Konexa Embedded Distribution Project

MIGA has been asked to provide a guarantee for a period of up to twenty years to cover equity and shareholder loan investments provided by ECOF Kaduna Ltd of Mauritius and Climate Fund Managers (CFM) for the development of the Konexa Integrated Power Distribution Project in Nigeria.

The Project consists of the development, construction and operation of energy generation and distribution infrastructure in the Kaduna State, involving three sub-projects with separate activities: The Distribution Project, the Off-Grid Project, and the Solar Project (together “the Project”). MIGA is not currently guaranteeing the solar project, updates to MIGA cover will be reflected in the Project Brief, per MIGA Access to Information Policy’. The Project is being developed by the Energy Company of the Future (ECOF), trading as Konexa, a company incorporated in Jersey, with the objective of investing in integrated electricity distribution projects and renewable power projects across Sub-Saharan Africa. Project financers may include Climate Fund Managers (CFM), Africa Finance Corporation, Microsoft, and the Rockefeller Foundation. InfraCredit will potentially provide a Naira-based debt refinancing facility after at least 6 months of operations. The Project will be implemented through two Nigerian entities.  ECOF Kaduna Ltd (Nigeria) will be responsible to implement the Distribution Project and the Off-Grid Project, while Konexa Solar 1 Ltd will implement the Solar Project.

1. Distribution Project

The Distribution Project includes network reinforcement and extension such as the building of new 11kV and 33kV distribution lines, safety enhancements, rollout of smart metering infrastructure and IT systems, as well as energy procurement, and distribution services to customers in the franchise area.

2. Off-grid Project

The Off-grid Project includes the construction, operation, and maintenance of eight Mini Grids and leasing of approximately 285 Solar Home Systems (SHS). The Mini Grids consist of a solar plant with 4.5 kW capacity, a battery for energy storage, and related equipment (control system, inverters, etc). Each Mini Grid will also include a diesel generator, for emergency back-up power. The equipment will be installed in a fenced area, covering approximately 2,500 m2. The SHS will be provided by external suppliers in the Project area and consist of a solar panel (60 – 120 W), a battery, lamps and device to connect a USB charger.

3. Solar Project

The Solar Project includes the construction, operation, and maintenance of a 2.5 MW solar photovoltaic plant, located on a 10-hectare plot in the Rigachikun community. The power will be evacuated through a 1-4 km 33 kV transmission line, to be built as part of the Project, to the new Konexa 3 injection substation.   

The Project will be located in two distinct areas in the vicinity of Kaduna City, in the Igabi Kaduna South, and Chikun Local Government Areas, Kaduna State, in Northern Nigeria., The site for the Solar Project will be leased from the Kaduna state government.  A small section of the site for the Solar Project was previously being used for poultry farming.

Construction activities for the Solar Project will include clearing of the site, the transport of equipment, the installation of photovoltaic solar modules and supporting inverters and transformers, electric meters, technical rooms, access roads, fences and a site security and surveillance system. The Project also includes activities related to the construction of distribution lines, injection substations, switchyards, and ring main units as part of the Distribution Project. An EPC Contractor, as well as a number of sub-contractors will be engaged for the construction activities.

During the operational phase, activities will be limited to daily monitoring, cleaning of modules as needed, maintenance of vegetation under and between modules, and maintenance of electrical components and the boundary fence, as well as maintenance and operation of the distribution network infrastructure.

The Project is categorized as Category B according to MIGA’s Policy on Environmental and Social Sustainability (2013) because the potential adverse impacts are site-specific, largely reversible, and readily addressed through mitigation measures. Key potential environmental and social (E&S) risks and impacts related to the Project include implementation of E&S management systems that will include labor and working conditions, waste management, stakeholder engagement, worker & community health and safety, security management, emergency preparedness and response, and land acquisition.

While all Performance Standards (PS) are applicable to this investment, based on our current information, the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

• 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

There are no significant impacts related to biodiversity or Indigenous Peoples associated with the Project, thus PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources and PS7 Indigenous Peoples do not apply.

