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€61 million
Environmental and Social Review Summary

Environmental and Social Review Summary

SETRAG Phase II – Gabon  

This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only.

Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content

MIGA has been requested to provide guarantees covering Equity/Quasi-Equity/Shareholder loans (EQS) investments from Meridiam Infrastructure Africa Fund and Meridiam Infrastructure Africa Parallel Fund (together referred to as ‘Meridiam’) of France, into Société d’Exploitation du TransGabonais, or SETRAG (the Project Enterprise or the PE), a limited company incorporated in the Gabonese Republic which serves as the operator of the Transgabonais railway corridor. Meridiam’s investment relates to the acquisition of an equity stake into SETRAG. Further information on the proposed MIGA guarantee is available in the Summary of Proposed Guarantee.

The MIGA guarantee will be used to support the rehabilitation and upgrade program for the Transgabonais railway corridor, with the goal of improving the reliability and availability of the railway line. The program aims at enhancing operational performance, safety and overall quality of service of the railway corridor, including (i) strengthening the railway platform, including realignment through unstable zones, (ii) modernizing the drainage system, (iii) replacing sleepers, (iv) acquiring new rolling stock, (v) refurbishing railway stations and workers accommodations, and (vi) rolling-out new and advanced train control and communications systems (the Project).

In support of these strategic objectives, SETRAG embarked on a rehabilitation and upgrade program (called Plan de Remise à Niveau or “PRN”) over an investment period spanning 2016-24 and split into two phases: Phase I from 2016 to 2020 and Phase II 2020 to 2024. At the end of the PRN program, the railway’s level of service is expected to be restored to 16 trains per day (tpd) from between 7 and 8 tpd currently, and the rail freight throughput is expected to increase to 11 million tonnes per annum (mtpa) by 2025 from 7.2 mtpa in 2019.

The Transgabonais railway is Gabon’s multi-user national railway backbone spanning 670 kilometers (km) between the Port of Owendo (located right outside the capital city of Libreville), and Franceville, Gabon’s third largest city located in the heart of the country’s mining region. The railway runs through natural habitat for about 80% of its length and passes through the Lope National Park (a UNESCO world heritage site) (for 62 km), the Bas Ogooué Ramsar Site (for 56 km), the Chutes et Rapides sur Ivindo Ramsar Site (for approximately 30 km), and the Rapides de Mboungou Badouma Ramsar Site (for 30 km).

The Project is confined to the existing 648 km railway, and a safety corridor 15 meters (m) on either side of the existing railway centerline (30 m in total), plus land already acquired or used for other existing infrastructure and construction materials (sand) extraction. The legal right of way (RoW) for the railway extends 40 m on either side of the centerline of the tracks, but to minimize potential social and environmental impacts, it has been decided to restrict the works area to the 15_m safety/operational corridor. The Project footprint will only be expanded within the RoW to build deviation lines and crossing loops over approximately 85 km. The Project will not result in any new footprint outside of the RoW or habitat fragmentation.

The railway corridor was commissioned in 1986 after over a decade-long construction period and has historically been used to transport mining products, notably manganese ore from the Moanda mine, general freight, passengers, as well as to provide non-rail services such as freight handling and logistics. In 2005, the Government of Gabon (GoG) awarded the concession to SETRAG under a 30-year Concession Agreement (CA). Prior to Meridiam’s investment, SETRAG was wholly owned by Comilog (Compagnie Minière de l’Ogoué), the world’s 2nd largest manganese producer and operator of the Moanda mine, itself majority-owned (63.7%) by the Eramet Group (Eramet), a leading French mining and metallurgy conglomerate. Comilog is not considered an associated facility to this Project as both the railway and mine already exist, and because the railway also transports commercial goods and passengers in addition to mine output.

The International Finance Cooperation (IFC) has been involved in both phases of the PRN program. A first loan was signed in June 2016 (Project # 34400) and the ESRS of the first phase was disclosed on May 12, 2015 (phase I IFC ESRS). The loan for the second phase (Project # 42222) was signed on October 2020 and the ESRS for the second phase disclosed on Feb 2020 (phase II IFC ESRS). MIGA is collaborating with IFC in the second phase of the PRN program (i.e. the Project). MIGA’s ESRS draws from IFC’s ESRS for Phase II and provides updates where applicable.

It is estimated that approximately about 500 workers will be needed for Phase II of the rehabilitation and upgrade program for the Transgabonais railway corridor. Phase II started in March 2020, and as mentioned previously is expected to be completed by mid-2025.


