Saint Lucia LED Street Lights Project

MIGA has been requested to provide guarantees to cover: (i) an equity investment and retained earnings of up to US$3.4 million from KLED Capital Limited of British Virgin Islands (KLED Capital); and (ii) a non-shareholder loan and future interests of up to US$9.0 million from CIFI LATAM S.A. (CIFI) of Panama into KLED (St. Lucia) Limited incorporated in Saint Lucia (hereinafter referred to as the “Project Enterprise” (PE), or KLED).  

The Project consists of: (i) The installation, replacement, operation and maintenance of 24,640 energy efficient LED streetlights. The Project will replace 22,000 existing old high pressure sodium lamps (HPS) with LED lamps and install 2,460 new LED streetlights; and (ii) the installation, operation and maintenance of up to 969 CCTV cameras at up to 323 locations island-wide in St. Lucia by the PE as per the Fixed Price Public-Private  Partnership Contract (the Contract) signed between KLED Capital and the Government of Saint Lucia (GoSL) on October 12, 2019. The 24,640 LED streetlights to be installed, will represent 100% of the St. Lucia streetlights. The LED streetlights and CCTV camera equipment shall remain the property of KLED during the period of the Contract and will be transferred to GoSL at the end of the Contract. 

As per the Contract, KLED is responsible for the supply and installation of the LED streetlights during the 18-month execution phase, and subsequently the operations and maintenance during the 14-year operation phase. KLED has subcontracted Islandwide Electrical Limited (“IWE”) to be responsible for streetlight installation and K&B Tech Solution (“K&B“) for CCTV camera installation for the Project. The LED streetlightmodules will be supplied by Lumileds. KLED is partner of Lumileds in the “Lit by Lumileds” program.  

KLED’s main services during the operation phase include, among others, the repairing of any material defects in the LED lights under the 14-year warranty, and the provision and operations of management and reporting software to report failures, track repairs, inventory upgrades and map equipment by GPS. During the operation period, GoSL will continue to own the land, and St. Lucia Electricity Services Limited  (LUCELEC) which is the is the only power utility company in Saint Lucia, will be responsible for the maintenance of the poles, over head cables and the power distribution network.  

The Projects have been categorized as a Category B under MIGA’s Policy on Environmental and Social Sustainability (2013). The Project is expected to have potentially limited adverse Environmental and Social (E&S) risks, generally site specific and can be addressed through the implementation of applicable Performance Standards (PSs), Environmental Health and Safety (EHS) guidelines, and design criteria. The  key potential risks and impacts associated with the Project  include (i) Hazardous (e.g., sodium bulbs, maintenance rags, oil recipients etc.) and non-hazardous (e.g., cables, scrap metals and wires.) waste management; (ii) occupational health and safety risks for the electric workers and drivers including electric shocks, works at height and traffic safety; (iii) community health and safety; (iv) impacts on biodiversity, such as light pollution, as some of the retrofitting will be conducted in the protected areas.  

While all Performance Standards (PSs) are applicable to this Project, current information indicates that the Project 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 

• PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources 

PS 5 Land Acquisition and Involuntary Resettlement and PS8 Cultural Heritage do not apply, as the PEs will not acquire or lease any land for the Project and the new LEDs will be installed on existing poles and the new CCTV cameras will be installed within the existing fiber optic cable network. Installation will be a short-term activity conducted on the public roads. New construction, excavation or trenching activities are not expected to be undertaken.  

According to the Independent Environmental and Social Consultant (IESC) review report no indigenous people were identified in the Project area and, thus, PS 7 Indigenous People requirements are not applicable to this Project. 

In addition to the PSs, the World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines apply to this Project.  