No sites of cultural / historical value were identified during the ESIA process. PS 8 Cultural Heritage does therefore not apply; however, a Chance Find Procedure will be developed and implemented under PS1.

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 Electricity Transmission and Distribution (2007)

The following documents were reviewed by MIGA:

• Environmental and Social Impact Assessment, Konexa Solar Plant and Grid Upgrades. EnvironQuest. September 2021.
• Construction Environmental and Social Management Plan (C-ESMP), Konexa PV and Grid Network Upgrades. November 2021.
• Environmental and Social Management Plan, Konexa Mini Grid Project. April 2020.
• Konexa Community Development Programme, November 2021.
• Konexa Community Engagement Strategy, September 2021.
• Stakeholder Engagement Report, Translantic Development Limited. June 2019.
• Security Risk Management Plan, Konexa. June 2021.
• Hydrological Study for the 2.5MW Solar Plant Site. Sitech Engineering Limited. November 2021.

In addition to reviewing the above documents, MIGA conducted virtual due diligence from February – December 2021, including calls with key Konexa representatives. Due to COVID-19 travel restrictions, MIGA was not able to undertake a due diligence site visit, but took part in findings from site visits conducted by CFM (April, 2021) and InfraCredit (November, 2021).  

MIGA’s due diligence review considered the environmental and social 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 Performance Standards.

Key environmental and social (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:

Konexa will establish an Environmental and Social Management System (ESMS) for the Project (ESAP item), based on the findings of the ESIA, Konexa’s policies, applicable local regulation, and the requirements of the PSs. The ESMS will include policies and provisions for risk identification, organization and responsibilities, and disclosure of information and reporting. As further detailed in the section below, the ESMS will also include a set of sub-management plans for inter alia occupational health & safety, emergency response, waste and recycling, water, biodiversity, stakeholder engagement, grievance management, and monitoring.

The ESMS will be revised and amended for the operations phase, prior to commencement of operations, as per the ESAP.

Policy:

The Project has a preliminary set of corporate Health, Safety and Environment (HSE) Policies in place, setting out the guiding principles and standards for HSE requirements, applicable to the Project and related infrastructure.  The policy statement affirms the Company’s commitment to develop the Project in a safe and socially responsible manner, and is based on a set of standards including risk analysis, work site supervision, incident analysis, training, and management.  

Identification of Risks and Impacts:

An Environmental and Social Impact Assessment study (ESIA) has been prepared for the Project, in accordance with local regulation and the requirements of the PSs and covering the activities within the Project. The ESIA has been finalized and was conducted by EnvironQuest, a local environmental consultancy, and Continuum Associates, a global consulting firm. The ESIA adequately identifies the potential risks and impacts of the proposed Project. The ESIA has been submitted to the Federal Ministry of the Environment for review and approval, and the final version will consider any comments resulting from the authorities’ review (ESAP item). The ESIA does not cover some sections of the 33 kV transmission lines proposed as part of the Distribution Project, and an amendment to the ESIA will therefore be developed to cover any transmission lines which were not considered as part of the original ESIA, and the relevant government approvals will also be obtained prior to any construction activities for those sections (ESAP item). A separate ESIA was conducted for the Mini Grids in 2020, which was submitted to the local authorities and approved on July 10th, 2020.

An assessment of security risks related to the Project was conducted by Spearfish Security – a global security risk consulting firm. The assessment concluded that security risks are fluid, but manageable, and regular re-assessment is required.  A Security Risk Management Plan (SRMP) has been developed and it includes security-related standard operating procedures and emergency response plans.

Potential cumulative impacts were considered in the ESIA, which concluded that no material cumulative impacts are expected.

A climate risk screening was performed for the Project, flooding due to extreme rainfall events could present a challenge during the construction and operational phases.  A hydrological study to evaluate flood risks was completed by Sitech Engineering Limited in November 2021. This study, along with the ESIA, recommended that erosion and flood control measures be incorporated to minimize the risk of flood-related impacts. These measures include modifications to grading and ground elevations, construction of infiltration trenches and line drains, re-vegetation of select areas post construction, and implementation of sediment traps along with other minor drainage improvements.  The Project will undertake the necessary additional studies to define and implement appropriate erosion and flood control measures to reduce flood risks to the Project.