The Project is a Category B under MIGA’s Policy on Environmental and Social Sustainability(2013) consistent with IFC’s categorization of Phase I and II of the program. The MIGA guarantee is directed at the refurbishment of existing assets and infrastructure within an existing RoW which are intended to make the PE and its assets cleaner and safer for staff, communities and the receiving environment. As mentioned earlier, the footprint of the Project will only be expanded within the RoW and Project developments undertaken as part of Phase II are not expected to cause significant adverse environmental and social (E&S) impacts. Key E&S issues include occupational health and safety during refurbishment works, pollution control, provision of potable water to workers, hazardous and non-hazardous waste management, resettlement of informal settlers (approximately 300 individuals physically or economically displaced), community and pedestrian safety, emergency preparedness and response, stakeholder engagement, and impacts on biodiversity.

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

  • PS 1:  Assessment and Management of Environmental and Social Risks and Impacts
  • PS 2:  Labor and Working Conditions
  • PS 3:  Resource Efficiency and Pollution Prevention
  • PS 4:  Community Health, Safety and Security
  • PS 5: Land Acquisition and Involuntary Resettlement
  • PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
  • PS8: Cultural Heritage

No indigenous people will be impacted in the course of this Project; therefore, there are no risks and impacts related to PS7 (Indigenous Peoples).

In addition, the following World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines are applicable to the Project:

  • World Bank Group General EHS Guidelines (2007)
  • World Bank Group EHS Guidelines for Railways (2007)

The following key documents were reviewed by MIGA, among other documents:

  • Rapport de Suivi Annuel (RSA) 2019 pour Bailleurs (Annual Monitoring Report for Lenders, 2019). SETRAG and ERAMET. April 2020
  • Environmental and Social Management Plan documents
  • Projet d’exploitation de sable du fleuve Ogooué. Etudes complémentaires sur la faune et la flore aquatiques: la Raie pastenague et les Podostémacées (Project of sand exploitation of the Ogooué river. Complementary studies on the aquatic fauna and flora: the Stingray and the Podostemaceae). Biotope Afrique Centrale. April 2022
  • Resettlement Action Plan (June 2016)
  • 2016, and 2018 agreements between SETRAG, WWF, the Ministry of Waters and Forests and Gabonese National Park Agency
  • 2017 Rail Operational Safety Audit Report
  • 2017 Fire Safety Audit of railway stations and passengers’ trains
  • 2019 Environmental and Social Impact Assessment (ESIA) of sand extraction in the Ogooue River
  • 2016 abridged ESIA of the sleeper’s plant in Booué
  • 2017 abridged ESIA of the refurbishment project Kango-Franceville
  • 2019 Occupational Health and Safety Management System Audit Report
  • Lenders E&S Monitoring Reports (February 2018, June 2018, May 2019, and September 2019)

Phase I project review

  • Refurbishment project Environmental and Social Audit (January 2015)
  • Environmental and Social Management Plan (March 2015)
  • Biodiversity Action Plan (March 2015)
  • Resettlement Framework (March 2015)
  • Other relevant documents including Eramet Environment, Health and Ethics Policies

As this is a joint project with IFC, MIGA has relied on IFC’s due diligence, supervision and the outcome of IFC’s site visits conducted in January and December 2019 (due to COVID-19 travel restrictions, MIGA was not able to undertake a due diligence site visit). IFC’s due diligence included review of documentation and assessing the progress of the PE in terms of their capacity to oversee and monitor its operations consistent with the PSs and implementation of good international industry practice in line with WBG General EHS Guidelines and WBG EHS Guidelines for Railways. For Phase 1, IFC and other lenders had engaged an Independent Environmental and Social Consultant (IESC), which monitored the Project on a semi-annual basis from October 2017 to June 2019. The same IESC has been engaged for Phase 2 and most recently undertook a monitoring visit in November 2021. The E&S monitoring report was shared with MIGA.

MIGA’s due diligence review considered the E&S management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and, in the E&S 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 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: SETRAG has developed and implemented various components of an Environmental and Social Management System (ESMS) in line with PS 1, which include a set of E&S procedures and it is adequately resourced to manage and oversee: i) compliance with all applicable national laws and regulations; ii) compliance with all environmental licenses required for the different activities; and iii) implementation of the Environmental and Social Management Plans (ESMP). SETRAG will develop an ESMS manual to coordinate implementation of all the different plans and procedures at all SETRAG sites (ESAP action item).


