertaken for the quarry and the development of a quarry rehabilitation plan (ESAP action item #4).
The large number of developments associated with the PUD are expected to have both direct and indirect impacts on adjacent areas as well as cumulative impacts.3 The ESIA for the Project only considered the effects of ECOTRA’s activities. Cumulative impacts associated with the PUD have both positive and negative aspects. Positive impacts resulting from the development of the PUD include the reduction of congestion in Dakar by relocating offices (including government offices) to the Diamniadio ministerial clusters, thereby decreasing congestion in the center of Dakar. The following potential valued E&S components (VECs) have been considered for negative cumulative impacts resulting from the entire development of the PUD, including MIGA’s Project: (a) atmospheric releases; (b) liquid discharges (wastewater and rainwater); (c) land acquisition for the right of way for roads and utility networks; and (d) health and safety of surrounding communities. Atmospheric releases from developments in the PUD appear to be limited because the main developments are office buildings and other low emission operations. Designs for these other developments within the PUD appear to have accounted for cumulative liquid discharges associated with rainwater drainage and wastewater treatment. Land use changes and the health and safety of surrounding communities are potential cumulative impacts that go beyond the PUD.
As cumulative impacts transcend the development of a single project, addressing them will require the DGPU’s action, given that it has oversight of the PUD, as well as the engagement of stakeholders who both rely on and affect VECs (ESAP action item # 5). As such the DGPU will undertake the following activities:
implementation of the E&S management framework developed as part of the SESA of the PUD;
implementation of mitigation measures and management of the impacts generated by the activities of each actor in the context of its ESMP;
collaboration of different actors around concerted intervention activities within the PUD; and
implementation of an E&S monitoring program to assess cumulative impacts over time of the projects in the PUD.
Cumulative impacts on VECs that extend outside the boundaries of the PUD will have to be addressed through broader measures:
the loss of agricultural lands both in the PUD and the surrounding area signals a transition in land use from agriculture to employment-based livelihoods. Planning by the DGPU and local governments, particularly the Prefectures in the local municipalities, should be undertaken to protect as much agricultural land as possible for those who are not able to transition to employment-based livelihoods, while emphasizing education and training for emerging job opportunities; and
particularly to address the impacts of construction on local communities from the construction projects in the area, establish a framework for dialogue and information-sharing with the representatives of the populations (e.g. town hall, district delegates, local associations, religious and customary leaders) and construction companies during the different phases of work.
As part of project cumulative impact assessment, an initial climate risk screening was carried and identified four climate hazards as potential risks for the Project site. Potential climate risks include: extreme precipitation, extreme heat, wildfires and water scarcity. Of these, flooding as a result of extreme precipitation presents the highest risk; wildfires are the lowest risk to the Project as the ESIA notes that there is currently little vegetative cover around the site and thus low available fire fuel load.
The climate at the Project site is characterized by a long dry season with a period of intense heat and heavy rainfall (the ‘hivernage’) during June to October, but particularly August and September. In Dakar generally, flooding is a problem not just because of the intensity of the rains, which are often of short duration, but also owing to the relatively shallow water table. According to the ESIA, the Project site design incorporates features to address both flooding and water scarcity through the creation of a system for gathering rainwater and storing it in three lakes within the PUD. The proposed storm water drainage system comprises a 2-element system, a primary gravity pipe network and a secondary system designed to capture overland flow using ditches and culverts.
The primary network is designed using historical rainfall data - a 1 in 5-year storm return period is selected for the design, though the network is checked for a 1 in 10-year and 1 in 20-year storm return period events to ensure that the network has sufficient capacity to handle any major peak flow storm events. The primary network consists of gullies with grated cover, sand baskets, access manholes and pipes of varying diameter; the network is discharged to three existing lakes.
The secondary system has adopted a design capable of containing extreme storm events with a 1 in 100-year storm return period when working in conjunction with the primary system. The stormwater management design is based on extreme rainfall scenarios and the combination of the primary and secondary systems is estimated to be capable of handling future increases in extreme rainfall due to climate change. Notably, for the roads, a geotextile layer has been proposed above the subgrade to safeguard the pavement structure from capillary rise and high ground water problems.
Finally, all materials are selected with consideration of extreme high temperatures and de-rated accordingly. The design for the PUD’s stormwater system also includes measures to reduce the increased risk of cyanobacteria forming in the water system as result of warming temperatures.
As mentioned earlier, the DGPU does not have an overarching ESMS; instead it has the Green Guide, which provides guidance to developers on key environmental considerations, and it does not elaborate procedures for the DGPU to follow to ensure developer’s compliance with the Guide. The DGPU will therefore be required to develop an ESMS using as the starting point the ESMP included in the draft ESIA and enhance it by adding the elements below to align fully with applicable PSs:
emergency procedures (i.e. procedures in the event of a fire, spill of dangerous products, and act of terrorism);
community grievance management; and
identification and mapping of stakeholders including a stakeholder engagement plan (SEP), which will include a procedure for informing and disclosing information to stakeholders.