Management Programs:

The ESIA includes a framework for an Environmental and Social Management Plan (ESMP), which provide principles for preventing and mitigating environmental and social impacts, in both construction and operation phases.

Building on the findings of the ESIA, applicable regulation and the requirements of the PSs, an ESMP for the construction phase (C-ESMP) has been developed for the Project, applicable to the Project , all contractors, subcontractors, suppliers and service providers conducting activities at the Project site. The C-ESMP sets out provisions for roles and responsibilities, training and competencies, stakeholder engagement, and HSSE management and monitoring measures.  

The EPC Contractor, and subcontractors will be required to adopt and implement the C-ESMP and associated management plans in line with the ESMS. As set out by the C-ESMP, all contractors shall also develop a Project-specific HSSE management system appropriate to the nature and scale of their respective activities.

Security Management Procedures have been established for the Project, as further described under Performance Standard 4.

An ESMP for the operations phase will be developed prior to commencement of operations, as per the ESAP.

Organizational Capacity and Competency:

The Konexa Health, Safety, Environment and Community (HSEC) Manager has the overall responsibility to implement the ESMS and related coordination with authorities, contractors and other stakeholders. Konexa has also appointed a Health & Safety Site Officer for the Project, and CFM will act as an E&S advisor throughout the Project construction and operations phases, including support around implementation of the ESMS, monitoring of HSE aspects in construction, stakeholder engagement, the grievance mechanism, and provide capacity building.

The EPC Contractor will appoint an HSE Officer responsible for overseeing the implementation of the C-ESMP, monitoring and inspections, training, and reporting to the Project and relevant authorities. The HSE Officers shall be suitably qualified and have prior experience from overseeing HSE management in construction projects. In addition, each sub-contractor will be required to appoint an HSE Coordinator. As per the ESAP, the Project will notify MIGA of the appointment EPC’s HSE Officer prior to the start of construction.

Konexa also has a Community Engagement Manager in place, responsible for stakeholder engagement. A team of Community Liaison Officers (CLOs) will be maintained at various locations across the Project area, supporting the Community Engagement Manager in maintaining relationships with the communities.

Emergency Preparedness and Response:

An Emergency Response Plan (ERP) will be a part of the ESMS including inter alia procedures for responding to fire and explosion, spills, loss of containments of dangerous substances, traffic incidents, safety and security incidents, and malicious acts. As part of the C-ESMP, the Project will require EPC and other contractors to implement the ERP, to address relevant risks including fire and other external emergencies during construction and operations phases. The procedures and responsibilities for emergency response actions and communication will be clearly defined and available on-site. 

The plan will include provisions for organization of emergency areas, roles and responsibilities, communication systems, resources, and training and updating. It will also include requirements for periodic tests and exercises to ensure that the necessary response measures are understood by the designated teams, staff and contractors. The ERP will also consider opportunities for emergency response coordination with a military base located adjacent the Project site.

The SRMP also includes response procedures for security related incidents and emergencies.

Monitoring and Review:

As part of the ESMS, a monitoring and reporting system related to construction and operations will be established and implemented. Monitoring frequencies, methodology and indicators will be reflective of the risks and impacts identified in the ESIA as well as local regulation. The ESMS will also include auditing procedures for contractor performance. The EPC Contractor will report regularly on the implementation of the C-ESMP to the Project, which will report to authorities as required, disclose monitoring results and provide feedback to affected communities on at least an annual basis in relation to any impacts affecting them and associated mitigation measures. Annual monitoring reports will also be developed and submitted to MIGA.

Stakeholder Engagement

In 2019, during the ESIA processes, several community consultation activities were completed with various groups of participants, including landowners, women, youth and local authorities. Stakeholder meetings were held to discuss the Project and to provide an opportunity for the affected communities to raise any concerns. Issues raised during the meetings primarily included access to and quality of electricity supply, employment opportunities, support for road maintenance and other community support measures.