SETRAG is a subsidiary of the Eramet Group which has a Sustainable Development Policy, an Environmental Policy, and an Ethics Charter. As a result of IFC’s involvement in Phase I, SETRAG developed a Project specific E&S Sustainability Policy in line with PS 1.

Identification of Risks and Impacts:

A number of E&S audits and action plans were undertaken during Phase I of the program. Since the railway was constructed prior to the adoption of the National Environment Law (dated August 26, 1993), as part of IFC’s Phase 1 due diligence, in January 2015, SETRAG conducted an E&S Audit of its activities. The key findings, including the need to develop an ESMS and undertake the studies listed below, were addressed through the implementation of IFC’s ESAP for Phase 1. In accordance with the Environment Law and consistent with the requirements of the PS, SETRAG also developed the following E&S studies:

  • Environmental and Social Impact Assessment (ESIA) of sand extraction in the Ogooue River (2019);
  • Abridged ESIA of the refurbishment project Kango-Franceville (2017);
  • Abridged ESIA of the sleepers’ plant in Booué (2016); and
  • Abridged ESIA for workers accommodations in Lastourville, Moanda, and Ndole (2013). 

In 2021, SETRAG also started to develop an ESIA for the refurbishment of the Owendo-Kango section of the line, which includes the realignment works through unstable areas.

As indicated above, the project footprint is entirely within the existing railway corridor and rehabilitation works will be confined to the 30-meter-wide safety corridor. Sources of risks and potential impacts associated with this Project include use of machinery and transportation, presence of workers (one team of up to 100 workers), storage and disposal of hazardous materials including used sleepers, refurbishment of infrastructures, presence of unstable track bed zones/slopes along the corridor, and the presence of informal settlers and informal economic activities within the safety corridor.

The Project is located in a country where the risk of Gender-Based Violence and Harassment (GBVH) is substantial due to the legal context, gender norms and beliefs, and capacity to respond to and manage GBVH issues. In February 2021, SETRAG engaged a consultant to undertake a gender and GBVH risk assessment. The risk assessment included a review of human resource policies and procedures, stakeholder engagement plan (SEP) and grievance mechanism. The assessment also included the risks and impacts to host communities of the Project, including the influx of contractors/migrants, and improvement measures for women safety along the railway corridor, in stations and supporting infrastructures.  Based on the findings, SETRAG is currently developing and will implement a gender and GBVH action plan (ESAP action item). The action plan will include measures such as influx management; railway stations improvement measures (such as safe waiting areas, adequate lighting in parking lots, separate toilets) CCTV; sufficient lightening around family houses; and improvement to existing stakeholder engagement plan and community grievance mechanism that are designed to manage such risks and potential impacts effectively.

Climate change:

The railway corridor spans a region which is expected to see an increase in temperatures and rainfall variability over the near to medium term. Climate change projections indicate that mean temperatures could increase by 1.8 degrees Celsius, and the number of hot days could increase by 25-75% by mid-century. Heavy rainfall events are expected to intensify and become more frequent for several sections of the railway corridor (some sections could see an overall reduction in rainfall totals). The Project includes drainage modernization works which will improve the flood resilience of the railway corridor – these works will include both structural and non-structural interventions such as stormwater drainage infrastructure and operational/maintenance plans for ensuring the system remains effective. A climate risk and vulnerability assessment will be completed to evaluate how long-term trends for rainfall may impact the overall effectiveness of the drainage system (ESAP action item).

Management Programs:

Management plans and procedures ranging from environmental and occupational health and safety (OHS), contractor management, train safety, vehicle safety, hazardous and non-hazardous waste management, spill management, chance find procedure, emergency preparedness and response plan, anti-poaching patrolling, and SEP including grievance redress mechanism have been developed in line with the PS. Some management plans are still in draft version (e.g. wastewater management; security management), and as per the ESAP, SETRAG will develop an ESMS manual to coordinate implementation of all the different plans and procedures at all SETRAG sites.

