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Kékéli Efficient Power S.A

$55.8 million
Environmental and Social Review Summary

Environmental and Social Review Summary

Kékéli Efficient Power

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.

MIGA has been requested to provide guarantees covering Equity/Quasi-Equity/Shareholder loans (EQS) investments from Eranove S.A (Eranove or the Sponsor) of France into Kékéli Efficient Power S.A, or KEP (the Project Enterprise or the PE), the operator of a tri-fuel thermal power plant located in the Port industrial zone of Lomé, Togo. Further information on the proposed MIGA guarantee is available in the Summary of Proposed Guarantee.

The Project comprises the operation and maintenance of a 65-megawatt (MW) combined cycle tri-fuel thermal plant and associated underground fuel supply pipeline system. The plant will run on natural gas as the main fuel source, through a connection to the West Africa Gas Pipeline (WAGP) operated by the West African Gas Pipeline Company Limited (WAPCo). Natural gas is supplied via a 30-meter (m) pipeline connecting the thermal power plant to a Project-specific compression station at the WAGP. Liquid propane 95 and distillate diesel oil (DDO) are expected to be used as secondary and backup fuels, respectively. A 900m underground pipe was built to connect the plant to the nearby ZENER (previously SODIGAZ) company, and a 300 m3 storage tank was built on site for DDO back-up supply in case of need (for a contractual maximum of 4 days/year). The power plant is connected to an existing 161 kilovolt (kV) substation in Lomé Port via a 1.2-kilometre (km) underground transmission line. The sub-station is operated by Communauté Electrique du Benin (CEB) and the transmission line is operated and maintained by Compagnie Energie Electrique Du Togo (CEET), the national utility and power off-taker. The transmission line is considered as an associated facility to the Project. All fuels are provided to the project by CEET.

The power plant is situated on 3 hectares (ha) of land in the heart of the Port industrial zone, about 10km northeast of Lomé’s city center. The site is owned by the state of Togo and registered at the name of the Ministry of Economy and Finance. The area of indirect influence includes the districts neighboring the port zone (Baguida-Kangni-Kopé), National Road 2 between the Lomé Port Authority crossroads and the Baguida monument crossroads that is often used by trucks coming from or going to the port zone and the effluent discharge point at the coast.

The Project was built in two stages: (i) the installation of a gas turbine providing an initial installed capacity of 47.5 MW (open cycle or Stage1) and (ii) the construction of a waste heat-powered steam turbine (17.5 MW) bringing the total installed capacity of the plant to 65MW (combined cycle or Stage 2). Construction works started in January 2020. Due to construction delays, because of amongst others the Covid-19 pandemic, the Project was fully commissioned and came into full combined cycle operation on 1 November 2022.

The Project is categorized as Category B according to MIGA’s Policy on Environmental and Social Sustainability (2013) because the potential E&S risks associated with the Project are expected to be limited in number, site-specific, largely reversible, and readily addressed through mitigation measures. These impacts can be avoided, minimized or mitigated by adhering to applicable PSs and World Bank Group (WBG) Environmental Health and Safety (EHS) guidelines.

Potential E&S risks and impacts associated with the Project relate to air emissions (including greenhouse gas emissions), noise, water and wastewater management, potential soil and groundwater contamination from handling, storage and disposal of hazardous materials, employee and community health and safety, emergency preparedness and response, stakeholder engagement, and cumulative impacts due to the presence of other power facilities in the Project area.

While all Performance Standards are applicable to this investment, based on current information, the investment will have impacts that must be managed in a manner consistent with the following Performance Standards (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 and Sustainable Management of Living Natural Resources
  • PS8: Cultural Heritage

There is no indication or evidence of Indigenous People residing in or having cultural ties to the Project area, thus PS7: Indigenous Peoples is not triggered.