Konexa has also carried out several rounds of stakeholder engagement activities as part of Project preparation and pilot phase. A third-party provider was engaged in 2019 to conduct a stakeholder mapping exercise, community meetings, key informant interviews, and focus groups discussions, as well as recommendations for a communication strategy and implementation of a grievance redressal mechanism.

A Stakeholder Engagement Plan (SEP) will be developed as part of the ESMS (as per the ESAP) for construction and operation phases, building on the engagement undertaken to date and in compliance with the requirements of PS1. The SEP will include procedures for information sharing between the Project and affected parties, and the establishment of a monitoring committee with representatives from the Project, local communities, and authorities.,

A Community Engagement Protocol is also being negotiated between the Project and local Municipality, setting out the principles for communication between the Project and Municipality, and responsibilities regarding community involvement and development. Community Power Committees have been established and Konexa required women representatives in each committee. Konexa has also developed a Community Development Programme with Climate Fund Managers which includes gender as a component.

External Communication and Grievance Mechanisms:

A grievance mechanism will be established as part of the SEP implemented by the Project , with the objective of providing a channel for people and communities affected by the Project to voice their concerns effectively and transparently per the ESAP. This includes recording any stakeholder comments or complaints and ensuring that they are passed on to the relevant party for response and resolution as soon as practicable. Community Notice Boards with details on how to contact Konexa with grievances are put up in communities where mini-grids are placed and sensitization activities are routinely carried out by Community Liaison Officers to remind them on how to contact Konexa. The Project SEP includes an External Grievance Mechanism, which is to be followed by the Project  to (i) receive and register grievances from external stakeholders, including Affected Communities; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses; and (iv) provide access to remedy. The EPC Contractor and all other (sub)contractors shall also adopt the External Grievance Mechanism.

Ongoing Reporting to Affected Communities

Reporting to affected communities will be conducted as part of the SEP, and through the CLOs, including changes to the Project and planning and implementation of community support programs.

PS2:  Labor and Working Conditions

Construction works for the Project will generate about 80 jobs for up to one year, and operations will involve up to 100 full-time workers. Construction staff will be housed in nearby towns, with transportation provided by the EPC Contractor, when required. Community members will also be trained and engaged on a part-time basis for the operation and maintenance of the Mini Grid.

Working Conditions and Management of Worker Relationship:

The Project will establish relevant HR policies and procedures for the construction and operations phases (as per the ESAP) to cover all workers, including direct workers and contracted workers. At a minimum, the HR Policies will include the following provisions: working relationship; working conditions; terms of employment; workers’ organizations; non-discrimination and equal opportunity; grievance mechanism; prohibition of child and forced labor; and occupational health and safety. The conditions of employment and worker’s rights will be communicated to all new employees during the induction process. The EPC contract will require the Contractor to observe applicable Nigerian labor laws and comply with requirements related to working conditions in line with PS2. It will also require the Contractor to ensure that these requirements are passed on to sub-contractors.

As part of the HR policies and procedures, the Project will develop a workers grievance mechanism for receiving, managing, and responding to any grievances received from Project workers. The EPC contractor will be required to establish its own Internal Grievance Mechanism, and all subcontractors shall adopt the grievance mechanism used by the EPC Contractor. The Project will develop and implement a Gender Based Violence and Harassment (GBVH) policy which contains the establishment of mechanisms to mitigate GBVH risks in the workplace and within communities per the ESAP.

Protecting the Work Force:

In line with Konexa’s policies, child and forced labor is prohibited in relation to the Project. The EPC Contractor will be contractually bound not to use any forms of forced labor, and to observe applicable laws and PS2 requirements related to child labor.