Organizational Capacity and Competency:

As a result of IFC’s involvement in Phase I and II, the team responsible for E&S management was strengthened and is now composed of about twenty staff reporting to SETRAG’s Sustainability Director – including six staff in the Resettlement Bureau (a social specialist, a data base officer, a GIS specialist, and three field officers) supported by an international resettlement expert, one CSR and gender officer who was hired in August 2021, and 9 staff in the Environment department, including a biodiversity specialist hired in May 2022. SETRAG also has 17 staff in the OHS and Fire safety department, and four staff in the Railway Safety department.Since 2016, there has been a full-time international E&S coordinator responsible to ensure implementation of IFC’s ESAP. In addition, a senior social specialist will be appointed and training will be conducted to strengthen the team on the implementation of both SEP and RAP (ESAP action item). The roles and responsibilities of the above-mentioned departments, and the coordination and communication among departments and with senior management, will be defined in an ESMS manual (ESAP action item). The manual will also include SETRAG’s organizational chart to facilitate efficient communications and reporting lines between all E&S related departments, other departments and management.

The HR department offers a range of training programs. The training plan for 2022 includes training in waste management; International Standards Organization (ISO) 26000 Social Responsibility and 50001 Energy Management System; prevention of soil and water contamination; first aid, OHS, driving safety, and fire safety. Every year, about 100 workers are trained in firefighting and prevention. Topic-specific OHS training (e.g., hazardous materials handling, working at heights, and use of personal protection equipment) is provided to workers annually. Dedicated annual training is provided to Safety Chiefs responsible for the safe movement of trains at the stations and to Regulators who are responsible for the safe operations of trains along the entire corridor. The train drivers and their assistants are subject to continuous training and supervision.

Emergency Preparedness and Response: SETRAG developed an updated Emergency Response Plan (ERP) in November 2020, which replaced the Emergency Preparedness and Response Plan (“Plan Fer”, 2014), and Crisis Management Plan (2016). The ERP covers all SETRAG installations and considers emergency scenarios such as natural disasters, fire, explosions, oil and hazardous materials spills, train accidents, terrorism or vandalism. The ERP, which is in line with PS requirements, includes the identification of areas where accidents and emergency situations may occur, response procedures, provision of equipment and resources, and designation of responsibilities and communication. The ERP, however, still needs to be harmonized with the previous Plan Fer (2014), which is a regulatory document (ESAP action item). A consultant was engaged in May 2021 to undertake this harmonization. SETRAG will implement a corrective action plan to address the consultant’s recommendations.

Monitoring and Review: SETRAG reports monthly on key performance indicators (KPIs) on energy and water consumption, air emissions (e.g. greenhouse gases), hazardous and non-hazardous waste, among others. SETRAG has developed a comprehensive monitoring plan to cover all management plans for the different sites. Relevant information is compiled in a data base (SAFEE) and annual reports are prepared for senior management. Lost Time Incidence Frequency Rate (LTIFR) and accident-free days are compiled in a dedicated database (SAFEE) and reported monthly. Customers and community complaints are also managed and documented. Progress on resettlement is being monitored (see PS 5 section below), and reports are prepared on a regular basis. Complaints related to resettlement are recorded and tracked in a database (SYCOSUR) developed during Phase I.

As part of IFC’s reporting requirements under Phase I and Phase II, the PE provides annual E&S monitoring reports to IFC. As a result of MIGA’s involvement, the PE will also be required to submit annual E&S monitoring reports to MIGA. SETRAG will develop and share with MIGA an updated template for the Annual Monitoring Report (ESAP action item).

Stakeholder Engagement, External Communication, and Ongoing Reporting to Affected Communities: SETRAG is currently implementing a SEP in line with PS requirements that includes the following elements: project description, legal framework, engagement principles, objectives and criteria, summary of previous engagement activities, stakeholder identification, engagement program, timeline, documentation, resources and responsibilities, and a grievance redress mechanism (GRM). The SEP was updated in January 2021 to incorporate the new E&S management structure and the roles and responsibilities of the new social staff that joined the Project in 2020. Updated stakeholder mapping was undertaken in early 2021, the results of which are currently being incorporated into the SEP (ESAP action item). The updated SEP will also incorporate the Interim Advice for IFC Clients on Safe Stakeholder Engagement in the Context of COVID-19 (2020) as needed.

The latest round of consultations, which were carried out in 2020, focused on resettlement activities for Phase II (see PS5 Section below), and included consultation with the committee established to support resettlement of the Owendo market to provide an update; consultation with affected communities on track bed unstable zones to discuss the impacts and mitigating measures; consultation on impacts of Project fencing on affected people and proposed mitigating measures; and consultation with potentially affected people in Ntoum to discuss the Project, census survey, potential impacts and mitigating measures. More stakeholder engagement activities with affected communities and local authorities were planned and conducted in 2021.