For this Project, MIGA’s environmental and social due diligence (ESDD) consisted of reviewing and discussing the following documents:   

• KLED Environmental Risk Assessment Feb 2021 

• KLED Environmental Management Plan, Feb 2021 

• KLED Waste Management Plan, last updated in May, 2021 

• KLED Waste Management Procedure, Oct 2019 

• KLED Noise Risk Assessment, Feb 2021 

• KLED Environmental and Social Management System Manual, Feb 2021 

• IslandWide Electrical Ltd. Job Safety Analysis Form, Nov 2020  

• KLED Environmental, Social, Health and Safety (ESHS) Policy, Feb 2021 

• KLED COVID-19 Compliance and Inspection Checklists; 

• KLED Environmental and Social Due Diligence (ESDD) Report. RINA consulting, Mar 2021. 

• LUCELEC Safety Rules Mar 2021 

• KLED Sub-contractor Code of Conduct 2021 

Due to travel bans and restrictions as result of COVID-19, MIGA’s E&S team could not conduct a site visit and depended on RINA consulting which conducted the E&S Due Diligence (ESDD) on behalf of CIFI. RINA ESDD comprised of reviewing of PEs E&S documentation; site visits to several Project locations, met with community representatives and interviewed the IWE employees in late February 2021. MIGA also had meetings with RINA Consulting, CIFI and KLED.  

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 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 Performance Standards objectives. 

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

Anticipated E&S risks and impacts are mainly related to streetlights component of the Project. These risks are minor, site-specific and can be managed by following health and safety procedures and waste management practices. Nevertheless, because light replacement works will be conducted on the roads either crossing or adjacent to protected areas, the Project Enterprise has hired an independent environmental consultant to conduct a biodiversity review to identify and assess the potential risks from light pollution (for more infromation please refer to the relevant sections below).     

Environmental and Social Assessment and Management System 

KLED has developed an Environmental and Social Management System (ESMS) Manual. The ESMS consists of 12 sections: environmental aspects, training, communication, emergency preparedness and response, environmental monitoring, among others. KLED will update Project specific ESMS for the construction and operation. As per the ESAP , KLED will update their ESMS to align with MIGA’s PSs as well as applicable WBG EHS guidelines, conform to Saint Lucia’s laws and regulations requirements to include social, health and safety, grievance redress mechanism, traffic safety, external communications, as well as the requirements and the procedure for the periodic E&S monitoring.  

Policy  

KLED has developed an Environmental, Social, Health and Safety (ESHS) Policy (Jan 2021). The document requires KLED contractors and subcontractors to follow occupational health and safety requirements including site security, occupational hygiene, noise control, waste management and traffic control. It also requires sub-contractors to provide equal employment opportunity regardless of race, nationality, religion, age, gender and medical history. As per the ESAP item 1, the Project will supplement the Policy document with i) KLED’s management commitment and responsibility to ensure compliance with the Policy; and ii) adherence to MIGA Performance Standards and other applicable Codes of Practice  

Identification of Risks and Impacts 

Following the requirements of the Saint Lucia Physical Planning and Development Act (Dec 2005), environmental and social impact assessment study is not required for the Project due to the nature of its activities. KLED has a written authorization from the Department of Economic Development Transport and Civil Aviation of the GoSL from March 27, 2020, which approves to proceed with the full implementation of the streetlight replacement program. 

To address the E&S risks related to the Project, KLED has developed an Environmental Risk Assessment matrix. It ranks risks related to odor, noise and vibration and fugitive emissions by probability of exposure and severity of consequences and lists some of the risk mitigation measures to be implemented.  

Management Program  

KLED has developed processes and procedures that are detailed in the ESMS. They also developed an Environmental, Social, and Health and Safety Risk Management Plans. These management plans are in a matrix format and refer to specific mitigation measures including protection of vegetation, waste management, traffic management and health and safety amongst other topics. The management plans include details on monitoring actions, along with the performance indicators and the responsible entity including KLED’s contractors 

Organizational Capacity and Competency 

The KLED Project Director is responsible for the ESHS aspects. Neither IWE nor K&B have assigned an officer responsible for EHS management. The ESMS defines E&S responsibilities for the senior management and the ESMS coordinator of KLED. A per the ESAP ESMS will be updated  to outline E&S coordination between KLED and its main contractors (IWE and K&B) and ensure that all the contractors and sub-contractors will implement applicable E&S standards per contractual agreements. As per the ESAP, KLED will also ensure that IWE and K&B assign qualified EHS officers. 