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 Thermal Power Plants (2008) 
  • EHS Guidelines for Electric Power Transmission and Distribution (2007)

The following documents were reviewed by MIGA:

  • Etude d’impact environnemental et social du projet de construction de la Centrale Thermique tri-fuel de 65 MW à Lomé Port, Rapport Final (October 2019)
  • Environmental and Social Impact Assessment (ESIA) for the Combined Cycle 65-megawatt (MW) power plant at the Lomé Port, JAT Consulting SARL (February 2019)
  • Noise Impact and Modeling Study, INSUCO, October 2019.
  • Order 076 / MEDDPN / CAB / ANGE / DETE / CCE of Environmental Compliance signed by the Minister of the Environment on October 23, 2019
  • Due Diligence Environnementale et Sociale Phase 1 : Revue Documentaire Projet de Centrale Thermique de Kékéli, Togo, ERM 0500521, March 27, 2019
  • Due diligence, Environmental and Social - Phase 3, Kékéli Thermal Power Plant Project -Togo, ERM 0500521, December 17, 2019
  • TSK HSE Plan
  • KEP E&S Policy, March 2021
  • KEP operational ESMS, plans and procedures
  • LRP Final Report, April 2022
  • Ambient Air Quality Monitoring Reports, 2020 and 2021
  • Ambient noise monitoring report 2021
  • Continuous Emissions Monitoring System data from November 2022-February 2023
  • Emissions test reports April-June 2022
  • Third party E&S audit and ESAP tracker reports, April 2021, July 2022, September 2022


MIGA’s due diligence included a desktop review of the above documentation, discussions with the Project and Sponsor teams, and two E&S due diligence visits, in December 2019 and in July 2022. MIGA’s E&S due diligence visits included meetings with key Project and E&S staff, regulatory authorities, the local communities, as well as an inspection of the Project site. In addition, MIGA has reviewed the E&S due diligence and monitoring reports prepared by ERM, the independent environmental and social consulting (IESC) firm engaged by the Project lender. The IESC most recently undertook a monitoring site visit in September 2022. The E&S monitoring report was shared with MIGA.

MIGA’s due diligence review considered the environmental and social (E&S) management planning process and documentation for the Project and identified gaps 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 operated in accordance with the Performance Standards. Key E&S issues associated with the Project business activities are summarized in the paragraphs that follow.

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

Environmental and Social Assessment and Management System:

KEP has developed an Environmental and Social Management System (ESMS) in line with PS 1, which incorporates the necessary plans and procedures to manage and oversee compliance with all applicable national laws and regulations, the ESIA conditions, and MIGA’s E&S requirements. The ESMS includes a procedure for periodic monitoring of E&S performance and regular management review of the system effectiveness. The ESMS was developed for construction and has been updated to cover the operating plant.


As part of its ESMS, KEP has developed an E&S policy which lays out its E&S objectives and guides efforts to achieve satisfactory E&S performance. The E&S policy includes KEP’s commitment to implement an integrated management system covering quality, environment and safety, conforming to ISO 9000:2015, ISO 14001:2015 and ISO 45001:2018. The system is expected to be certified to these standards by December 2023.

Identification of Risks and Impacts:

In compliance with Togolese regulations, an E&S Impact Assessment (ESIA) was undertaken to assess the potential risks and impacts of the Project and propose mitigation measures to avoid, minimize and/or control the identified risks during both construction and operations. The ESIA was approved by the National Environmental Management Agency (ANGE) in October 2019. After a review by the Lenders’ IESC and prior to starting construction, the ESIA report was updated and then finalized in January 2020. Cumulative impacts were considered in the ESIA. During the operations phase, potential cumulative impacts will mainly relate to noise and air emissions (see PS3 section) due to the current operation and potential future construction of other energy projects in the Project area, including commissioning of another CCGT on the site. No specific E&S permit is required for operations, but the Project has to comply with the E&S conditions covered in the Environmental Management Plan which was approved by ANGE.

Localized climate projections indicate that under unabated climate change, the Project region is expected to observe an increase in the frequency and intensity of extreme weather events, such as heatwaves and flooding from heavy rainfall. The Project is located approximately 300m from a coastline that is highly vulnerable to erosion, which is expected to intensify as storm surge dynamics change and sea-levels rise.  Multiple programs are currently underway to reduce coastal erosion rates in Togo, including the World Bank’s West African Coastal Areas Management (WACA) Program.  MIGA will require the PE to conduct a Climate Risk and Vulnerability Assessment to identify and report on potential climate risks and resilience measures (ESAP item).