Grievance Mechanisms:

The SEP includes a GRM. As a result of IFC’s involvement in Phase I, a database to record and track resettlement complaints was developed and includes a complaint form, a numeric register georeferenced to the location of complainants, and a monitoring system to follow up on the responses. A complaints management procedure (March 2021) has also been developed to support implementation of the GRM. In 2021, SETRAG placed 40 letter boxes at stations along the railway route and at the Owendo site. The purpose of the boxes is to receive comments, complaints, grievances and suggestions. In 2022, SETRAG is planning to appoint a grievance management officer and to pursue its efforts to raise public awareness on the GRM.

PS2:  Labor and Working Conditions

In February 2022, SETRAG employed a total of 1,651 direct employees (among which approximately 17% are women). SETRAG’s organizational structure is composed of 3 levels: (i) managers (c. 18%), (ii) technicians (c. 48%) and (iii) workers (c. 34%).

Human Resources (HR) Policies and Procedures: Human Resources are managed according to the policies of the Eramet Group, which has documented procedures for hiring, selection, disciplinary practices and termination, and terms of employment (wages, benefits, working hours, overtime, rest days, breaks, and leave). Working conditions and terms of employment are specified in the written contracts signed by employees, provided and communicated to employees during induction. SETRAG will undertake a gap analysis of Gabonese Labor Law against PS 2, and update HR Policy and procedures as required (ESAP action item).

Working Conditions and Terms of Employment: SETRAG complies with all national legislation limits related to working days per week, rest days and leave. SETRAG pays above the minimum wage in Gabon. In addition, each employee is eligible to the “Caisse nationale de sécurité sociale” (i.e. CNSS- social security cover) in case of illnesses, work accidents, and retirement. SETRAG also provides supplementary private health and life insurance. Normal working hours are from 07:30 am until 3:30 pm and do not exceed 48 hours a week and 12 hours overtime a week. 

Workers accommodation, in the form of housing is provided at select railway stations.  SETRAG currently has a total of 1023 housing units for staff. Among these dwellings, 508 are currently occupied by SETRAG employees, 359 are occupied by third parties (SETRAG subcontractors’ staff, state agents whose mission is unrelated to the railway, e.g. gendarmes, teachers or others, and local community members) and the remaining are vacant. The SETRAG Housing Unit is responsible for the management and maintenance of the housing stock and the Housing Commission is responsible for allocating housing to SETRAG employees and third parties. During phase I, about 150 houses were refurbished and built in line with guidance from the IFC and the European Bank for Reconstruction and Development (EBRD) Guidance Note on Worker Accommodation Process and Standards (2009); however, most houses date back from the 1970s and need to be refurbished. A four-year renovation plan was developed in August 2021 and will be implemented (ESAP action item). In addition, SETRAG will implement short-term arrangements as needed to provide access to drinking water to staff living in workers’ accommodation units where water is not treated to World Health Organization (WHO) standards (ESAP action item). Gaps related to fire safety requirements (fire extinguisher available in some, but not all housing) were identified during IFC’s monitoring activities, and a fire safety audit of the workers accommodation was undertaken in 2020. The audit identified over 200 corrective actions, which SETRAG is currently compiling into a costed and timebound corrective action plan (ESAP action item).

Workers’ Organization:

SETRAG’s workforce is represented by ten unions with a total of 42 representatives representing most direct workers. According to union representatives, main issues which continue to be raised by staff are availability of potable water and workers accommodation. SETRAG is focusing on improving accommodations and supply of potable water as per the renovation plan. Union representatives are selected every three years and SETRAG enters into collective bargaining with all the unions. The current collective bargaining agreement was negotiated in December 2020, its application started in February 2021and it is valid for an undetermined period of time.

Non-discrimination and Equal Opportunity: As a result of IFC’s involvement in Phase I and II, SETRAG included in its HR Policy, provisions with regards to non-discrimination and equal opportunity. SETRAG  is currently developing a sexual harassment policy and a code of conduct for its staff and contractors.

Retrenchment: SETRAG engaged approximately 200 additional staff in 2021. No retrenchment is anticipated.

Grievance Mechanism:

SETRAG has developed and implemented a workers’ grievance redress mechanism (GRM) consistent with PS 2. However, IFC’s monitoring exercise identified the following areas for improvement: (i) need for a documented procedure for handling complaints; (ii) wider dissemination of the grievance mechanism within the PE to increase awareness of workers; (iii) provisions to be included for anonymous complaints to be raised and addressed and (iv) incorporate mechanisms to handle complaints related to sexual harassment. SETRAG reviewed the induction training package to include information related to the GRM and workers are informed about the GRM at the time of recruitment. The letter boxes that have been installed at stations (see PS1) can be used by employees and contractors to submit anonymous complaints. SETRAG will develop and implement a formal complaint handling procedure (ESAP action item).