The DGPU will develop an ESMS in line with national law and the PSs (ESAP action item
ECOTRA has an online system that it will use to track fleet movements, speed limit, and amount of materials mined from the laterite quarry. Furthermore, ECOTRA has put in place an adequate COVID-19 Management Plan in alignment with government requirements. However, ECOTRA’s EHS procedures should be enhanced to align with its policy and provide a comprehensive ESMS that meets the requirements of PS1 (ESAP action item #3 referred to above).
The DGPU has set up a Coordination unit (CU) for the Project. The CU team comprises of a coordinator and experienced professionals in key areas (e.g.. electrical, environment, monitoring, evaluation, hydraulics and roads network). The CU is responsible for monitoring the EHS elements of the Project and coordinating with DEEC, the government entity responsible for monitoring the ESMP and addressing E&S non-compliances. The CU Director reports directly to the Secretary General of the DGPU. Currently the DGPU has only one EHS specialist to cover the entire PUD, which presents an E&S organizational capacity challenge given the physical size of the PUD and number of developers/companies to monitor. As such the DGPU will be required to build its EHS team with at least one additional EHS specialist (ESAP action item #7).
The DGPU’s Urban Planning and Land Development unit responsible for land acquisition is headed by an Urban Geographer who is supported by an Environmental Professional and a Topographical Engineer. This unit will be required to complement its team with a Social Specialist who can support land acquisition activities, the SEP, grievance management, as well as development and implementation of a livelihood restoration plan (LRP), (ESAP action item #7). Given the diversity of funding sources for the overall development of the PUD, which include development finance institutions that apply the PSs, the DGPU’s Urban Planning and Land Development unit should seek training on international best practice on involuntary resettlement and land acquisition in line with MIGA’s PS5, as well as developing an ESMS (ESAP action item #8).
As discussed above, the DGPU has several units involved in sustainable development. Increased collaboration among these units and with their regional and national counterparts would positively contribute to seamless execution of the DGPU’s sustainable development goals and ESMS (ESAP action item #6).
ECOTRA has a Quality, Safety and Environment unit that is responsible for implementing the Company's policies on EHS management, with a view to mitigating EHS impacts as well as preventing accidents that could potentially arise from the Project. The team is comprised of a Director based in Dubai (United Arab Emirates) with a background in quality and health; and a Safety Engineer based in Senegal with an environmental engineering background. These two experts are experienced in E&S and safety management of construction sites.
Emergency Preparedness and Response
For emergency management, a fire station and a gendarmerie (police) barrack exist in the city center of the PUD. The DGPU will install fire hydrants in the PUD as well as enhance its emergency preparedness and response plan (EPRP) to include emergency scenarios that may arise in the PUD and outline specific roles and responsibilities. The EPRP will also be tested through simulations that include participation of all key stakeholders (ESAP action item #9).
ECOTRA’s EHS plan also includes an EPRP that addresses the management of emergency situations such as fire, release of hazardous products, traffic accidents, electrical and specific requirements including fire-fighting equipment, personal protective equipment (PPE), first aid, etc. During the site visit, it was observed that fire extinguishers were overdue for servicing, and some workers were not wearing appropriate PPE; this was also noted by DEEC during its February 2020 monitoring visit. The DGPU will ensure that ECOTRA updates its EPRP to include: (a) a comprehensive risk analysis; (b) evaluation of emergency scenarios for which procedures have been developed; (c) establishment of an internal emergency response team and delineation of roles and responsibilities; (d) identification of external entities that must intervene in the event of an emergency; (e) establish regular schedule for inspection and maintenance of firefighting equipment; and (f) establishment of an emergency evacuation plan (ESAP action item #6). As previously mentioned, ECOTRA has put in place an adequate COVID-19 Management Plan in alignment with government requirements. Further information on community exposure to disease is provided in detailed on COVID-19 management under PS4.
The DGPU’s CU carries out regular monitoring of ECOTRA's work to ensure implementation of EHS and security measures. The DEEC is also responsible for undertaking site visits and compliance audits on ECOTRA’s activities. Frequent coordination and communication between the CU and DEEC will be enhanced to optimize effective oversight of these aspects of the implementation of the Project. The DGPU is planning the recruitment of an independent engineering and consulting firm (ESAP action item #7) to support the DGPU in environmental monitoring of works. This firm will also work closely with the CU and DEEC to ensure coordination on monitoring as well as support the DGPU in annual reporting on E&S performance to MIGA.