Emergency Preparedness and Response 

KLED has developed the Emergency Preparedness and Response Plan (EPRP) as a part of its ESMS Manual. It covers such scenarios as electrocution of workers, hurricane preparedness, traffic accidents and other. Each installation crew will be equipped with first aid kit and regular first aid training will be provided to the IWE staff.  KLED will update the EPRP section in the ESMS Manual to establish the Emergency Response Team (ERT) and describe ERT’s responsibility, and a procedure for regular drills. KLED will also integrate its EPRP with the one available at IWE and LUCELEC for a coordinated action in case of emergency require IWE and K&B to update their ESRP to be in line with MIGA PS1(per the ESAP). 

Monitoring and Review  

As part of the ESMS, the KLED will develop and implement a program of reporting for the installation/ replacement and the O&M phases of the Project. Reporting will be done in a form of EHS checklist, incident record register, and regular environmental and social performance reports. During installation, the IWE and K&B will submit regular reports to KLED and CIFI, which will be shared with MIGA. The Project will also provide MIGA with a semi-annual environmental and social monitoring report during the installation, and an annual environmental and social monitoring report during operations. 

Stakeholder Engagement  

The Project was originally considered for financing in 2016.  In 2016, GoSL was responsible for stakeholder engagement and disclosure of information to stakeholder. GoSL posted the information on its official website in May 2016 and its official Facebook page in June 2016 , and invited the general public to provide comments. Out of 5 comments received, four were positive and one was neutral. Since then, no information about the Project was disseminated. As per the ESAP, KLED will develop and implement a Project specific Stakeholder Engagement Plan (SEP) for the LED installation and O&M stage. The SEP will include the following elements: engagement principles, objectives and criteria, identification, characterization and priority of stakeholders, engagement program including indication of which information should be disseminated (i.e. works schedule, roads closure schedule etc.) and how it will be delivered to stakeholders and the description of grievance redress mechanism.  

External Communication and Grievance Mechanisms 

Currently, the Project doesn’t have an External Communication and Grievance Mechanisms to manage grievances and communicate to external stakeholders. Therefore, KLED will develop an External Communication and Grievance Mechanism procedure in line with MIGA PS1 during installation and O&M phases. This procedure which will, among other things, include methods to receive, register, screen and assess, track, respond to, and act upon external inquiries and complaints from the public during construction and operations. The grievance mechanism shall ensure that grievances from affected communities and external communications from other stakeholders are responded to and managed appropriately.   

PS2:  Labor and Working Conditions 

KLED has a total of 3 employees, of which all are males.  IWE has a total of 22 employees of which 1 is female.  IWE will also have 2 employees during the O&M stage of the Project. K&B has eight employees of which two are women 

Human Resources Policies and Procedures 

KLED does not have an HR procedures and Policy and based on the IESC report, some employees lack labor contracts. Therefore, KLED will develop and disclose an HR policy with procedures that are Project specific, in line with MIGA’s PS2 and Lucia’s national labor law per the ESAP. The  HR Policy will detail the employees terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation, health insurance and end of service benefits per SaintLucia national labor regulations.  The HR policy will be provided as a hard copy to current and new hires together with an employment contract which outlines the terms and conditions of their employment. KLED will ensure that the HR Policy is adopted and followed by all contractors and subcontractors. In addition, KLED has developed the Project Code of Conduct to be provided to subcontractors that details KLED commitment to core values and sustainability principles including equality, diversity and inclusion.  It also covers general rules and behavior on site including hygiene and safety, alcohol/ drug/ non-smoking policy, use of personal protection equipment and compulsory site inductions. The Code of Conduct will be updated to include issues related to gender-based violence and harassment at the workplace per the ESAP.  

IWE follows the principles of the Labor Code of Saint Lucia (2006) which has some elements consistent with the requirements of the Performance Standard 2 including the employee’s rights to join workers organization, provisions for non-discrimination and equal opportunity and prohibition of child labor.  

