District of Bogota Metro Line 1

MIGA is being asked to provide non-honoring of sub-sovereign financial obligations (NHSSFO) guarantee for up to COP 3,200 billion (US$828 million) from BNP Paribas S.A. and/or potentially other commercial lenders yet-to-be-identified (the Lenders) to Bogotá, Distrito Capital (Distrito). The proceeds will be used by Distrito to fund its contributions to the second tranche of fundings for the construction and operation of the Line 1 of the Metro of Bogota (the Project), that will be built and operated by Empresa Metro Bogota (EMB), public company fully owned by Distrito, with the support of a consortium formed by China Harbour Engineering Company (CHEC) and Xi’ An Rail Transportation Group as Engineering Procurement and Construction (EPC) contractor.  

The Project will be Bogota's first metro line. It includes a 24 km long elevated metro with 16 stations, a depot, the supply of 30 trains, and the electrical, control, telecommunications, ticketing and fare collection systems, and access roads. The Project also covers preliminary works, the restructuring of some existing Bus Rapid Transit (BRT) lines and associated stations, and the upgrading of public spaces. The Project crosses the most densely populated areas of the city and is mainly located along the TransMilenio line, crossing the neighborhoods of Bosa, Kennedy, Puente Aranda, Barrios Unidos, Mártires, Antonio Nariño, Chapinero, Teusaquillo, and Santafé. It begins in the western part of the city, where the Yard will be located, up to Avenida Caracas and Calle 76. 

The Project is being implemented under a concession agreement for the Design, Finance, Build, Operation and Maintenance. Construction, financed with a first tranche in 2018 by the International Bank for Reconstruction and Development (IBRD)1, Inter-American Development Bank (IDB), and European Investment Bank (EIB), started in 2021 and is currently at 55% completion. The proceeds from the second tranche of financing will support the remainder of the construction, with commissioning expected by 2027. These institutions are expected to finance also part of the second tranche. IDB and IBRD are also providing technical support to the Project.  

The following documents were reviewed by MIGA:  

In addition to reviewing the above documents, MIGA conducted an E&S due diligence visit in July 2025 which included meetings with key staff and management, community representatives, as well as visiting the main construction front and the worker’s camp.  

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 managed in accordance with the PSs. 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 Policy and Management System: 

EMB was established in 2016 and has since been committed to building and maintaining a robust Environmental and Social Management System (ESMS). The Company has adopted an overarching E&S Policy and ESMS committing to sound E&S performance across all its operations. The E&S Policy and ESMS confirm its commitment to follow national and other internationally recognized sustainability standards to which the Project subscribes, as the IDB, IBRD, and EIB E&S Standards. EMB has also developed, among others, the following policy documents: Corporate Social Responsibility Policy; Labor and Human Rights Policy; Code of Conduct; Forced Labor and Child Labor Policy. Observations during the site visit indicated a high standard of management of the E&S aspects within the current operations.  

EMB implements the ESMS throughout its activities and operations. The ESM guides consistent management of E&S aspects across the entire operation, collecting all procedures and plans in line with the requirements of PS1. The ESMS includes (i) all relevant E&S policies including the ones listed above; (ii) management programs and plans (ESMP); (iii) organizational structure, roles and responsibilities; (iv) emergency preparedness and response; (v) training, monitoring and review; (vi) the resettlement framework; and (vi) stakeholder engagement and grievance management programs. Distrito will require EMB to continue implementing the ESMS, ESMP, E&S procedures, and mitigation measures throughout the life of the Project (ESAP item). 

Identification of Risks and Impacts:  

The key E&S risks and impacts of the Project are typical of this type of large infrastructure in highly populated urban areas. These include: i) land acquisition, involuntary resettlement, and impacts on livelihoods including temporary loss of livelihood for commercial activities; ii) impacts on cultural heritage; iii) generation of expectations, conflicts, and grievances from the community; iv) traffic; v) biodiversity; vi) noise, vibrations, air pollution; vii) OHS and workers management; viii) security and community safety; ix) moderate ground settlement near Project foundations.  