ECOTRA has internal reporting templates on incidents and accidents. However, it needs to put in place an external reporting framework with timeframes and agree to a template with DEEC, who has ultimate oversight responsibility for monitoring the ESMP implementation. Furthermore, the DGPU will ensure that ECOTRA enhances its E&S monitoring framework to include several environmental parameters such as ambient air quality, effluent discharge, waste, noise, grievances among other activities. The DGPU will ensure that ECOTRA, in consultation with DEEC, develops a template for monitoring and reporting on EHS performance to relevant stakeholders (ESAP action item #3).
The ESIA undertook some level of stakeholder analysis and mapping. Stakeholder consultation with communities took place during the ESIA preparation. During the land acquisition process in 2015, consultation with the land users took place as per national legal requirements. A few requests from the communities included: employment opportunities, infrastructure development, health center, and access to the lake for continued subsistence farming purposes.
During the site visit and discussions with a random sample of existing subsistence farmers around the lake within the PUD, two main concerns were raised: (a) ability to continue farming in this area; and (b) impact of the development of the PUD, in particular the ECOTRA project on the lake in terms of water access and availability to continue farming. These stakeholders and others could benefit from increased engagement, as well as disclosure of relevant Project information to help them understand the risks and potential impacts as well as opportunities of the Project.
The DGPU has not established a SEP beyond what is needed for specific transactions and as such one will be developed as part of the DGPU’s ESMS and implemented as per PS1 requirements. Furthermore, the DGPU should also ensure ECOTRA develops a SEP based on the requirements of MIGA’s PS1, incorporating the grievance mechanism and provision of regular information to farmers on their works and potential impact to lake or farming activities (ESAP action item #6).
Grievances are meant to be channeled to and handled by the Prefectures office but claimants’ may also direct grievances to the DGPU. The current grievance mechanism does not seem to be fully understood by claimants who frequently are referred from the DGPU to the Prefectures office. The DGPU will enhance its grievance mechanism and implement a procedure for external communications to explain its functioning. The grievance mechanism will be centralized, enhanced, communicated to stakeholders and incorporated into the SEP (ESAP action item #6).
Ongoing Reporting to Affected Communities
Existing subsistence farmers around the lake are concerned about the Project’s environmental impacts as well as their potential displacement. The DGPU will as part of its SEP, provide these farmers with ongoing information on the issues of concern to them (ESAP action item #6).
PS2: Labor and Working Conditions
Human Resources Policies and Procedures
The DGPU does not have a documented Human Resources (HR) policy. It has Staff Rules and procedures in line with national law. To align with PS requirements: the DGPU will develop a HR policy and update its staff rule to integrate freedom of association as well as a grievance mechanism (ESAP action item #9).
ECOTRA has developed a recruitment policy that includes forecasting and planning, non-discrimination, equal opportunity and the public disclosure of employment opportunities, which involves advertising on ECOTRA’s website, in newspapers and online. The DGPU will ensure that: (a) the recruitment policy is signed by ECOTRA’s senior management; and (b) the Staff Rules which also indicates EHS measures to be observed on the site is strengthened to align with the requirement of PS2 (ESAP action item #10).
Working Conditions and Terms of Employment
The DGPU currently has 73 employees, of which 22% are women. All staff have employment contracts and are provided with health insurance. Although the DGPU has a training budget, and will establish a training plan.
ECOTRA has a workforce of 626 employees with a percentage of 5.27% women. There were 50 expatriates as of March 2020. The labor force is composed of contract workers and day laborers whose number varies (100 to 400) depending on the season. Influx of workers has not been identified as an issue in this Project. The cleaning service is subcontracted and consists of 20 people.
ECOTRA employees' contracts are compliant with the statutory working hours of 8 hours per day from Monday to Friday and, in some instances Saturdays. ECOTRA’s employee contracts are registered with the labor inspectorate and workers are affiliated with social institutions such as the pension authority (IPRES), social security (CSS) and workers’ compensation (IPM). It should be noted, however, that hiring and payment procedures for day laborers must be revised to comply with Labor code decree 97-17 (1st December 1997), including the requirement that work hours must not exceed six hours and forty minutes per day and for maximum of 5 days a week. The DGPU will ensure that ECOTRA carries out a comprehensive review of its human resources policies and practices for hiring day laborers to ensure compliance with national legal required practices, including regulations on work hours and provision of pay slips (ESAP action item #11). Furthermore, in line with the ESMP in the ESIA, ECOTRA will include awareness raising of its employees on HIV/Aids and sexually transmitted diseases and sexual harassment.
The DGPU does not have unions or worker’s representatives, however it does not discourage freedom of association. The staff are organized in a staff association but not geared towards issues of labor and working conditions. The DGPU will include in its staff rules that freedom of association is allowed as per the Labor Code (ESAP action item #9).