Working Conditions and Terms of Employment 

IESC visited the Project and based on the Project ESDD findings and conclusions, the working conditions in IWE compound are consistent with the requirements of PS 2. IWE provides an allowance for lunch to its workers. Workers usually have lunch in restaurants located nearby their work fronts. Regarding the use of restrooms, workers use facilities located in public institutions, which are located at short distance from each work front and in general have good sanitary and hygienic conditions. During the site visit random interviews were conducted to IWE workers. They expressed satisfaction with their working conditions. 

Employee Grievance Mechanism 

Based on IESC ESDD findings, IWE workers make their complaints directly to their supervisors. It is reported that workers' complaints, concerns and suggestions are promptly addressed; however, they are not recorded. As per the ESAP item, the KLED will develop a written Worker Grievance Mechanism and disclose it to all workers including contractor’s employees (IWE and K&B). KLED’s grievance mechanism will clearly define the response timeframes to grievances and incorporate a grievance log as part of the grievance redress mechanism process. In addition, KLED will require IWE and K&B to develop and make available a worker’s grievance mechanism that will inform workers of the grievance mechanism process and in line with MIGA PS2 requirements.  

 The grievance mechanism will be an internal process for responding to feedback and concerns; it will not impede access to other judicial or administrative remedies that are available to workers under St. Lucia’s national laws or through any collective (union) agreement.  

Occupational Health and Safety 

IWE, the main contractor of KLED, follows the health and safety requirements of LUCELEC, the country’s power utility company. The installation contractual agreement that was signed and agreed between KLED and IWE has incorporated key EHS requirements for IWE to strictly adhere to and implement for the Project.  LUCELEC Safety Rules are generally in line with the PS 2 and WBG EHS Guidelines and cover confined space entry and work at heights, hazardous materials, tools and protective equipment and vehicles operation. These rules also cover such aspect of hazards management as safety meetings, work authorization, employees conduct, safety training, emergency response procedures and incidents investigation.  

LUCELEC conducts training on its health and safety procedures for sub-contractors and their workers at least 3 to 4 times per year. Based on the interviews, IWE also attends the regular safety training conducted by the LUCELEC. The Project will formalize the health and safety training by developing a training matrix which will reflect the health and safety competency levels for each work stream (linesman, etc.) (as per the ESAP).   

Potential occupational hazards include falls from height and electrocution, as well as the exposure to a hazardous dust that can be emitted from the broken sodium bulbs. IWE has appropriate preventative safety measures in place, which were observed during the site visit, including machine guarding and emergency signing. IWE provides the necessary appropriate PPE. Adherence to wearing the required PPE was observed during the site visit.  

The COVID- 19 has potential risks and impacts on KLED and its activities. To reduce the potential impact of COVID-19 on workers, customers and communities, As per the ESAP, KLED will develop policies and procedures to ensure that the risks associated with COVID-19 are adequately addressed for the Project  

Supply Chain:  

The LED streetlight modules will be supplied Lumileds, global lighting solutions company headquartered in the United States. CCTV cameras are manufacturedby Dahua Technology, IT solution and security service provider based in China. KLED conducted the supply chain risk assessment of the main suppliers and no risks were identified.  

PS3:  Resource Efficiency and Pollution Prevention 

Water Consumption 

Water requirements during installation/ replacement of the LEDs and CCTV cameras and, also, during operations are minimal and limited to domestic use, sanitation and drinking water at IWE facilities and wiping of the CCTV lenses semiannually.   

Wastes 

The main environmental concern is the handling, management and proper disposal of hazardous waste from the Project that will include; sodium bulbs, as the existing HPS lamps contain small amounts of mercury which is a hazardous material. The Saint Lucia Waste Management Act requires safe management and export of the hazardous waste to a facility approved by the Physical Planning and Development Authority. 

