Konexa NBP2 and Solar Project

MIGA has been asked to provide a guarantee for a period of up to 15-19 years to cover Equity, Quasi-equity, and Shareholder loan investments provided by Konexa Power Holdings PCC of Mauritius (“Konexa”, the Guarantee Holder (GH)) for the development, operation and maintenance of the new subprojects in Nigeria. Konexa is a repeat MIGA client. MIGA received Board approval in June 2022 and amendment approval in May 2023 to issue up to US$45 million of guarantees to the GH to cover its investments in Commercial and Industrial (C&I) projects and the Off-Grid project against the risks of expropriation and war and civil disturbance. The first Contract of Guarantee (CoG) was issued in February 2024 for the C&I project located in Kaduna (NBP1 Project). 

The Konexa Project now comprises two new Project Enterprises (PEs): KONEXA NBP 2 LIMITED and KONEXA SOLAR 2 LIMITED. The term “Project” is used to collectively refer to these PEs and their subprojects. This ESRS focuses exclusively on these new PEs and subprojects and does not cover the existing NBP1 Project in Kaduna State, which was previously disclosed in December 2021 and March 2024.  

The NBP2 Project-Enugu involves the ownership, financing, construction, operation, and maintenance of distributed energy and storage systems to be installed within Nigerian Breweries (NB) premises at Amaeke Ngwo, Udi Local Government Area, Enugu State. These systems include transformers, switchgear, metering, double inverter, Battery Energy Storage System (BESS), ring main units, and other associated equipment and buildings. It also covers the financing, construction, rehabilitation, upgrade, extension, operation, and maintenance of new and existing electricity lines, substations, and other related interconnection infrastructure. Grid connections will be made with a planned 19.42 km 33kV overhead electricity line originating from the Transmission Company of Nigeria (TCN) New Haven transmission substation, to supply energy to the NB premises at Ama, Udi Local Government Area, Enugu. A dedicated substation, BESS, and Uninterruptible Power Supply (UPS) will be constructed for effective power integration and internal distribution with the NB Ama Plant. 

The NBP2 Project-Lagos shares a similar scope to the subproject in Enugu. Facilities are located at Iganmu, Surulere Local Government Area, Lagos State, and include new 33kV overhead and underground electricity lines from Akangba (2.7km) and Ijora (3.1 km) transmission substations to the Lagos plant. Within the NB Lagos premises, a site-specific storage and power management solution will be implemented, including a UPS and associated BESS. 

As Konexa continues to expand its business, it will continue to add new customers and invest in additional equipment, such as more electricity lines at different voltage levels. For the existing NBP1 Project, Konexa is investing in new construction of electricity lines to a substation on the transmission system to interconnect an additional nearby customer(s) to the NBP1 Project’s system in Kaduna State. Similar approaches are anticipated for the NBP2 Project in Lagos and Enugu States. These expansions are expected to have limited environmental and social (E&S) risks and impacts (no physical resettlement, no adverse impacts on sensitive or protected areas, no adverse impacts on cultural heritage sites…). MIGA will conduct the required E&S due diligence prior to these expansions. 

This Solar Project covers the ownership, financing, construction, operation, and maintenance of about 40 MWp grid-connected solar power plant, a 6.8 MW BESS and interconnection equipment located along the Abuja-Kaduna Expressway, near the Abuja Steel Mills Limited (ASML) facility in Gurara Local Government Area, Niger State. The solar plant will feed into the national grid at the existing 132/33kV Paras Energy substation, enabling NB to claim renewable energy use. Key components include PV solar panels/modules, mounting structures, inverters, transformers, a new grid connection substation, underground and overhead electricity lines, on-site buildings (operational control center, office, security house), access roads, and ancillary infrastructure. 