Management Programs:

Under the KEP ESMS, the EPC contractor prepared and implemented a set of Project-specific E&S management plans and standard operating procedures for construction activities. These have been updated to cover operations and are currently under external review, These cover the key E&S risks and impacts during the operations phase of the Project, including waste management, air quality, noise, water and wastewater management, hazardous materials management, emergency response, occupational health & safety, and traffic management. The updated and finalized plans and procedures will be provided to MIGA (ESAP item).

Organizational Capacity and Competency: 

KEP has a Quality, Safety and Environmental (QSE) Manager in place together with a support team with three specialists on site to implement the PE’s ESMS and manage the Project in compliance with national and MIGA’s requirements. In addition, a consultant has supported KEP to implement the Livelihoods Restoration Plan (LRP).

Emergency Preparedness and Response:

Storage, handling and use of hazardous material such as natural gas and DDO present potential hazards in relation to accidental spills, fire and explosion. A fire protection system in line with good international CCGT design standards is in place, and all personnel have received training on fire protection and firefighting. An emergency response plan (ERP) was developed, and drills are conducted on a regular basis. The ERP will be updated to include communication channels with communities, neighboring facilities and authorities, as well as a requirement to be updated yearly to take into account any changes to the Project, the industrial zone, or surrounding areas (ESAP item).

Monitoring and Review:

KEP has procedures, tools, and indicators in place to monitor the Project’s E&S performance. The plant is fitted with a Continuous Emissions Monitoring System (CEMS) to monitor stack emissions. Monitoring is conducted for ambient air quality, noise, solid and liquid wastes, energy and water consumption, and accident and safety data. KEP also submits quarterly monitoring reports to ANGE. The PE will prepare and submit to MIGA Annual environmental and social monitoring reports to demonstrate ongoing compliance with Togolese laws and MIGA’s requirements.

Stakeholder Engagement:

As part of the ESIA process, a series of meetings was organized between March-September 2019 to inform the public of the proposed Project. Consultation activities were undertaken with various stakeholders, including the local communities of Gbétsogbé and Noudokopé and people engaged in informal commercial activities affected by the development of the Project. Concerns raised during this engagement process included compensation for Project Affected Persons (PAPs), potential negative impacts on the neighbouring villagers, and opportunities for local employment and community support. Since starting construction, KEP has implemented a Stakeholder Engagement Plan (SEP) and during operations has maintained regular communication with the communities living around the Project site and the PAPs.

External Communication and Grievance Mechanisms: 

The SEP includes a community grievance mechanism, with effectiveness indicators in place. Two local complaints management committees, one for each village neighboring the Project site, are active. Some grievances related to compensation have been reported, all have been closed to date. The IESC’s monitoring reports indicate that there is awareness among the communities on the grievance mechanism, and that KEP has maintained good relations with the communities through its active engagement and support.

Ongoing Reporting to Affected Communities:

Reporting to affected communities is conducted as part of the implementation of the SEP and the RAP.


PS2:  Labor and Working Conditions

As of February 2023, KEP employs 47 staff, among which women represent around 11% of the workforce. The Project employees commute to work from their homes. No worker accommodation is provided onsite.

Working Conditions and Management of Worker Relationship:

KEP has developed and implemented a Human Resources (HR) policy in line with the Togo labor standards and PS2 requirements. The policy addresses non-discrimination and equal opportunity, child labor, forced labor, terms of employment, freedom of association, worker grievances, performance management, disciplinary procedures and termination of contract. The HR policy also includes provisions regarding zero tolerance for sexual harassment and gender-based discrimination. All Project workers are in receipt of a contract of employment which includes references to the relevant working conditions and terms of employment. KEP’s workforce is represented by four elected representatives who meet with the PE’s management on a quarterly basis. A worker grievance mechanism (GRM) accessible to all Project employees and contractor workers is in place. The GRM allows employees to raise anonymous complaints.

Protecting the Work Force:

KEP’s commitments in relation to prohibiting child and forced labor are outlined in the HR Policy. The minimum employment age for Project employees and contractors is 18 years.