ECOTRA does not currently have a trade union or staff representatives for the Project, however, the company does not discourage freedom of association. The DGPU will ensure that ECOTRA includes in its Staff Rules that freedom of association is allowed as per the Labor Code (ESAP action item #10).
Non-Discrimination and Equal Opportunity
The DGPU has confirmed that principles of non-discrimination, equal opportunity and fair treatment are important and respected with respect to any aspects of the employment relationship, such as recruitment and hiring, compensation (including wages and benefits), working conditions and terms of employment, access to training, job assignment, promotion, termination of employment or retirement, and disciplinary practices. Furthermore, there is, no specific policy that addresses harassment, intimidation especially regarding women, this will specifically be included in their HR policy (ESAP action item #9).
As per the Recruitment policy, ECOTRA and Staff Rules and discussion with HR managers, the principle of non-discrimination and equal opportunity is applied in every aspect. There is, however, no specific policy that addresses harassment, intimidation especially in regard to women (ESAP action item #10).
There is no planned retrenched by the DGPU or ECOTRA.
The DGPU does not have a formal grievance mechanism included in the Staff Rules. Grievances are dealt directly with either Human Resources and or the hierarchic manager of the staff.
ECOTRA has developed an internal grievance procedure (e.g. accessible grievance box system) that is available to all workers including third-party workers. Complaints received are identified and sent to relevant teams (HR and senior management) for assessment and response. ECOTRA reported that the most frequent complaints are related to disagreement in overtime payment. ECOTRA will review it grievances mechanism to align with PS2 including providing options for anonymous reporting (ESAP action item #10).
Protecting the Work Force
The DGPU as a government entity does not employ any child labor, minimum age for internship is 18 years; and there is no forced labor.
ECOTRA has confirmed that it does not employ child labor for any tasks. Only applicants 18 years or above can be considered for hiring. Forced labor is banned. Even though ECOTRA does not hire minors, it will need to be vigilant to ensure that subcontractors do not bring into the site employees or driver apprentices who are less than 18 years of age noting that national law permits apprentice driver from age 16. The DGPU will ensure that ECOTRA enhances its vigilance and raises awareness with subcontractors (ESAP action item #12).
Occupational Health and Safety
The DGPU staff work in offices, they typically go on site to identify land to be acquired or to supervise construction projects. The DGPU staff has access to astock of personal protective equipment (PPE); that include safety shoes, protective glasses; and masks and reflective vests.
The draft SESA has identified accidents and incident risks that may occur in the various projects and construction works in the PUD that the DGPU will need to manage. The DGPU has proposed mitigation measures such as: (a) training workers on risks and prevention measures; (b) provision of PPE for all staff; (c) ambulances for medical response and first aid response services for interventions; (d) a well-equipped on-site infirmary; (e) awareness campaigns to promote health and safety; (f) safety signs; (g) traffic management plan, including pedestrian designated areas and crossings; and (h) speed limits signage for vehicles. These measures are part of the ESMP that will be incorporated into the DGPU’s ESMS (ESAP action item #6).
ECOTRA has drafted a summary document to put in place a Health and Safety committee and has trained the team that will lead this committee. ECOTRA willestablish the committee as per legal requirement. The DGPU will ensure that ECOTRA promptly acts and resolves this gap in its ESMS (ESAP action item #3).
To manage the risk of accidents and incidents, ECOTRA implements prevention and protection measures that include: (a) health and safety plan; (b) medical visits before hiring; (c) daily EHS induction; (d) provision of PPE to workers; (e) availability of first aid kits and fire extinguishers; and (f) an infirmary staffed with a doctor and two nurses. However, this system could be enhanced by implementing measures to increase staff training in life, fire and safety such as first aid, rescue and evacuation drills, designating fire wardens, designating a muster point, and establishing clear roles and responsibilities (ESAP action item #13).
DEEC’s visit of February 2020 noted the following gaps in OHS performance: unprotected open trenches more than 2m deep, PPE not consistently worn by workers and dust management issues. The DGPU will ensure that ECOTRA will rectify these performance gaps and report on OHS performance as part of its external reporting procedures (ESAP action item #3).
The DGPU will ensure that ECOTRA provides suitable PPE for the work undertaken, renewed as needed and provided to all workers (ESAP action item #14).
ECOTRA has short term housing for expatriates in Saly (40 km away) and Thies (35 km away) while they secure their own long-term accommodations. ECOTRA has confirmed that the short-term housing is in good condition.