The Project carried out an ESIA in 2018 that identified all those risks and impacts. To comply with the E&S safeguards and standards of IBRD, IDB, and EIB, the ESIA and ESMP were updated in preparation of the second phase of Project. A consolidated version of the ESIA and the ESMP was finalized in November 2024. Air quality, noise, and vibration monitoring and modeling were performed and included in the ESIA, and the results were analyzed against current regulations. Impacts on groundwater and aquifer contamination and landslide risks, among other factors, were also assessed. The ESIA also assessed impacts on biodiversity. The ESIA includes also an assessment of social impacts, focusing on economical and physical displacement, cultural heritage, traffic, damage to properties, workers management and community health and safety. Visual impacts have been assessed and managed through specific interventions such as the installation of parks and green areas. Regarding indirect impacts, the ESIA identified changes in the dynamics of formal and informal vendors, land occupancy and value. Socioeconomic programs, as the Economic Sustainability Program, Public Space Occupants Plan, Land Occupancy and Value Observatory Program, Urban Fabric Construction Program, are in place to mitigate those impacts. 

Management Programs:  

The ESIA includes mitigation measures, ESMP, and design modifications (such as noise control parameters for rolling stock and track maintenance, Lead Rubber Bearing (LRB) devices for vibration management and providing seismic isolation for the viaduct's piers) to address identified risks and impacts. The ESMP groups together several plans and programs for both construction and operations, including the Monitoring and Follow-up Program, the Disaster Risk Management Plan, the Resettlement Action Plan (RAP) (more details in PS5 section below, including also details on temporary economic displacement), among other plans, which contain measures to prevent, mitigate, correct, and compensate for the impacts generated by the Project. Specific measures to minimize the identified impacts during construction include but are not limited to: monitoring of noise levels; dust management; monitoring of potential ground settlements and application of specific soil treatments where required; soil remediation; traffic management; waste management; cultural heritage; occupational and community health and safety management. Distrito will require EMB to continue to implement the ESMP and related mitigation measures throughout the implementation of the Project (ESAP item). Distrito will require EMB to submit for MIGA’s review the final ESMP relative to the operation phase before the start of operations (ESAP item). 

Organizational Capacity and Competency: 

At the Project level, EMB has a comprehensive E&S management structure responsible for the implementation of the ESMS and ESMP. The unit is composed by 70 professionals including environmental engineers, occupational health and safety specialists, and resettlement and social professionals. The Project has also a Supervisory Department tasked to provide overarching review and support on E&S and technical matters to EMB and the EPC contractor. In addition, the EPC contractor also has established a comprehensive E&S management department that reports and works in coordination with the Supervisory and EMB E&S department.  

During construction, inter-institutional coordination processes were undertaken between EMB and Distrito and other entities that lead specific issues and have recognized programs and results in addressing social processes, such as the Urban Development Institute (IDU) around property acquisition and resettlement, and the Institute for the Social Economy (IPES) for managing the economic dynamics of informal commerce. Coordination was also advanced with the Secretariat for Women, Directorate of Sexual Diversity, Directorate of Culture, Secretariat for Social Integration, District Institute of Heritage and Culture, Secretariat of Heritage, and Ministry of Culture. They contributed to the development of mitigation measures, as the archaeological surveys, promotion of community participation, consultation and input into the project. 

Distrito, which fully owns EMB, does not have a focal point or unit dedicated to oversight the Operation and its E&S aspects, and it relies instead on the various departments already existing at city level. To ensure sufficient oversight of EMB and coordination of Distrito’s E&S responsibilities for the Project, Distrito will appoint an E&S Implementation Unit (ESAP item). The Unit can be formed by newly contracted personnel or by resources already available within Distrito that have an understanding of the E&S risks and impacts associated with the Project.  

Emergency Preparedness and Response: 

The Project has a Disaster Risk Management Plan in with PS1, that focuses on seismic and flooding risks, among others. Based on the morphology of the city, the ESIA identified three flood zones, corresponding to the floodplains of the Bogotá, Tunjuelo, and Fucha rivers. The design of the Project was modified to make the flood susceptible sections of the Project resilient to extreme flood events with return periods of 1,000 years. The Plan includes also contingency measures in case of seismic events, with the Project designed to withstand events with return periods of 1,000 years.  