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: 

For NBP2 Project-Enugu and NBP2 Project-Lagos, there will be no additional land acquisition for the electricity lines, which will be laid along the existing road right-of-way and no physical displacement or material economic displacement is expected. For the Solar Project, the 40ha site for the proposed solar farm was acquired by ASML from the Niger State Government, with a valid Certificate of Occupancy. The land was subsequently leased to Konexa by ASML for a period of 30 years. There is no physical displacement, and all economic displacements have been compensated for, and no outstanding community grievances were reported related to the land lease process. For the Solar Project, the national grid is located near the solar plant site, and the electricity line (1 km) will not require any physical or economic displacement. Therefore, PS5 Land Acquisition and Involuntary Resettlement is not directly triggered. Any potential residual impact will be managed under PS1. 

There is no material impact related to biodiversity, and the Project sites are not home to any Indigenous People and do not contain known cultural heritage. Therefore, PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7 Indigenous Peoples and PS8 Cultural Heritage are not directly triggered; 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: 

In addition to reviewing the above documents, MIGA engaged with Climate Fund Managers B.V. (CFM) and Norfund (July and October 2025) to discuss the findings of their respective due diligence, which included their site visits conducted in November 2024. MIGA also had several virtual engagements with Konexa to get updates about the implementation of their Environmental and Social Management System. Finally, MIGA conducted a due diligence site visit in September 2025 (NBP2 Project-Lagos, and Solar project) and October 2025 (NBP2 Project-Enugu). The site visit included (i) a meeting with ASML’s senior management that leased the land to Konexa; (ii) interviews with select members of a cross section of community leaders representing different stakeholders: village chief, youth leader, women leader, community association secretary. 

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 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: 

As a repeat MIGA client, Konexa has developed and is implementing an ESMS and Occupational Health and Safety Management Systems (OHSMS). Each PE will develop Project-specific ESMS and OHSMS manuals covering both the construction and operation stages, which will specify compliance with applicable E&S laws and MIGA PSs and which are suitable to be inserted into the Engineering Procurement & Construction and Operation & Maintenance bidding documents (ESAP item). The ESMS and OHSMS will be 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 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 (ESAP item). 

Each PE will ensure that the Project E&S standards and MIGA’s E&S requirements (including the agreed ESAP) are cascaded in legal agreement with the Engineering Procurement & Construction (EPC) contractors (ESAP item). The EPC contractor will design and implement a set of distinct yet harmonized and compliant management plans—such as, but not limited to, the Occupational Health & Safety Plan, Environmental and Social Management Plan, Labor Management Plan, Community Health & Safety Plan, Human Resources Policies, Traffic and Transport Management Plan, for the construction stage and that are aligned with the Project’s requirements, Nigerian laws, MIGA’s PSs and WBG EHS guidelines.  

Policy: 

Konexa has established an HSSE policy (April 2023) for the NBP1 Project, outlining its commitment to managing safety, environmental, and social risks. This includes ongoing engagement with local stakeholders and surrounding communities. Konexa is also developing a corporate-level Environment, Social and Governance (ESG) Management System (ESGMS) applicable to all projects to address ESG considerations throughout project identification, due diligence, and reporting. Konexa will finalize its ESG policy and update its ESGMS by laying out the requirements for each PE to develop a project specific ESMS and ensuring that going forward any new PE would have a framework from which to develop project specific documentation based on corporate policies, program and procedures (ESAP item). Konexa also established Human Resource policy which has been updated on April 2025 to address GBV gaps. 

Identification of Risks and Impacts: 