Workers Engaged by Third Parties
As a third-party firm to the DGPU, ECOTRA’s policies, procedures, management and monitoring of PS2 have been described above and where applicable corrective actions to meet this PS has been proposed as part of the ESAP. The main construction contract is likely to be split into several work packages, overseen by the EPC contractor, and possibly undertaken by several sub-contractors. The EPC contractor will ensure that third parties meet the applicable E&S, national labor law and PS2 requirements (ESAP action item #11).
PS3: Resource Efficiency and Pollution Prevention
As mentioned previously under PS1, the DGPU has general plans in place that outline the management of pollution releases to air, soil and groundwater, as well as noise pollution in the Green Guide Document. However, the DGPU does not have specific procedures to ensure that companies do not pollute. This gap will be addressed as part of the development of a comprehensive ESMS (ESAP action item #6).
Resource Efficiency and Pollution Prevention
Both the DGPU and ECOTRA source electricity from the national network. ECOTRA has two backup generators (1000 kilowatt (kW)) which operate on gasoline and are filled by an onsite tanker truck. Currently, ECOTRA has water supply delivered to Diamniadio by tanker trucks. A connection to the network of the national water company, Senegalaise des Eaux S.A. (SDE), is in progress.
The direct sources of carbon dioxide (CO2) emissions include use of diesel and furnace oil in vehicles (ECOTRA has its own fleet of trucks and cars that are maintained on site by a third-party vendor, SMPL, a subsidiary of Easy Group, an ECOTRA partner) and backup power generators, and electricity are purchased from the grid. The total gross GHG emissions for the Project are expected to be below 25,000 tons of CO2 equivalent annually. As part of its ESMS, ECOTRA will measure its GHG footprint (ESAP action item #3).
As indicated above, water for the Project is provided by tanker trucks. There is natural drainage of stormwater from north to south toward the lakes. This directly benefits subsistence farmers around the lake in the Project area. As part of the Project design, a rainwater harvesting program will be put in place to collect water and treat wastewater to: (a) be reused to irrigate the green spaces of the PUD; (b) serve as water for firefighting; and (c) supply the lake. The DGPU plans to increase the capacity of the lakes by dredging. The capacity of one of the lakes has been increased from 70 to 100m³. The three lakes will be connected by pipelines so that excess water in one lake can drain to another. Once the retention capacity of the lakes is reached, excess water will flow through the current natural channel towards the sea, 5 km away. The houses being constructed near the current natural channel may be threatened by the flow of water from the Project site. The proposed hydrological study will identify the likelihood and scale of such threats and any mitigation measures will need to ensure the protection of the biodiversity values of the La Petite Cote Key Biodiversity Area (KBA) (see PS 6 section). Thus, following the proposed hydrological study (ESAP action item 26), the DGPU will discuss with ECOTRA options to reuse this excess water instead (ESAP action item #15). Water use will be monitored during construction and operation with annual consumption rates provided in annual reporting on E&S performance to MIGA.
The DGPU has an agreement with the national air quality management authority to carry out air emissions measurement. It is the responsibility of each of the companies in the PUD to monitor the environmental aspects associated with their activities as per their respective ESMPs, including monitoring of relevant environmental parameters. However, as part of its EHS reporting, the DGPU will be required to monitor and report on dust control measures such as regularly watering runways and traffic lanes (at least twice a day), limiting traffic speeds and ensuring truck tarpaulins are sealed (ESAP action item #6).
Atmospheric contaminants generated by the Project include gaseous emissions from site equipment, vehicles and generators, as well as dust and particulate matter from the transport of construction materials and movement of machinery and vehicles. ECOTRA implements mitigation measures for air, soil, water and noise pollution for their base camp, including: (i) water spraying and sealed tarpaulins on trucks to mitigate dust; and (ii) speed limit of 30 kilometers per hour (km/h).
The PUD has a wastewater treatment plant (WWTP) for treatment of sanitary wastewater. Currently, the WWTP (1800 m3/day) was built to connect to the existing developments within the PUD. A Government-approved contractor is in the process of setting up a technical facility in Diamniadio that will serve all PUD operations and contractors. The phase II and III expansions will be able to treat 14,000 m³/day and to meet maximum demand once the entire PUD is operational.
The national company responsible for wastewater management, ONAS, provides technical quality control to verify that the WWTP is functioning within its capacity. Treated wastewater is reused within the PUD and the remainder injected into the lake. Treatment of industrial wastewater is the responsibility of the companies that produce them.
ECOTRA has an agreement with an approved vendor to periodically empty the septic tanks and discharge their contents to the municipal WWTP. Stagnant water was observed in ECOTRA’s washing area both in the photographic documentation as well as during MIGA’s site visit. The drainage of wash water to the recovery tank is not adequate and as such the overflow leads to stagnant water in this area. The DGPU will request that ECOTRA assesses the effectiveness of wash water drainage to the recovery tank to prevent retention of stagnant water, identify all waste streams (solid and liquid) including construction site wastewater such as runoff and concrete wash water, and incorporate procedures to manage these waste streams into its ESMS (ESAP action item #16).