Monitoring and Review: 

The Project ESMS has E&S monitoring programs in place. Periodical E&S internal inspections focusing on ESMS and ESMP alignment, and good housekeeping practices are conducted. The monitoring and inspection programs include E&S key performance indicators as energy consumption, generation of hazardous and non-hazardous wastes, effluents quality, lost-time injuries, employee turnover and absenteeism, employee training, grievances (e.g., open vs resolved) by internal and external stakeholders, and social indicators. Distrito will implement monitoring and inspection programs to follow up on the progress and performance of the Project. Within these programs, Distrito will also monitor EMB’s management of internal/external grievances, workers health and performance, and engagement with communities and stakeholders (ESAP item).  

Currently EMB submits periodic (semi-annual during construction, annually during operation) E&S monitoring reports to the IBRD, IDB, and EIB. Distrito will share those reports to MIGA and also prepare and submit to MIGA periodic E&S Annual Monitoring Reports (AMR), covering the outcomes of the monitoring and inspection program on EMB activities and any action taken by Distrito to manages the E&S aspects of the Project.  

Stakeholder Engagement: 

The ESIA process included a Social Participation Strategy and went through extensive consultation activities in 2017 and 2018. Specific consultations were also carried out with the stakeholders directly affected by the displacement process. Consultations were considered meaningful, culturally appropriate and inclusive, with more than 5000 people actively participating. Consultation results showed concerns from the population in relation to displacement, traffic, employment, noise and vibration. The Project addressed those concerns at the meetings, inviting the stakeholders to also submit concerns and suggestions via the established engagement channels. Each suggestion or concern submitted through the system is reviewed, categorized, and responded/resolved. With respect to stakeholder engagement undertaken as part of the resettlement process, the information included in the Resettlement Action Plan (RAP) shows that both those economically and physically displaced as well as the broader community were satisfactorily informed and consulted on the land acquisition and resettlement process.  

Stakeholder Engagement Programs (SEP) are in place and set out which external parties are involved in the implementation and when, and which approaches for engaging on the Project and associated activities are foreseen including those defined in the ESIA and ESMP. Since the start of the construction, the Project has deployed a team to inform about project activities and work with local business and organizations. Distrito will require EMB to continue to implement the SEP and continue its engagement activities with the community throughout the life of the Project (ESAP item). Distrito will report on the implementation of EMB SEP in the in the AMR to MIGA. 

External Communication, Grievance Mechanisms & Ongoing Reporting to Affected Communities: 

The Project has established a robust grievance management procedure (GRM) that provides direct and accessible communication channels for all citizens in Bogotá and for those affected by the Project. The Project has received several grievances since the start of construction that are under review or have already been addressed. A specific class of grievances relates to temporary loss of economic livelihood by commercial activities (more details included in PS5 below). The GRM for the Project in line with good practices is in place and operational. It is based off the principles of (i) committing to zero tolerance of retaliation against stakeholders raising concerns; (ii) including regular in person visits by EMB representatives to the affected stakeholders; (iii) being adapted to address Gender Based Violence and Harassment (GBVH) complaints with those responsible for receiving GBVH-related cases having appropriate training/qualification. In addition, people filing grievances are regularly informed of the resolution process. Distrito will require EMB to maintain the GRM active throughout the life of the Project, and Distrito will report on the implementation of the GRM in the Annual Environmental and Social Monitoring Report to MIGA (ESAP item). 

PS2: Labor and Working Conditions 

The Project is employing 13,000 employees during the construction phase. 300 of those are employees of EMB, while the remaining 12,700 are contracted by the EPC, of which 125 were brought to Colombia from China to cover management positions.  