Based on the Project Waste Management Plan (updated in May 2021) the waste streams generated by the Project can be summarized in the Table 2 below 

Table 2: Waste to be generated from the street lighting component 

IWE installation crews will remove sodium street lights from the poles in their casings together with fitting and connecting cables. The casings of the existing HPS lamps are graded as IP (“Ingress Protection”) 66 following International Standard EN 60529:1991 Degrees of Protection Provided by Enclosures (IP Code). IP 66 mean that the casings provide full protection against dust and other particulates and provide protection against direct high pressure jets. HPS lamps will be delivered to the IWE compound where IWE teams will separate photocells and aluminum cable from the casing and place them in the 40 ft. containers. One container may fit approximately up to 3000 whole streetlight pieces. The IWE team will not have to remove the bulb from the casing before transportation which will eliminate the risk of exposure to breakages and hazardous dust. KLED has an agreement with the Cadwell Inc. which is a certified recycling company to manage hazardous waste based in Boca Raton, Florida. All sodium bulbs will be transported in the ship designated to the hazardous materials provided by Cadwell Inc. As per the ESAP KLED will update the WMP to ensure that the IWE compound that is used for the Project to manage waste, will be complaint with MIGA PS3 and the World Bank Group EHS Guidelines. In particular, hazardous waste should be stored separately from other waste streams, secondary containment should be provided to prevent the release of the hazardous substances to the environment, proper working surfaces and tools should be provided to enable safe working environment, signage should be posted, the site should be free from debris and slipping and tripping hazards.  

Other non-hazardous solid waste that include scrap metal, plastic and packaging waste will be transported to the landfill following the agreement with the Saint Lucia Waste Management Authority (SLWMA).  

Noise 

During the Project installation works, the noise level will be minimal and temporary in nature and will be mainly attributed to the transportation trucks (bucket trucks and pick-up trucks). The Project will minimize noise disturbance impacts by restricting the use of transportation trucks that are the main noise emitters to daytime hours.  

PS4:  Community Health, Safety and Security 

Work activities will be conducted on public roads, including vehicle ways and walkways exclusive for pedestrians. The social risks associated to the Project are related to traffic accidents and safety conditions for pedestrians. The Traffic Control Plan (Feb 2021) provides some measures to avoid such risks (e.g. placing of cones and signaling in pedestrian walkways). The implementation of these measures was verified during the site visit. Based on the IESC findings, the risk of pedestrian accidents to is low and is being properly addressed. KLED will update the Traffic Control Plan to include provisions for road closures and alternative routes, as well as the procedure for notification of and coordination with the local traffic authorities.  

During the site visit, it was observed that the Project work activities will have minimal impacts and will not generate noise and dust to neighbors and/or business. No sensitive social receptors were identified. As part of the visit, community members who live and work near the Project sites were also interviewed. They indicated that they are aware of the Project and generally have a positive opinion about it. Interviewees mentioned that the Project would benefit the pedestrians and would increase the security in the neighborhood. During the site visit meetings and engagement with stakeholders and communities, no major concerns or complains were raised by the stakeholders.  

Security Personnel 

IWE employs two security guards to control access to its premises. In case of security incident, the guard communicate with the local security authority to resolve the issue with affected parties involved. No incidents regarding the conduct of the security personnel were reported by IWE. The IESC considers that the risks from the security personnel to the community are low. KLED will develop a Security Management Plan to determine the actions to be taken by the security personnel and by KLED/ IWE in case of security incidents per the ESAP.  