Non-hazardous waste is currently sent to the existing Mbeubeuss landfill which is approximately 20 km away. The DGPU is currently working with the Ministry of Urban Planning on a comprehensive solid waste management and recycling project for all non-hazardous waste streams. Asphalt plant waste is sent to a government managed site located outside the PUD. The DGPU will be required to develop a waste management plan to include hazardous and non-hazardous wastes in accordance with PS3 requirements (ESAP action item #6).
Collection and transport of ECOTRA’s domestic and construction wastes is contracted to a government-approved vendor for disposal at the Mbeubeuss municipal landfill.
Hazardous Materials Management
The DGPU does not provide services for hazardous waste, it is the responsibility of individual developers to manage. However, the DGPU will develop and implement procedures to monitor the hazardous waste management of the companies within the PUD (ESAP action item #6).
ECOTRA has two sites: one base camp and a construction site where the concrete batching plant is. The sites includes several operations that use or can generate hazardous materials: truck and heavy machinery parking areas, a washing area, a maintenance area and maintenance workshop, a concrete facility, a coating facility, hydrocarbon storage areas (two diesel tanks of 30 m3 one with no secondary containment, a gasoline tank of 5 m3 with secondary containment, and a 30 m3 bitumen tank with no secondary containment). ECOTRA plans to place the petrol tank underground including a secondary containment structure in the near future.
ECOTRA contracted an approved disposal service for the collection and transportation of hazardous wastes such as used oil, filters, ink cartridges, used oily rags and contaminated waste. The DGPU will ensure that ECOTRA’s ESMS will be updated to include a written procedure for the management/storage of hazardous materials; and for transferring diesel fuel from delivery vehicles to underground storage tanks (ESAP action item #6). Furthermore, the DGPU will ensure that ECOTRA installs secondary containments in the storage areas for diesel tanks as well as in the used oils (ESAP action item #17).
Excavation spoils, which consist primarily of clay, are stored in a dedicated area within the Project site and reused. On site black soil (clay-humus soil) from excavation is used to fill low points in the Project area. The marly-limestone cuttings are stored and mixed with the laterite at a ratio of 37.5% marl to 62.5% laterite. The mixture obtained has geotechnical characteristics suitable for backfilling trenches after laying pipes and to fertilize the green spaces in the PUD. During the site visit, piles of spoils were observed.,the DGPU should ensure that ECOTRA as part of its ESMS manages these spoils prior to the rainy season (ESAP action item #3).
PS4: Community Health and Safety
Community Health and Safety
The DGPU’s draft SESA considered the health and safety of nearby communities that could be affected by the transportation and movement of construction materials, equipment and vehicles during works of various companies. The draft SESA recommended the following impact mitigation and accident prevention measures: (a) regular watering of runways and traffic lanes; (b) community information and awareness campaign; (c) covering of trucks transporting construction materials; (d) adjustment of noisy work schedules; (e) noise level monitoring; (f) monitoring of air quality emergency procedures; (g) installation of traffic signs; (h) installation of track dividers; and (i) planning of intervention procedures in the event of an accident. As part of its ESMS, the DGPU will elaborate procedures to manage the above risks to ensure community health and safety.
In addition, the transport of materials and the movement of vehicles and trucks from the quarries to the base camp pose potential E&S risks and impacts. The DGPU will ensure that ECOTRA develops mitigation measures under its ESMS to address impacts to community health and safety, this includes developing and implementing safe driver and transport safety vehicle procedures, including training sessions for its own and third-party haulage contractors during construction to be developed as part of the traffic management plan (ESAP action item #3). To date no on-site vehicular accidents have been recorded by ECOTRA.
In addition to these measures, DGPU will ensure that ECOTRA periodically organizes effective awareness sessions with communities likely to be impacted by informing them of Project activities. The sessions will include potential E&S risks and impacts from the quarry and the mitigation measures to be implemented (ESAP action item #18).
Hazardous Materials Management and Safety
As part of its ESMS, ECOTRA will be required to develop a hazardous material management plan within and outside the fence to ensure that it avoids or minimizes the potential for community exposure to hazardous materials particularly during transport. Furthermore, DGPU will ensure that ECOTRA will exercise commercially reasonable efforts to control the safety of delivery of hazardous materials, and of transportation and disposal of hazardous wastes (ESAP action item #19).
Community Exposure to Disease
ECOTRA through its ESMS will avoid or minimize the potential for community exposure to COVID-19 per their COVID-19 Management Plan from its workers’ interactions with communities. ECOTRA will continue to raise awareness amongst all its workers and ensure that they are: (a) provided with masks to use on their way to and from work; and (b) that they are continuously informed on protection measures against COVID-19 (ESAP action item #20).