Working Conditions and Management of Worker Relationship:  

EMB and the EPC contractor have respective Human Resources (HR) Departments. Day to day HR supervision is performed by the worksite managers at each construction front. In accordance with national law on labor standards and International Labor Organization (ILO) obligations ratified by Colombia (Colombia ratified all ILO fundamental conventions), workers contracts comply with ILO core labor standards. Contractors shall ensure occupational and community health & safety as part of their works contracts. All these requirements are spelled out in the Labor Integrated Management System. The system is in line with MIGA PS2 requirements and includes the following commitments: non-hiring of minors, voluntary overtime, fair and on-time payment of salaries compliant with minimum wage, provision of decent accommodations and adequate food, non-discrimination, prohibition of harassment and sexual harassment, prohibition of abusive disciplinary measures, freedom of association, comply with maternity legal provisions, and no discount of salaries due to fines. The contents are explained to workers at recruitment during a 1-hour induction training and available onsite. Distrito will require EMB and the EPC to continue implementing the Labor Integrated Management System to ensure that all the contracts under this project will comply with ILO core labor standards (ESAP item). A year prior to the end of construction activities, Distrito will require EMB to include measures for the demobilization of the construction workforce (ESAP item). Distrito will conduct periodic labor and OHS audits, proposing corrective action where necessary (ESAP item).  

The EPC contractor rented a hotel facility to accommodate the 125 workers brought in from China. The facility is in line with the requirements of PS2 and the IFC/EBRD Guidance Note on Workers’ Accommodation. The facility is also periodically audited by EMB, national labor associations, and IBRD, EIB, IDB. Distrito’s review of EMB’s audit will be included in the AMR.  

Protecting the Work Force: 

Colombia’s labor laws allow for worker’s organizations and protect labor leaders against discriminatory actions by employers. However, less than 4% of workers in Colombia belong to unions. EMB Labor Management Plan includes freedom of association. EMB and its contractors are committed to not discriminate on the basis of race, religion, origin, ethnicity, gender identity, sexual orientation, and political parties. The ESMS prohibits harassment, forced labor and child labor. The Project does not hire people under 18 years old, and age is verified through the person’s ID and recorded in the worker’s file.  

Workers can raise grievances either directly with their manager or anonymously through suggestion boxes located at the entrance of each construction camp, or through the online portal. Grievances are collected by the respective managers every 2 weeks and submitted to EMB Human Resources for analysis and implementation of corrective actions. The existence of the suggestion boxes and portal is communicated during induction training. Distrito will require EMB and the EPC contractor to continue to implement the Workers’ Grievance Mechanism in line with PS2 (ESAP item). 

Occupational Health and Safety:  

As part of the ESMS, the Project has developed an OHS Management Plan. However, during the early phase of construction it was observed that it was not properly implemented by the EPC contractor, heightening the OHS risks at the construction site. To address this, EMB and the EPC contractor reviewed the plan to strengthen it and meet both national and international standards. The updated OHS Management Plan includes clear institutional structure, policies, methodologies, measures, instruments, and indicators to monitor the hiring of workers, health management, hazard management, and occupational risks. The system includes specific protocols for hazardous work and handling of hazardous substances as well as a code of conduct and an updated worker grievance mechanism and procedure. The goal of the plan is “zero workplace incidents” and it addresses in detail the specific risks that workers face, including detailed procedures for investigating and analyzing any accidents that may occur during operation. Currently the project records an average of 2 accidents (any type of accident) per 100 hours, implementing measures to reduce it over time, noting that before the review of the OHS Management Plan the average was 4. No fatalities or major injuries occurred on the Project so far. During MIGA site visit, it was observed proper use of PPE at all sites. Distrito will require EMB to continue to implement the OHS Management Plan in accordance with national regulation, PS2, and other applicable requirements (ESAP item). Distrito will oversight the implementation of the plan and conduct periodic labor and OHS audits, proposing corrective actions if necessary (ESAP item).  

Workers Engaged by Third Parties: 

Construction activities on the Project are performed by full-time employees of the EPC contractor, under the supervision of EMB. The EPC contractor employes small local contractor companies for activities like security, food delivery, and cleaning activities. EMB and the EPC contractor have a comprehensive Contractor Management Plan that expresses their commitment that contractors will follow and implement EMB ESMS. The Contractor Management Plan ensures contractor compliance with national laws and the EMB’s labor management and hiring policies; access to the worker grievance mechanism by contractors´ workers; and overall compliance with PS2 requirements by contractors. EMB verifies also labor compliance of each contractor (i.e., contracts, payroll, payments to social security).  