Occupational Health and Safety:

The ESIA includes a description of occupational health & safety (OHS) risks and impacts during construction, operations, and decommissioning, with a series of preventive measures. The main risks and impacts are expected to include working at height, operation of machinery and lifting equipment, slips and falls, traffic safety, exposure to welding light and fumes, and electrical hazards. As referenced earlier under PS 1, the C-ESMP will be implemented by Konexa, EPC Contractor and subcontractors, and includes an OHS Management Plan. This includes inter alia organization, identification of risks and prevention measures, scheduling of meetings and trainings, permit-to-work procedure, use of personal protective equipment and medical check-ups. The Project will develop and implement aCOVID-19 risk management plan for the Project per the ESAP.

Workers Engaged by Third Parties:

The Project will include HSE provisions in the EPC and O&M contracts and contracts with other sub-contractors. As a minimum, provisions will include compliance with labor legislation, terms of OHS management, and access to a workers’ grievance mechanism including review and response to anonymous complaints, and the C-EMSP applies to all contractors and service providers active at the Project sites.

Supply Chain

As part of the ESMS, procedures will be established for review of the Project’s supply chain against risks related to child labor or forced labor, in line with Performance Standard 2 (ESAP item).

PS3:  Resource Efficiency and Pollution Prevention

Resource Efficiency:

During construction, water will be primarily required for domestic use and building foundations for the solar plant, a control building, and the Customer Service Center. Total water requirement for the construction phase is estimated at around 180 m3.

During operations, water will be used to clean the solar panels. The frequency of cleaning depends on weather and climatic conditions, and the estimated water usage is around 270 m3 per year. Minor amounts of water will also be necessary for domestic and users in the control building and service center. Water requirements will be met through abstraction from existing onsite boreholes, and a hydrology study has been conducted for the solar plant site. 

Greenhouse Gases:

The Project will produce renewable energy from the solar PV plant and improve energy supply for industrial and domestic users, which will lead to a reduced use of fossil fuels for generators, and reduction of greenhouse gas emissions. The grid upgrades will also reduce distribution and transmission energy losses. Minor amounts of greenhouse gas emissions will result from operation of back-up diesel generators at the Project HQ and the Customer Service Centers.

Pollution Prevention:

According to the ESIA, air, water and soil pollution during construction and operation is not expected to be significant and can be mitigated through implementation of pollution proposed prevention measures. Pollution prevention measures indicated in the ESIA include the use of proper equipment, vehicle and roads maintenance, dust suppression measures, speed restriction, etc.

Wastewater from construction activities will include temporary sanitary facilities, stormwater and drainage over potentially contaminated areas (e.g., concrete batching/ mixing areas and equipment storing areas. Apart from runoff water from cleaning the solar panels, only sanitary wastewater will be generated during operations. As there is no sewage collection network at the site, a septic system will be used, designed and installed in accordance with local regulations the WBG EHS Guidelines.

Construction waste will primarily consist of wood residues, pallets and packaging material, metal scraps, and domestic waste. The main source of air emissions during the construction phase relates to dust emissions because of vegetation clearance, earthmoving equipment and the transportation of building materials and construction equipment.

During operations, domestic waste will be generated at the Customer Service Center and offices. Hazardous waste will include batteries, transformer oil, fuel, lubricants, etc.

A Waste Management Procedure will be developed as part of the ESMS (as per the ESAP), including characterization of waste by type, quantities, and potential use; opportunities for source reduction, as well as reuse and recycling; procedures and operational controls for onsite storage; and final disposal. This plan will also include the manufacturer’s recycling plans for batteries and discarded solar panels as applicable.

Decommissioning and rehabilitation plans will be developed prior to decommissioning of the solar plants and associated infrastructure. Such plans will include, but will not be limited to removal, re-use and recycling of materials, and vegetative rehabilitation to prevent erosion.

PS4:  Community Health, Safety and Security  

Community Health and Safety

The Project will be implemented in Kaduna state, in both urban, peri-urban and rural areas (Mini-Grids and SHS). The Distribution Project includes the construction of new 11kV and 33kV distribution lines. The right of way for the distribution lines do not cross any community, farms or pastoralist routes. The Solar Project is located in the Rigachikun community and the nearest households are adjacent to the southern boundary of the site. Community health and safety issues associated with the construction and operation of the Project include unauthorized access to project sites, road safety, impacts associated with in-migration of the project workforce, impact on community water resource use and emergency situations. According to the ESIA, there will be an induced migration to the project areas for people from nearby communities.