Emergency Preparedness and Response
Under PS1 in the EPR section, the DGPU is required to collaborate with key stakeholders in their preparations to respond effectively to emergency situations, especially when their participation and collaboration are necessary.
Security guards inside the DGPU building are contracted through a third-party contractor and are unarmed. ECOTRA has its own in-house experienced security staff, most previously served in the army or gendarmery. The DGPU will ensure that ECOTRA is guided by the principles of proportionality and good international practices in relation to hiring, rules of conduct, training, and equipping. The DGPU will also make reasonable inquiries to ensure that the security guards are not involved in past abuses (ESAP action item #21).
PS 5: Land Acquisition and Involuntary Resettlement
Land acquisition is strictly guided by the national requirements. These guidelines and procedures will be integrated into the comprehensive ESMS that the DGPU will be required to develop and must meet all GoS requirements as well as the standards of its international lenders including Performance Standards. In addition, DPGU will develop a land acquisition framework/procedure in accordance with national requirements and PS5 to ensure that future land obtained for the Project will meet PS5 requirements. The procedure will provide for public disclosure of PAPs’ identification, asset valuing methods, compensation rates and schedule and appeal processes, so that future PAPs understand the compensation process and know what to expect at the various stages of the transaction. The procedure will include a transparent process for consultation and compensation (or where necessary, livelihood restoration). (ESAP action item #22).
According to the DGPU, it compensates existing land users at the start of each project, rather than compensating at one time for all the land in the PUD project footprint. Land within the PUD is secured on an as-needed basis. The most up-to-date figures for the Project site, (which is the subject of MIGA’s proposed guarantee cover), indicates that a total of 10 PAPs have been compensated for 17 plots of land to date in line with national legislation. These represent all the plots that have been acquired to date, thus, no further compensation payments are due at this point. These plots primarily contained mixed crops, trees, and six permanent structures. The land acquired so far, 84 ha, does not cover the entire Project site, the total size of which is estimated to be approximately 400 ha. As the site is further developed an additional land acquisition process will be conducted.
Both the DGPU and the Prefecture of the Rufisque Commune confirmed that land was provided free and clear per national law. The Senegalese policy regarding land acquisition requires that the state must initiate the procedure for a project to secure land. Whenever the development of an area necessitates the acquisition of additional land, the DGPU mobilizes the Commission Départementale de Recensement et d’Évaluation des Impenses (CDREI) of the city of Rufisque, mandated by “décret n ° 00055 / DR 28 juin, 2004”, to develop an inventory of the PAPs’ assets and determine their value, and, if necessary, reconcile any differences in accordance with the grievance resolution procedures of the GoS’s National Mediation and the Conciliation Committee. The land that the 10 PAPs were farming is considered state-owned and the PAPs did not possess an actual or a customary title. This resulted in the PAPs being compensated for the standing assets (e.g. crops, trees, irrigation infrastructure, and permanent structures) but not for the land they were using. This aspect of compensation is in line with PS5 requirements.
Senegalese compensation rates are based upon scales established by national regulations, with crop compensation being based on a rate per square meter. According to the DGPU, these nationally set rates are generally considered to be at fair market value, however, experience in several projects have shown that to meet MIGA’s PS additional compensation is typically required. Based on information from the DGPU, compensation for trees represent over half of all compensation paid, followed by compensation for permanent structures.
To meet the requirements of PS5, a socioeconomic survey, livelihood restoration measures, or monitoring of PAPs after compensation will need to be done. Based on available information, it was not possible to determine whether all PAPs were able to restore their livelihoods. The ESIA considered impacts on agricultural activities and recommended that PAPs be hired both as part of the construction phase and for future operations with other companies in the PUD. The DGPU will prepare a vulnerability assessment and action plan based on a review of the PAPs ability to restore their livelihoods (ESAP action item #23).
As part of its Community Development Plan (CDP), the DGPU has an annual budget to provide services and amenities to surrounding municipalities. To date it has already invested in the construction of infrastructure (e.g. access to potable water and access to quality health services etc.) to support local communities. Furthermore, PUD’s development plan includes plans to build schools, universities, and health structures to benefit surrounding communities. To ensure that the CDP is aligned with the concerns and priorities of communities and PAPs, the DGPU will revise the CDP as needed to address any findings by the vulnerability assessment of former landowners on the Project site who were unable to restore their livelihoods based on the findings from the vulnerability assessment (ESAP action item #24). Furthermore, a LRP will be developed for the entire area (Arrondissements 1, 2, 3 and 4) that would entail the CDP to achieve outcomes that are consistent with the objectives of the Performance Standards (ESAP action item #24).