Environmental and Social Impact Assessment (ESIA) final reports have been prepared for the Enugu and Lagos sites, and a draft ESIA for the Niger site, in accordance with local regulations and the requirements of the PSs and covering the activities within the Project. The ESIAs have been submitted to the Federal Ministry of the Environment for review and approval, and the final versions consider any comments resulting from the authorities’ review as per regulatory requirements. Following a recent modification of the Enugu electricity line route, the new line route will be within the Right-of-Way (RoW) of the Enugu-Onitsha expressway. A dedicated ESIA is being prepared for this component of the Project and will be submitted to the Ministry of the Environment for review and approval. During the site visit it was noticed that because of encroachment into the expressway’s RoW, some existing utility poles are located within private properties. KONEXA NBP 2 intends to implement tubular towers, which provide a minimum span of 100 m between towers to decrease the number of poles that may need to be located within encroachers properties and will install mesh guards to prevent snap conductors where electricity lines run directly above buildings. KONEXA NBP 2 also intends to implement a collocation strategy through the installation of tubular towers designed to accommodate both new and existing cables. Following the completion of ESIA process, KONEXA NBP 2 will be required to address any potential E&S related gap associated with the new Enugu electricity line route in line with MIGA PSs requirements and within a timeline agreed with MIGA (ESAP item). The NB facilities and operations are out of the scope of the ESIA and MIGA’s PSs applicability as they do not qualify as Associated Facilities per the MIGA PS1. The presence of distributed energy systems on NB premises is solely for the purpose of enabling grid interconnection and power delivery. They do not require modification or expansion of the brewery’s operations. In addition, MIGA Exclusion List does not apply to C&I off-takers activities as MIGA is only supporting renewable energy generation. 

Konexa has developed a risk register for the previous NBP1 Project, which outlines the identified risks for the project. Draft E&S risk assessment reports have been developed for the Project and the existing register will be updated to include the identified Project’s risks (ESAP item).  

Management Programs:  

The ESIAs include a framework for an Environmental and Social Management Plan (ESMP), which provides principles for preventing and mitigating environmental and social impacts, in both construction and operation phases. While the Solar Project ESIA was developed by ASML, all ESMP requirements also apply to Konexa. Building on the findings of the ESIAs, applicable regulation and the requirements of the PSs, and Konexa’s own ESMP, Occupational Health and Safety Management Plans (OHSMP), and procedures, the PEs will require their EPC contractors to develop Construction ESMP (C-ESMP). The PEs will review and approve required management plans prior to construction (ESAP item). These plans and procedures will include but not be limited to: human resource policies; waste management; pollution prevention (including emissions, spill response); water management (including supply, treatment, disposal); hazardous materials; emergency preparedness and response; occupational health and safety; community health, safety and security; road safety and traffic management; accommodation management; local recruitment and labor management; environmental monitoring; stakeholder engagement (including grievance management); chance find procedure; workers grievance redress mechanism; gender-based violence, malaria and transmissible diseases management plan, and pest and invasive species management plan. The management plans include details on monitoring actions, and the frequency of monitoring, along with the performance indicators and the responsible entity.  

Organizational Capacity and Competency: 

Currently, Konexa has a team structure that includes senior management (permanent staff) and contract project staff. The team includes an E&S Manager and a Community Development Manager at corporate level, as well as a Health, Safety, Environment and Community (HSEC) Officer and three Community Liaison Officer (CLOs) specifically recruited for the NBP1 Project. The recruitment of three additional HSEC officers and three CLOs is being finalized in order to have a dedicated HSEC officer per site. However, the Human Resources (HR) Manager has yet to be filled. CFM will act as an E&S advisor throughout the Project construction and operations phases, including support for implementation of the ESMS, monitoring of HSE aspects in construction, stakeholder engagement, the grievance mechanism, and providing capacity building. Konexa will be required to provide the CV of the selected HSEC officers and CLOs to MIGA before construction (ESAP item). Konexa will be also required to hire an experienced and dedicated corporate HR Manager (ESAP item).  

Each EPC Contractor, including Paras Energy for the Solar Project, 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 (ESAP item). 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 have required capacity to ensure the proper implementation of E&S requirements. 

Emergency Preparedness and Response: 

An Emergency Response Plan (ERP) will be a part of the ESMP 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 (ESAP item). As part of the C-ESMP, the Project will require its 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 relevant local authorities and technical services.  

Monitoring and Review:  

Each PE will provide effective oversight of its EPC Contractors’ management of E&S risks and impacts in accordance with the Contractor Management Plan and check that ESAP items and the mitigation measures included in the ESMP are being implemented adequately (ESAP item). The EPC Contractor will report regularly on the implementation of the C-ESMP to the Project.  