Child and Forced labor: SETRAG does not currently have any employees under the age of 20 and will not employ nor permit any contractor to use child labor or employ persons under the age of 18. SETRAG also prohibits the use of forced labor.

Occupational Health and Safety:

SETRAG has an OHS management system which addresses work hazards and risks. Incident / accidents statistics are recorded on a monthly basis and compiled in an annual report submitted to SETRAG’s management. During Phase I, a specific OHS department was created with adequate resources and staff. The team developed a robust OHS management system commensurate with the risks of SETRAG’s activities. Before IFC’s involvement in Phase I, LTIFR was at 8 accidents per million hours (international benchmark rate for the railway sector is 6.5). By 2018, the LTIFR had reduced to 3.7 and continues to be below the international benchmark rate. SETRAG has a medical center in Owendo staffed with three medical doctors and twelve nurses and equipped with a pharmacy, an imaging room, and a laboratory. Many of the railway stations have a nurse on site (nine nurses in total). As part of IFC’s investment in Phase I, an independent review of the OHS management system was conducted against PS 2 and good international industry practice. While there has been some progress and there are many individual plans are in place, they have not yet been integrated into an overall OHS plan. SETRAG will prepare an OHS manual containing all procedures and actions for OHS (ESAP action item). SETRAG has developed and implemented policies and procedures to manage risks associated with COVID-19 including hygiene and sanitation measures, processes for isolation, periodic screening, and sensitization campaigns for staff.

Workers Engaged by Third Parties: SETRAG hires third-party contractors to provide services such as health, water management, electricity production and distribution in railway stations and worker accommodations, security, railway repair and maintenance. SETRAG has developed an internal audit program for all contractors to ensure alignment with contractual requirements and labor laws. Contracted workers have access to SETRAG’s GRM if not available through their own companies.

Supply Chain: SETRAG implements Eramet group’s purchasing policy and has a supplier management procedure (2019) in place. In November 2021, SETRAG had approximately 97 suppliers.

PS3:  Resource Efficiency and Pollution Prevention

Resource Efficiency: SETRAG’s rolling material includes 34 locomotives, 723 cargo wagons, and 41 passenger wagons. SETRAG’s fleet includes also about 153 road vehicles, 10 light vehicles and 55 construction vehicles (on rental and owned by SETRAG). Annual electricity consumption is 4,069,000 kilowatt hours (kWh), and water usage is around 270,000 liters (L). Total annual gas oil consumption from locomotives, vehicles and generators is 11,457,000 L and 78,000 L of gasoline is used for vehicles. GHG emissions are approximately 36,000 CO2 t equivalent per annum. The following actions have been implemented to reduce energy consumption: acquisition of 6 new efficient locomotives, development of a transport plan, and the use of solar panels for lighting in railway stations.

Greenhouse Gases (GHG): GHG emissions are estimated to be approximately 36,000 tonnes of Carbon Dioxide equivalent per year (CO2e/year). GHG emissions accounting will be undertaken on an annual basis and provided to MIGA as part of the Annual Monitoring Report.

Water Consumption: SETRAG provides drinking water to their workforce in all operational areas. Near urban centers, water is provided by the national utility company (Société d’énergie et d’eau du Gabon – SEEG). As a result of IFC’s involvement in Phase I, water treatment systems were upgraded in the towns of Booué, Lopé, Ndjolé and Lifouta. For Phase II, new water treatment systems are planned for the following locations: Mouyabi, Moanda, Mbel, Ivindo and Lastourville. SETRAG has implemented a water monitoring plan and water monitoring is conducted monthly in all locations where SETRAG supplies water through its own installations. 

Pollution Prevention

Air Emissions: Air emissions from the Project include dust during construction and greenhouse gas emissions from locomotive engines and vehicles (discussed above). Dust will be minimized through standard mitigation measures, such as watering roads, covering trucks carrying spoil, and progressively rehabilitating cleared areas.

Wastes: Waste management was identified as a significant issue by IFC during phase I at most SETRAG sites. Families living near railway stations, including SETRAG’s workers, used to burn their waste in open air behind their backyards, and none of the railway stations (except those in urban areas) had a designated area to properly dispose wastes. Under the ESAP for Phase I, a waste management plan was developed for the Booué area, and discussions were held with the different municipalities to address the issue in a collaborative manner. A waste management system in line with PS3 requirements was developed in 2021 and is being rolled out across all SETRAG sites. Waste management improvements have been achieved, including in Owendo where a waste management area is now operational. A waste disposal facility is under construction in Booué.