Occupational Health and Safety:

As part of the ESMS for the construction phase, the EPC contractor developed and implemented a set of occupational health and safety (OHS) plans and standard operating procedures including procedures for provision of personal protective equipment (PPE), training, safe working procedures and emergency response, medical care, first aid, health monitoring, vaccinations, pest management and measures for prevention of disease spread, HIV prevention, accident/incident monitoring, investigation, reporting and corrective action, and periodic audits and corrective actions where applicable. KEP has updated these OHS procedures that were developed by the EPC and the IESC’s review indicates that appropriate measures are being implemented. Measures include routine fire safety drills with extensive training provided to all onsite personnel. KEP has also established a COVID-19 Emergency Response Plan based on the World Health Organization (WHO) recommendations that includes training for staff, medical screening, restrictions and guidelines regarding physical distancing, use of Personal Protective Equipment, and monitoring of cases.

Workers Engaged by Third Parties:

KEP hires third-party contractors to conduct routine maintenance activities. The PE requires its contractors to develop and implement workplace rules, processes, and procedures in line with KEP HR, OHS and environmental policies and procedures. A comprehensive set of E&S provisions and references to the IFC PSs are included in the contracts that KEP signs with contractors. The PE has implemented a procedure to monitor the contractors’ environmental, health and safety performance and compliance with contractual requirements.

Supply Chain:

The PE implements Eranove’s purchasing policy and has a supplier management procedure in place. No high risk of child or forced labor in the Project’s primary supply chain has been identified.

PS3:  Resource Efficiency and Pollution Prevention

Resource Efficiency:

The plant is a combined cycle thermal power plant (CCGT) which comprises a gas and a steam turbine. Waste heat from the gas turbine is recovered and then routed to a steam turbine connected to a generator which produces additional power, thereby increasing energy conversion efficiency and reducing greenhouse gas (GHG) emissions when compared to an open cycle plant. Natural gas is supplied via a 100m underground pipeline connecting the site to the West Africa Gas Pipeline (WAGP). Liquid propane secondary fuel could be supplied by SODIGAZ gas distribution company via a 400m underground pipeline which has yet to be commissioned. A 300 m3 storage tank was built on site for distillate diesel oil (DDO) back-up supply in case of need. The Project’s annual GHG emissions during operations are estimated at 258,715 tCO2e/year, at an estimated intensity of approximately 488 grams of carbon dioxide equivalents per kilowatt-hour produced. KEP will be required to monitor and report GHG emissions to MIGA on an annual basis.

Two 380-meter-deep boreholes were dug on site to supply water to the Project during operations, and a water abstraction permit was obtained in August 2021.  The plant design, with a closed loop cooling system, will allow to keep the Project’s water consumption to an average of 73m3 of water per day. A water management plan was prepared for construction and has been updated for operations as part of the overall ESMS update (ESAP item). The water management plan includes the necessary measures to mitigate any significant adverse impacts of the Project on the availability of groundwater for other water users.

Pollution Prevention:

Air quality baseline measurements were undertaken at five sensitive receivers around the site during the ESIA preparation, and during construction before open cycle operations started. The levels of PM10, SO2, NO2, and other parameters were found to be within WHO guidelines limits. Potential incremental impacts on air quality from plant operation were evaluated through the use of a predictive atmospheric dispersion model. Since commissioning, actual emissions are monitored through the Continuous Emissions Monitoring System (CEMS) that has been fitted to the exhaust stack, and KEP will conduct ambient air quality monitoring on a quarterly basis during operations.  Monthly emissions data provided from November 2022 to February 2023 indicate compliance with the requirements of both MIGA and the République Togolaise.

Modelling undertaken as part of the ESIA process concluded that noise impacts at the identified sensitive receptors during operations are expected to remain compliant with WBG EHS guidelines. Noise reduction measures were incorporated into the Project design. Acoustic screens have been installed at the plant and as a result of baseline noise measurement undertaken during the ESIA process and construction, the exhaust stack height was raised, and noise barriers were erected at the site boundary. During plant commissioning in open cycle, third-party noise monitoring was conducted around the site at sensitive receptor locations. Test results indicate that noise levels measured during the day and the nighttime were generally at background levels and so no further mitigation is currently foreseen. Ambient noise monitoring at the identified sensitive receivers will be conducted on a quarterly basis during operations to confirm any impacts on receptors and assess the need for any additional mitigation measures to comply with the WBG EHS guidelines. Results will be reported in the Annual E&S monitoring report to be prepared for MIGA.