As a condition of MIGA’s contract of guarantee, the GH will be required to provide MIGA with an Annual Monitoring Report that evaluates E&S performance against MIGA’s E&S requirements and will include sections on E&S risks and impacts, updates on development effectiveness indicators throughout the guarantee period. 

Stakeholder Engagement 

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 phase. 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.  

External Communication and Grievance Mechanisms: 

Konexa has an existing external Grievance Redress Mechanism (GRM) which will be included in SEP to be 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 (ESAP item). The GRM will ensure the Project to: (i) receive and register grievances from external stakeholders; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track through a dedicated register, and document responses; and (iv) provide access to remedy. The EPC Contractor and all other (sub)contractors shall also adopt the External Grievance Mechanism. 

Project information is disclosed through the project website, information boards, local government offices, and regular direct engagement with stakeholders. Reporting to affected communities will be conducted as part of the SEP, and through the Community Liaison Officers (CLOs), including changes to the Project and planning. Three additional CLOs are being recruited to ensure that each site is covered by a dedicated CLO. 

PS2:  Labor and Working Conditions  

Construction works for each of the sites at Enugu and Lagos States will generate up to 145 jobs (60 skilled and 85 unskilled) at the peak of the 15month construction phase. At least 80% of the workforce will be sourced from the host communities. During operations, about 15–20 staff will be employed to manage substation functions and line maintenance, with a focus on local hiring and skills transfer. For the solar plant site in Niger, the Solar Project is expected to employ up to 800 workers at the peak of the 18month construction phase, including 720 locally sourced unskilled workers and 80 skilled workers such as engineers and technicians. During operations, about 70 staff will be employed for maintenance, monitoring, administration, EHS, and security, with a mix of skilled and unskilled roles, prioritizing local recruitment. Community members will also be trained and engaged on a part-time basis for the operation and maintenance of the Solar Project. 

A temporary base camp will support onsite personnel of the Solar Project. This accommodation will be required to be compliant with the IFC/EBRD Guidance Note on Workers’ Accommodation: Process and Standards. EPC contractors and subcontractors typically rent houses in nearby towns for their permanent and skilled staff. All accommodation facilities, including the base camp and the rented houses, will be subject to monthly inspections by the Project to ensure compliance with MIGA PS 2 requirements (ESAP item).  

Working Conditions and Management of Worker Relationship:  

Konexa has an HR policy consistent with local laws and MIGA PS2 requirements (April 2025) and procedures which apply to the Project construction and operations phases and which cover all workers, including direct workers and contracted workers. The HR policy includes several provisions, including: recruitment and onboarding; code of conduct; working conditions; terms of employment; workers’ organizations; non-discrimination and equal opportunity; anti-harassment; grievance mechanism, including GBV; 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 (ESAP item).  

As part of the Konexa HR policy and procedures, the Project will develop a workers grievance mechanism for receiving, managing, and responding to any grievances received from Project workers (ESAP item). 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 (ESAP item).  

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 ESIAs and the draft risk assessment reports include description of occupational health & safety (OHS) risks and impacts during construction, operations, and decommissioning, with a series of preventive measures. The main OHS 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 PS1, the C-ESMP will be implemented by the Project, EPC Contractors and subcontractors, and include 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.  

Workers Engaged by Third Parties: 

The Project will include HSE provisions in the EPC and O&M contracts and contracts with other sub-contractors (ESAP item). 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. The Project will conduct internal audits of contractors’ staff (monthly during construction, then twice a year during operation) to verify workers are legally hired as per the Nigerian legislation, and to ensure compliance with MIGA’s PS2 requirements (ESAP item). 

Supply Chain 

The Project will develop a sourcing policy including supplier’s code of conduct principles reflecting compliance with applicable laws, health and safety, prohibition of forced and child labor, human rights and working hours etc. The Project will ensure and will require the EPC contractor to ensure that all their suppliers sign and adhere to these principles (ESAP item). The Solar Project’s PE will be required to (i) conduct a supply chain risk assessment of the nominated primary solar suppliers and develop supply chain risk assessment procedure and a screening mechanism against risks for alleged child and forced labor in the solar supply chain; and  (ii) incorporate or require the EPC Contractor to incorporate the provisions related to child labor and forced labor in each contractual agreement it or the EPC contractor enters into with a solar supplier (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 15,000m3.  