As mentioned above in PS2, Konexa will develop an Occupational Health and Safety (OHS) plan as part of the C-ESMP, which will be adopted by all contractors and include community health and safety aspects such as prevention on communicable diseases such as malaria, HIV/AIDs etc. (ESAP item). The Emergency Response Plan also includes potential community exposure to incidents and accidents, and a separate Traffic Management Plan will be established with traffic and pedestrian controls for both on and off-site vehicle movements (as per the ESAP). Konexa and its contractors will establish COVID-19 protocols in relation to community engagement as part of the OHS management plan (ESAP action). Konexa will provide early notification to nearby communities of upcoming works. Signage in English and the local language and barriers will also be installed

Electric and magnetic fields produced by the overhead transmission lines are expected to be within the applicable limits set by the International Commission on Non-Ionizing Radiation Protection, in line with the recommendations of the EHS Guidelines for Electric Power Transmission and Distribution.

Security

Konexa has developed an SRMP including provisions for security management and control, roles & responsibilities, crisis management and response, medical treatment and evacuation, community safety, and training. To align with the requirements of Performance Standard 4, the SRMP will be revised to include rules of engagement and codes of conduct for security forces (ESAP item).

Konexa has appointed an external security provider as security advisor for the Project, which will lead on the overall security management, including preparing and updating the SRMP, provide training and conduct drills, ensure lists of approved transportation routes and facilities (such as hotels) and work with security providers to ensure compliance with the SRMP. In addition, during the construction and operations periods, Konexa will engage a local Security Service Provider (SSP) to provide physical security at all of the sensitive project sites including the solar PV site, key injection substation sites, the Konexa HQ office and the customer service centers.  The contract with the SSP will include provisions for a rapid reaction force to be provided by the mobile police to respond to security incidents impacting the Project sites.    

The Project sites, including substations, transformers and Mini Grids will be wire fenced and monitored through closed-circuit television cameras and intrusion alarms, supported by a guard force presence at selected locations. Unmanned sites will be fitted with infra-red motion sensors to detect movement.

The Community Liaison Officer will be responsible for security-related communication and engagement with adjacent communities.

PS5: Land Acquisition and Involuntary Resettlement

A total of approximately 64 hectares will be required for the development of the Project. 10 hectares were leased from the Kaduna State government for the Solar Project. The majority of the plot was vacant and unused, but around 0.1 hectares was occupied by a poultry farm. The Distribution Project requires 54 ha of land and construction on all the Project sites will be on existing Right-of-Ways.

The area and buildings of the poultry farm has been acquired on a willing buyer – willing seller basis, following a valuation of the assets conducted by an independent third party. Konexa will conduct a review of legacy land acquisition in relation to the solar plant site, and identify mitigatory measures as adequate to achieve outcomes that are consistent with the objectives of Performance Standard 5 (ESAP item). Land for the mini-grids will be leased, and selection of sites will be conducted in liaison with the communities. A procedure for selection of sites and consultation with communities regarding land leasing will be included as part of the Project’s ESMS.

A Community Development Programme (CDP) has been established for the Project, building on community needs and opportunities identified in the ESIA and through stakeholder engagement activities. The implementation of the CDP will include community development interventions related to creation of local employment opportunities, access to micro-credit, farming techniques and production methods, water supply, healthcare services and road infrastructure. The activities of the CDP will be further detailed in consultation with communities and other stakeholders prior to implementation.

The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org. 

• Environmental and Social Action Plan (October 2021)
• Environmental and Social Impact Assessment: Konexa 2.5MW Solar PV and Grid Network Upgrades (September 2021)

Broad Community Support is not applicable for this project.

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
E-mail: cao-compliance@ifc.org