The Project footprint was previously used for herding with usage near the lakes. The herders were not compensated under the Senegalese procedures because they had no assets in the Project footprint that required acquisition. MIGA’s PS5 requirements covers restrictions on access to resources similar to what is consider under land acquisition procedures. In this case, the DGPU will ensure that herders have adequate access to water within the larger area and will consider granting access to seasonal ponds designed to hold run-off water from the site (ESAP action item #25).
For the small-scale vegetable gardeners who are active around the lakes (approximately 20-50 at present), the DGPU has indicated that for the moment, there are no plans to move them, but it cannot be excluded in the future. There are plans to increase the capacity of the lake on the Project site, as well as a plan to redevelop the area. Thus, if further land acquisition takes place within the Project site, the DGPU is committed to developing a livelihood restoration framework based on PS5 that will ensure that any land obtained in the future for the Project will meet PS5 requirements (ESAP action item #22). Thus the gardeners will be included in the vulnerability assessment (ESAP action item #23).
PS6: Biodiversity, Conservation of Living Natural Resources
The Project is located in an area that has largely been modified by urban encroachment, deforestation, grazing, agricultural land and drought. Patches of degraded savanna shrub and steppe habitat exist characterized by various species such as acacia and euphorbia. The vegetation supports several locally common bird and mammal species including black-headed lapwing (Vanellus tectus), red-billed hornbill (Tockus erythrorhynchus), the Barbary gonolek (Laniarius barbarous), and house sparrows (Passer domesticus). It is likely that many of the original species and ecological functions in the area have been lost due to habitat modification.
The Project’s ESIA dated December 2019, photos from drone flights of the Project area, and an additional biodiversity desktop assessment of a variety of sources (e.g., Integrated Biodiversity Assessment Tool, International Union for Conservation of Nature Red List of Threatened Species, Birdlife International and Alliance for Zero Extinction) indicate that the site does not support critical habitat. However, the ESIA refers to the presence of several partially protected tree species under national legislation, including the baobab (Adansonia digitata). The removal of these species would require reforestation activities based on an offset determined by La Direction des Eaux et Forêts, Chasses et de la Conservations des Sols (DEFCC)  . The Project specifications ensure the retention of these trees in the landscape.
During the construction phase, E&S impacts include habitat loss, and temporary noise, dust and vibration. However, given that most of the habitat is modified and any remaining natural habitat is very degraded, these impacts are unlikely to be significant. The Project’s ESMS will incorporate measures to minimize impacts.
As stated under PS1, ECOTRA will operate a laterite quarry. The quarry is located in the peripheries of the Sébikotane Classified Forest Reserve. This area is a modified habitat that has been subject to significant anthropogenic pressures including housing, wood harvesting, bush fires, grazing, agriculture, and quarrying. It comprises shrub savanna and steppe although the presence of several tree species including baobab and the Neem tree (Azadirachta indica) suggests that the area was once more forested.
The 2018 Forest Code requires that an ESIA be undertaken prior to quarrying activities together with the preparation of rehabilitation plan. Once the ESIA has been completed, the proposed E&S management plans will be incorporated into ECOTRA’s E&S management system for the Project and any biodiversity action plan will be included in the ESAP to be implemented by ECOTRA and supervised by DGPU, (ESAP action item #4).
Legally Protected and Internationally Recognized Areas
There are no protected areas or internationally designated sites directly affected by the Project. Furthermore, there are no impacts from the Project on Ramsar site or Mbao protected Forest. The nearest designated site is La Petite Cote, a Key Biodiversity Area (KBA) /Important Bird Area (IBA) and the boundary of which is just under a kilometer to the south of the Project site. La Petite Cote, is a coastal strip that extends from Bargny south to the village of Mbodiène, comprising sandy beaches, offshore sandbars, dunes and saltmarsh, crossed by several small rivers and estuaries. There are also some shallow lagoons and temporary wetlands in depressions behind the dunes. The site is important for breeding and wintering waterbirds, and is likely critical habitat under criterion 3, migratory or congregatory species. The Project is
Alien Invasive Species
The company’s ESMS will include measures to avoid the introduction of invasive alien species. It will use only native species in site restoration activities.
Management of Ecosystem Services
No impacts on ecosystem services are anticipated on the main Project site and any priority services affected by quarrying activities in the classified forest will be addressed in the to be developed ESIA for the quarry.
The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org.
For additional information, please contact:
Mamadou Faye, ing., M.Sc.A, Ingénieur Polytechnicien, Structure, et ouvrages d'art, Coordonnateur du PUI, Diamniadio, DGPU
Phone number: 00221 775549552
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
Broad Community Support is not applicable for this Project.