During operation, dry cleaning of solar panels will be preferred to avoid water abstraction from existing boreholes on site. If dry cleaning is not feasible, the Solar Project will: 
(i) submit to MIGA for approval a “best available technology” assessment, evaluating the technological, economic, and E&S implications of both dry and wet cleaning methods ; and (ii) provide a hydrogeological study and water mass balance to confirm that the Solar Project will not result in any material adverse impacts or conflicts with local water use—such as agricultural or community needs, taking into account climate change considerations (ESAP item).  

The Solar Project will develop and implement a Water Management Plan for construction and operation, which will include measures for efficient water use/water minimization as part of the cleaning needs for panels and for general use as well as monitoring procedures of water supply services. Water use will be a KPI, and the PE will keep track of water usage (ESAP item). 

The Solar 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 (GHG). The grid upgrades will also reduce distribution and transmission energy losses. GHG emissions during the construction and operations phase are expected to be predominantly associated with the use of fuels for vehicles and machinery.  

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 proposed pollution 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 Solar Project site, a septic system will be used, designed and installed in accordance with local regulations and the WBG EHS Guidelines. Storm water management measures have been implemented at the Solar Project site through the construction of a concrete channel designed to collect runoff from opposing slopes. This channel directs storm water to a natural pond. Additionally, existing vegetation has been preserved on the surface area to support erosion and sediment control within the site. 

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 Project’s customer service center and offices. Hazardous waste will include batteries, transformer oil, fuel, lubricants, etc. A Waste Management Plan will be developed as part of the ESMS (ESAP item), 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 cover hazardous waste management, including the manufacturer’s recycling plans for batteries and discarded solar panels as applicable, and provisions to ensure that hazardous waste contractors that will be engaged are licensed by the relevant local authority. 

The Project will require the EPC contractor to develop and implement Pollution Prevention and Control Plan including dust suppression measures, speed restriction, regular maintenance of machinery and equipment, implementation of erosion control measures, an oil spill prevention and management procedure, providing spill and leak cleanup material and equipment (ESAP item).  

PS4: Community Health, Safety and Security   

Community Health and Safety 

NBP2 Project-Enugu is located in a peri-urban area characterized by limited residential development, while NBP2 Project-Lagos is situated in a dense urban environment. In contrast, the Solar Project is sited within an industrial area.  

Community health and safety risks 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. Induced migration is also anticipated to the Solar Project areas.  

As mentioned above in PS2, the Project will develop an OHSMP as part of the C-ESMP, which will be adopted by all contractors and include community health and safety aspects including prevention of communicable diseases such as malaria and HIV/AIDs (ESAP item). The ERP also includes potential community exposure to incidents and accidents, and a separate Traffic and Transport Management Plan has been established with traffic and pedestrian controls for both on and off-site vehicle movements. Konexa will provide early notification to nearby communities of upcoming works.  

Security  

A Security Risk Management Plan (SRMP) has been developed for the Project, and it includes provisions for security management and control, roles & responsibilities, crisis management and response, medical treatment and evacuation, community safety, and training, rules of engagement and codes of conduct for security forces. Based on an assessment of security risks related to the Project, security risks are fluid, but manageable, and regular re-assessment is required. 

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. Konexa has also engaged a local Security Service Provider (SSP) to provide physical security at all of its sensitive facilities, and the contract includes provisions for a rapid reaction force to be provided by the mobile police to respond to security incidents. Konexa will be required to update the contract to include the Project’s sites (ESAP item).  

The Project sites, including substations, transformers are wire fenced and will be monitored through closed-circuit television cameras and intrusion alarms, supported by presence of security personnel at selected locations. Assets located within the NB premises will be under the host security personnel’s supervision. The CLO will be responsible for security-related communication and engagement with adjacent communities. 

Broad Community Support is not applicable for this project. 

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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