Process effluent, sanitary wastewater and run-off are subject to onsite treatment prior to discharge to the municipal sewerage network via two discharge points. Process effluent treatment involves oil/water separation and pH neutralization. Effluent quality monitoring was conducted by a third-party in May 2022 during commissioning of the combined cycle plant. Test results indicate that effluent quality parameters meet the EHS Guidelines standards. KEP will continue monitoring effluent quality during operations.

During operations, the type and volume of hazardous materials stored and handled on site will be limited. These include acids, caustic soda, fuel, solvents, lubricating oils, transformer oil, natural gas and DDO.  KEP maintains a tracking register for chemicals and other hazardous materials. Safety Data Sheets (MSDS) are displayed on doors and on the material storage containers. As part of induction and ongoing training, site personnel are trained on safe working practices in the handling and storage of these materials. The 300m3 DDO tank is bunded to fully contain a potential 100 percent fail. A gas leak detection system is in place and inspected on a regular basis.

The Project will generate both non-hazardous and hazardous wastes during operations. Hazardous waste includes used generator and turbine lube oil, spent gas turbine air filter cartridges, and spent gas turbine lube-oil filter cartridges. Used oil and oily materials will be collected on site and then removed in drums for disposal by a licensed contractor. A waste management plan was developed during construction and has been updated for operations to include storage, organizational responsibilities and management, waste segregation, transportation, handling and disposal. Non-hazardous waste is removed by a licensed contractor to a landfill site that is managed by the municipality.

PS4:  Community Health, Safety and Security

Community Health and Safety:

Potential community health and safety issues associated with the operation of the Project include unauthorized access, road safety, and emergency situations related to the delivery, use and storage of liquid fuel oil and natural gas. The site is fenced, and security personnel are in place to prevent unauthorized access to the site. Road traffic risks are minimized through driver training, enforcement of speed limits and regular maintenance of Project vehicles.

The Project ERP includes measures to prevent impact on community health and safety, and KEP maintains routine contact with local communities to provide them with relevant information, including security measures. Emergency control including firefighting equipment has been placed at suitable positions on site. As mentioned earlier, the ERP will be updated to include mechanisms to ensure communication with local communities and neighboring facilities. KEP will conduct regular drills and evacuation exercises for the relevant emergency scenarios which may impact local communities (ESAP item).

Water for the Project is abstracted through two boreholes that are 380m deep. Permitted maximum extraction is 95m3/day against a requirement of 73m3/day on average. Water abstraction is metered and is required to be reported quarterly to the Water Resources Department. Given the depth of the boreholes, the Project is not expected to have adverse impacts on the availability of water resources for community use.

Security Personnel:

The Project site is fenced and protected by unarmed security guards. During the night, additional security is provided by soldiers who patrol in the surroundings of the site to prevent any potential terrorist action against the Project infrastructure and other industries in the area. KEP will revise the security management plan developed by the EPC contractor to include a policy on the use of private security forces, a code of conduct for security guards, and training requirements on the use of force (ESAP item).

PS5:  Land Acquisition and Involuntary Resettlement


The development of the Project involved land acquisition of approximately 3 hectares for the power plant site and of the Right of Way (RoW) along 1.2 km for the underground transmission line and the 400m underground propane supply pipeline. Land use on the Project site and along the RoW at the time of the ESIA included an active dispensary building, a nurse's housing building, sheds with informal occupants, unfinished buildings, some market gardening activities and wells used for irrigation purposes. The construction of the power plant, underground transmission line and future propane supply pipeline required some physical displacement and caused the permanent loss of land used for agricultural activities, and temporary loss of income due to the relocation of economic activities. The construction of the gas supply pipeline did not require any displacement. A Resettlement Action Plan (RAP) and a Livelihood Restoration Plan (LRP) for the Project were prepared in early 2020 in accordance with PS5 requirements, including compensation for loss of assets at full replacement value. The RAP has been fully implemented, with regular monitoring undertaken by a consultant. A grievance mechanism was developed as part of the RAP. One grievance was received in 2020 and has been addressed. No outstanding matters have been reported to date.