PS3: Resource Efficiency and Pollution Prevention 

Resource Efficiency:  

The Project has been conceived under parameters of energy and environmental efficiency, operating with natural ventilation, making optimal use of daylight, rainwater harvesting, and reforestation programs. The Project is expected to have significant positive impacts, improving mobility in the city and reducing emissions and noise from road traffic, and expected to contribute to the GHG emission reduction of 148 thousand tons of CO2e per year at city level. GHG emissions for the Project in operation are estimated to be 17 thousand tons of CO2e per year. Distrito will report to MIGA GHG emissions of the Project throughout the Project life (ESAP item).  

Pollution Prevention: 

Key impacts are related to noise and vibration, air quality, visual impact, soil and groundwater quality. Air emissions have been assessed using a pollutant dispersion model for the construction phase, with PM10, PM2.5, NO2, SO2, and CO emissions monitored during construction. These are mitigated with measures such as water spraying and dust curtains. During operation air emissions will be negligible. Regarding noise, a specific model was used to determine levels during construction and operations. Specific mitigation measures have been included in the design to reduce noise impacts in the operation phase. The model will be reassessed during commissioning phase to determine efficacy of the mitigation measures. During construction vibrations impacts are expected to be low. The design of the Project incorporated mitigation measures to manage vibrations during operations such as, for example, the incorporation of rolling stock supports and energy-dissipating connectors into the viaduct structure and Metro stations. Impacts on soil and groundwater are also monitored. Specific measures to minimize the identified impacts during construction and operation are included in the Environmental Monitoring Plan. Visual impact during operation are managed through the installation of green areas. Distrito will require EMB to continue implementing and updating the Environmental Monitoring Plan during construction and operations (ESAP item).  

Hazardous materials used in the Project operations are petroleum derived products such as diesel and lubricants. The risk of significant spills is minimized by the Project use of licensed handlers, and use of steel storage tanks with concrete secondary containment. Once exhausted, lubricants, used oil and oil filters are temporarily stored on site in enclosed, covered areas with secondary containment. Waste and hazardous waste are collected and transported for processing and/or disposal by a company licensed to provide these services. EMB keeps records of the manifests ensuring the chain of custody from its facilities to the point of disposal, reprocessing or recycling. In addition, EMB reports the quantity of hazardous waste generated to the environmental authority annually. EMB has comprehensive Waste Management, Wastewater Management, and Hazardous Material Management Programs in the ESMP for the construction phases. Distrito will require EMB to continue implementing the Waste, Wastewater, and Hazardous Material Management Programs during construction and to develop the ones for operations before operations start (ESAP item).  

PS4: Community Health, Safety and Security 

Community Health and Safety   

Potential community health and safety impacts associated with the Project are related to traffic and the presence of the construction site within highly populated urban areas. EMB is committed to community health through its Code of Conduct, Traffic Management Plan, Workers Management Plan, and ESMS/ESMP. Following Distrito women and gender equity policies, strategies and regulations, EMB included gender specific actions in the Project design, implementation, and operation, as: (i) zonal participation committees inclusive for women and LGBTQI community (ii) design features that would enhance inclusion and security for women in construction corridors, (iii) foster women participation in construction works (currently at 13%) and policies and mechanisms that address and prevent gender-based violence. Victims of gender-based violence who may be identified during project construction will be referred to legal/psychosocial support and assistance programs as, for example, the ones of the District Women's Secretariat. 

Security Personnel: 

The Project relies on  licensed professional security firms. The EPC contractor Security Manager and field-level security coordinators ensure good coordination and communication with third-party security personnel through daily work assignment meetings. Coordination is also established with the national police. The function of security personnel is to control access and patrol the perimeter. Reportedly, no security accidents have occurred. The hired security personnel underwent a government-approved training program before being assigned, which includes topics such as Human Rights and public safety. The Company has adopted a Code of Conduct for security personnel in line with the Voluntary Principles on Security and Human Rights and the International Code of Conduct Association for Private Security Providers (ICOCA), providing regular induction and progressive training on the subject to all the security personnel.  

PS5: Land Acquisition and Involuntary Resettlement 

The first phase of the Project required the acquisition of 1,474 properties/buildings. The acquisition process resulted in a physical and economic displacement of 3320 Project Affected People (PAPs). The PAPs number included also a total of 137 vendors occupying public space in the immediate areas of the Project, that resulted as economic displacement by the Project. Among the properties and buildings acquired there were vacant lots, private residences, multi-story commercial and residential buildings, and special commercial buildings.  