SETRAG is building adequate sanitary facilities with septic tanks for all refurbished and newly constructed workers accommodations. On the rest of the line, some of the workers accommodation is attached to the national sewerage network, which is managed by the national utility (SEEG) and the rest are equipped with common septic tanks. SETRAG will develop a plan to progressively rehabilitate the remaining septic systems (ESAP action item).

Hazardous Materials Management: In 2017, SETRAG conducted an assessment of legacy contaminated areas which included identification of contamination sources, characterization of soil and groundwater contamination. SETRAG continues to rehabilitate contaminated sites, and installed oil separators (in Owendo, Booué, and Franceville) in line with IFC’s ESAP for Phase I. It also mandated a consultant to develop an assessment and remedial action plan for 23 contaminated sites. SETRAG developed hazardous materials transport and spill management procedures, a hazardous materials management plan and remedial action plan and is initially focusing on 9 priority sites. Implementation of the plans is ongoing.

While all wooden sleepers are now being replaced by new concrete ones, creosote has been used as a wood preservative for the existing sleepers, and in 2016 SETRAG conducted a study to assess creosote content in old sleepers in order to analyze disposal options. As part of the Project, approximately 25 000 tons of contaminated sleepers will be replaced by concrete sleepers and disposed. As part of the options recommended by the study, incineration field testing was conducted and an action plan was developed in 2018, including engagement with the Ministry of Environment, identification of crushing equipment, development of safe transport and storage procedures, and identification of storage sites. However, incineration testing showed that emissions values exceeded guidelines values for furans and dioxins due to low heating capacity. Other alternatives are being explored by a dedicated working group established in September 2020. SETRAG is currently in the process of completing feasibility studies to explore other options to dispose of used creosote contaminated sleepers (ESAP action item).

During Phase I, manganese storage was observed along the railway in Booué. The external E&S consultant responsible for project monitoring confirmed that adequate containment was in place and risks of contamination were negligible.

Pesticide Use and Management:

Vegetation control is done by daily workers along the railway. SETRAG does not currently use herbicides or pesticides at any of the sites.

PS4:  Community Health, Safety and Security

Community Health and Safety: In Gabon, train safety is regulated by the Train Safety Regulations (2011) (“Règlement général de sécurité”). Freight and passenger train safety is mainly linked to management of train movement, train driving, railway and train maintenance, and overall safety management systems.  Detection devices, referred to as “Hot Box” to detect wheel overheating are installed in three different locations along the railway.

Level crossings (where the railway crosses roads) are high risk accident locations for railways. An important component of the PRN program is focused at mitigating this risk. IFC’s due diligence of Phase I, identified that many crossings did not have proper signage and/ or barriers. During Phase I, safety walls (approximately 3 km) and three pedestrian overpasses were built, six level crossings were equipped with safety barriers and manned control posts. In addition, railway safety awareness campaigns were undertaken in densely populated areas. During Phase II, an additional 25 km safety walls, refurbishment of 28 level crossings and building of 5 pedestrian overpasses are being planned.  

SETRAG conducted an audit of its rail operational safety procedures and their implementation in Phase I. One of the audit’s recommendations was the creation of the Railway Safety Department, which was established by the PE in 2017. SETRAG will continue addressing the audit’s recommendations and reinforce the implementation of its railway safety management system (ESAP action item).

As previously mentioned, SETRAG carries out periodic safety awareness campaigns and in 2018 – 2019 hired 79 outreach officers to cover 48 schools along densely populated areas. In addition, pedestrian safety communication materials were also developed and used, including comic strips, posters in railway stations, TV ads on train safety and others. SETRAG developed a comprehensive communication and community safety awareness plan late 2020. Two safety awareness campaigns for schools were rolled out in February and December 2021.

SETRAG has put in place specific measures related to COVID-19 in stations and on trains, including enhanced cleaning and sanitation, communication on safety measures through audio messages, posters and flyers, as well as temperature screening of passengers.