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resource  

Because some of the streetlights will be retrofitted along the roads either adjacent to or crossing the borders of the established protected areas, the Project has engaged TSA Ecology, independent consulting company from United Kingdom, to conduct a desktop review of potential impacts from the Project. The following protected areas were identified: i) Castries and Dennery Waterworks Reserve and Marquis where 31 (250 watt) sodium lights will be replaced; ii) Pointe Sables Environmental Protection Area (PSEPA)- 5 (250 watt) and 14 (70 watts) sodium lights within the protected area, and 3 (250 watt) sodium lights along the protected area boundary will be replaced; and iii) Pitons Management Area -77 (250 watt) and 120 (70 watt) sodium lights will be replaced within the protected area, while 127 (250 watt) and 34 (70 watt) sodium streetlight lights will be retrofitted along the protected area boundary. These protected areas provide habitat to species of fauna that are classified as Critically Endangered (CR), Endangered (EN) and Vulnerable (VU) according to the International Union for Conservation of Nature (IUCN) including Saint Lucian Whiptail (CR), Hawksbill Turtle (CR), Ornate Ground Snake (CR), Semper's Warbler (CR), Green Turtle (EN), Saint Lucia Threadsnake (EN), Whitebreasted Thrasher (EN),Saint Lucia Black Finch (EN),Saint Lucia Oriole (EN), Saint Lucia Viper (EN), St. Lucia Anole (EN), Saint Vincent Frog (EN) and Black-capped Petrel (EN),Saint Lucia Amazon (VU), Black Swift (VU), Olive Ridley (VU) and Leatherback (VU).  

Light pollution is known to cause disturbance to wildlife. In particular, for bats, the artificial lighting at night (ALAN) is known to increase chances of predation on bats while shortening the amount of time available to them for foraging. With regards to certain bird species, ALAN is known to alter the timing of reproduction and the timing of bird singing. Artificial lighting is also known to disorient migrating birds. For certain species of turtles, ALAN might have a detrimental effect on sea turtle reproduction as they often avoid nesting at lit beaches.  

No new streetlights will be installed by the Project in the protected areas, and, thus, the purpose of the study conducted by TSA Ecology was to identify the biodiversity impacts from replacement of the HPS lights with LEDs. The study compared the various parameters between these two types of lighting such as i) illumination (or intensity of light); ii) Correlated Color Temperature (CCT) – color appearance of light emitted by lamps (e.g. warm vs cool); iii) Color Rendering Index (CRI) – ability of a lamp to reproduce colors compared with a natural source and, iv) optical radiation. The study concluded that the replacement of HPS lights will result in a more focused, directional light source (focused on the road surface) and will result in lower illumination level on any surrounding vegetation. Thus, the area of impact from the lighting polls will be reduced with LEDs. Another benefit of the LEDs is that they will not generate ultraviolet or infrared light, avoiding risks to flora and fauna unlike the HPS bulbs. The study has concluded that the retrofitting may actually lead to the net gain of the biodiversity values. In order to optimize the positive effects of retrofitting the study has recommended to install LED bulbs with lower CCT where the Project sites are adjacent to the protected areas, as it was proved by the field studies in other parts of the world that the lighting with lower CCT (2700 Kelvin) has lower effect on the wildlife. As per ESAP , the Project will install the LED lamps with CCT below 2700 Kelvin in the protected areas to minimize any impacts and disturbance to wildlife within these protected areas in line with SaintLucia’s laws and MIGA PS6 requirements. KLED will ensure that the installations will adhere to the consultant’s recommendations and in line MIGA PS 6 requirements.  

KLED will also update the project EMP to ensure that during installation, operations and maintenance, contractors minimize any impacts to flora and fauna in lineSaintLucia’s Laws and MIGA PS6 requirements. Such impacts minimization measures include speed control, restrictions on disturbance and extraction of wild flora and fauna by personnel, prohibition of open fires near natural vegetation and noise control (car horns and machinery) when work is carried out near or in protected areas. 

KLED has a written authorization from the Department of Economic Development Transport and Civil Aviation of the GoSL from March 27, 2020, which approves to proceed with the full implementation of the streetlight replacement program. As per the ESAP, KLED will develop and implement a Stakeholder Engagement Plan (SEP) for the LED installation and O&M stage. The SEP will include the following elements: engagement principles, objectives and criteria, identification, characterization and priority of stakeholders, engagement program including indication of which information should be disseminated (i.e. works schedule, roads closure schedule etc.) and how it will be delivered to stakeholders and the description of grievance redress mechanism. 

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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 

• KLED Environmental Management Plan 

• KLED Social Management Plan 

• Project Biodiversity Desktop Review 

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