The Project development affected 30 persons, including four households that were physically displaced.   Of the 20 economically displaced people, six were eligible for livelihood restoration support. These included two owners of craft workshops (sewing and hairdressing activities) and individuals who conducted market gardening activities. All PAPs have been compensated, and the final independent LRP monitoring report dated April 2022 confirms that all the planned livelihood restoration activities have been completed, and notes that these have had a positive impact on the affected persons.  KEP will continue engaging with and monitoring the status of the PAPs as part of ongoing community engagement and implementation of the community grievance mechanism.

Private Sector Responsibilities under Government-Managed Resettlement:

The GoT provided land free and clear to Eranove prior to the start of construction and land acquisition took place prior to MIGA’s involvement with the Project. During E&S due diligence, MIGA reviewed the land acquisition process and the Project’s proposed compensation amounts to assess compliance with PS5. KEP collaborated with the government agencies to achieve outcomes that are consistent with PS5. The Project should continue efforts to obtain proof of remittance of funds to the 30 people eligible for compensation as identified in the RAP, should monitor and evaluate the implementation of involuntary resettlement actions through the monitoring indicators defined in the RAP for each type of PAP (ESAP item)

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource

Biodiversity surveys were undertaken at the Project site as part of the ESIA. A biodiversity desktop assessment has also been conducted during MIGA’s due diligence, including a review of scientific literature, and species data from a variety of sources. The Project is located in the industrial zone of Lomé, i.e., in Modified Habitat.  Although the Project site does not support Critical Habitat, it is located in the Zones Humides du Littoral du Togo Ramsar Site, a wetland of international importance which encompasses a very large area of 591,000 ha including the entire coastline of Togo and part of the Lomé urban area. The Ramsar Site is characterized by mangroves, rivers, lakes, lagoons, marshes, ponds, and a long sandy beach. Although the Ramsar Site is not protected, and much of the area is degraded, some of these different ecosystems still support important biodiversity values and ecosystem services.

As the Project is located within the industrial zone, areas of Natural and possibly Critical Habitat within the wider Ramsar site are unlikely to be affected. Water for the Project is supplied from a 380m-deep aquifer that is not hydrologically connected to the nearby surface wetland areas. The closest area to the Project site supporting high biodiversity values is the beach and the shallow waters close to the coast, located several hundred metres away from the site. Several species of marine turtle frequent the Togolese coasts either to lay eggs or feed. Two species are known to nest along these beaches and are under significant threat from a range of anthropogenic pressures. These include the Endangered (EN) Green turtle Chelonia mydas and the Vulnerable (VU) Olive ridley turtle Lepidochelys olivacea. There have also been occasional sightings of the Critically Endangered (CR) Atlantic Humpback Dolphin Sousa teuszii off the Togo coast, although not specifically near the Project site. It is unlikely that the number of turtles and dolphins in the area would meet the threshold to trigger Critical Habitat, and operation of the Project is not expected to have measurable adverse impacts on these biodiversity values, because effluent is treated prior to release in the public sewerage system. However, the client will engage a qualified independent consultant and/or organization to conduct an initial scoping study to assess any potential direct, indirect, or cumulative effects of effluent discharge on these species and, if relevant, present appropriate mitigations necessary to comply with requirements for projects located in internationally recognized areas and potentially impacting natural habitat (ESAP item).  

PS8:  Cultural Heritage

A chance finds procedure is in place, but no artifacts were reported during construction. It was identified during the ESIA consultations that a fetish belonging to the Gbétsogbé community was present on the Project site. The fetish is considered to be non-critical and replicable cultural heritage, as the community indicated that it could be displaced. A formal removal ceremony was conducted prior to construction.

A Broad Community Support determination is not required for this Project. 

The documentation listed below is available electronically as PDF attachments to this ESRS at

For more information on the Project, please contact:

  • Contact Name: TOURE TIA Mansour

Address: 01 BP 2304 Lomé, Villa 58 Cité BOAD, Baguida (TOGO)
Tel: +228 98 21 52 15



MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:


Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400