The Project developed a comprehensive Resettlement Action Plan (RAP) to carry out the resettlement process. The RAP was based on extensive baseline and consultation activities (almost 3000 people participated in the various sessions overall), and its implementation was supported by IBRD, IDB, and EIB. The RAP included also a Livelihood Restoration Program (LRP) and a Grievance Redress Mechanism (GRM). The first approved version of the RAP was finalized in 2018. EMB formed a dedicated team of more than 50 specialists for the process and, with the support of Distrito, has completed the resettlement process for the Project in 2024. As part of the RAP, nine support and engagement/communication programs were also implemented. These were targeted to address the specific needs of formal and informal businesses/vendors in public spaces in addition to the PAPs mentioned above. Regarding the informal vendors, after conducting a comprehensive baseline, EMB carried out their relocation with the support of the Instituto para la Economía Social (IPES), a division within Distrito specialized in offering alternative income generation for stakeholders involved in informal activities, focusing on training, entrepreneurship, business skills and management of largely informal commercial activities. Once the process was completed, EMB conducted a completion audit, confirming the positive outcome and conclusion of the process. Distrito will require EMB to share the completion audit report with MIGA (ESAP item).  

The RAP focused on physical resettlement and permanent loss of livelihood, and the processes associated with those two aspects are now considered positively completed. Temporary loss of income, however, was not considered. Along the Project corridor there are up to 4000 commercial activities potentially affected by a temporary loss of livelihood due to temporary closures, obstructed access, or decrease in clients’ traffic during the construction activities. To mitigate this impact, Distrito and EMB are defining, with the support of IBRD and IDB, a specific Strategy for the management of  temporary impacts to commercial activities, inclusive of resources allocation, clear actions, and responsibilities, that would bring the Project into alignment with the objectives of PS5. Distrito will share with MIGA for review and approval the Strategy (ESAP item). The Strategy will include the mitigation measures, resources allocation, clear actions and responsibilities to close the gaps with MIGA’s PSs. Distrito will also report periodically on the implementation of the Strategy, and on the management of any grievances that should arise during the process (ESAP item). 

For the second phase of the Project, it will be necessary to acquire at least 134 other properties. The Project has already consulted with the affected stakeholders and is updating the RAP, considering also the lessons learned from the first phase. Distrito will require EMB to share the updated RAP with MIGA for review (ESAP item). Distrito will monitor the resettlement process conducted by EMB and will require EMB to also conduct a resettlement completion audit at the end of the process to be then shared with MIGA (ESAP item).  

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resource: 

The Project runs through existing road corridors in urbanized/modified habitats. The depot (32 hectare) borders a municipal Environmental Management and Preservation Zone. The Project conducted an extensive biodiversity survey as part of the ESIA and is implementing comprehensive management and monitoring measures for biodiversity. Main impacts addressed by the Plan relate to tree cutting, modification of urban green areas and impacts on urban fauna. Distrito will follow up periodically on the implementation of the management and monitoring measures for biodiversity and summarize progress in the Annual Monitoring Report. The construction of the Project requires the cut of around 1750 trees. EMB is required to plant and maintain a minimum of around 5000 trees along the Project as compensation. Details on the type of trees to be planted were included in the Reforestation Plan consulted with the Bogotá Botanical Garden to avoid the use of invasive species. EMB will not use pesticides in its operations. 

PS8: Cultural Heritage 

Archaeological surveys were carried out as part of the ESIA, classifying the right of way based on the findings. As part of the ESMP, an Archaeological Management Plan (AMP) and a Chance Find Procedure were prepared and approved by the relevant authorities at local and national level, and are in line with international standards, with the focus of preserving sectors and buildings of the city that have cultural value. The Project required also the relocation of the national monument “Bolivar Equestre”. A specific restoration and relocation plan was developed and consulted with stakeholders and then approved by the relevant authorities. The “Bolivar Equestre” was moved to its new location and the official audit confirmed that the move occurred with no issues.