Infrastructure and Equipment Design and Safety: A Fire Safety team of 8 people is in place along the line, and half of the team is based in Owendo. In addition, approximately 20% of staff are trained in fire safety across all of SETRAG’s facilities, with about 300 staff trained each year. As required under IFC’s ESAP for Phase I, a Fire Safety audit in line with the French Fire Safety standard was conducted in 2018, which included the four main railway stations and passenger trains. Recommendations included the following: equipping railway stations with fire resistant floors, smoke evacuators, adequate emergency lighting, fire extinguishers and fire hydrants and refurbishing of emergency exits in some of the passenger trains A timebound corrective action plan will be developed and implemented (ESAP action item).

Security Personnel: Following a decree in 1978, a trained police unit (62 staff) was instituted in Gabon for the railway with the same attributions and powers as judiciary police. These agents are regularly trained in fire safety, self-defense, ethics, use of force, Human Rights, anti-poaching patrolling, etc. SETRAG also engages security contractors to protect SETRAG premises in Owendo (60 staff), and throughout the railway corridor (40 staff).

SETRAG conducted a security risk assessment late 2020 and is developing a security management plan. SETRAG ensures that the contracts with its security providers include adequate provisions related to vetting of personnel, training, procedures in the event of any incident or alleged violation to ensure effective oversight and accountability for the security personnel. SETRAG will also develop a policy on the use of public and private security forces (ESAP action item).

PS5: Land Acquisition and Involuntary Resettlement

General: SETRAG has developed a Resettlement Framework (2015) in line with PS 5 that guides the resettlement process, eligibility criteria and compensation framework to be implemented for affected households that will be economically and/or physically displaced. As required under the ESAP for Phase I, in 2016 a Resettlement Action Plan (RAP), including a grievance mechanism, was developed for the first 15 km of the rail network in line with requirements of PS 5. The RAP identified gaps between PS 5 requirements and the relevant Gabonese legal requirements and described how such gaps are to be handled; the RAP requires that compensation for loss of assets is made at full replacement value, treatment of informal users and settlers along the railway corridor is consistent with PS 5, vulnerable households are identified and monitored, no forced evictions can occur and affected households and their representatives are properly consulted prior to being displaced. The RAP incorporates appropriate monitoring arrangements to ensure that affected persons receive the entitlements and support which they are eligible for.

Community Engagement: During development of the 2017 RAP, the PE implemented a process of informed consultation and participation (ICP) for the affected households and communities. The first round of consultations was held in May 2015 and involved key stakeholders (village chiefs and other local authorities, men and women of the affected communities). Between September 2015 and February 2016, eleven meetings were organized with institutional stakeholders (Department of Urban Planning, Ministry of Environment, Water and Electricity Utility Company, and the Resettlement Steering Committee) to present and discuss the project and its timeline, PS 5 requirements,  and the need for a second census and socio economic survey (to update and refine the initial census of people present within SETRAG’s concession and legal right of way in 2012), the eligibility criteria and compensation for the affected people. In March 2016, radio announcements, newspaper ads and outreach agents were used to inform communities about the upcoming census and socio-economic survey followed by a second round of consultations. The key objectives of the consultations were to present the Project, the upcoming census and socio-economic survey, the resettlement program, collect feedback and consult on opportunities and challenges. The meetings were attended by local authorities, associations, women, men and youth representatives. The census and socio-economic survey were also conducted in March 2016. Since July 2018, more than 30 meetings were held to ensure ongoing information and participation of Project Affected Persons (PAP).

Grievance Mechanism: All the affected people are provided with ongoing information and participate during the implementation phase and have access to the grievance mechanism. SETRAG monitors, documents and reports on all consultations carried out with affected people. A total of 173 grievances were received since 2018, the vast majority of which relate to the resettlement process. Approximately 60% of grievances have been closed to PAP satisfaction. Most common complaints relate to people not being present at the time of census, and asset owner not properly identified.

To date, the IFC and the external E&S consultant consider that the resettlement process implemented so far is deemed in line with requirements of PS 5 on adequate compensation and stakeholder engagement. The SETRAG Resettlement Bureau (including one social specialist, one data base officer, one GIS specialist, and three field agents) is supported by an international resettlement expert. The team will be reinforced in 2022, as SETRAG will appoint a senior social specialist and continue building the team’s capacity on the requirements of PS 5 (ESAP action item).

Resettlement and Livelihood Restoration: Physical and economic displacement was required for both Phase I and Phase II. An initial census of project affected persons (PAPs) was carried out in 2012, which included all people present within SETRAG’s concession (including Phase I and Phase II) and legal RoW (80 m buffer) and identified a total of 989 people. It was then decided to undertake works only within the 30 m safety corridor, so a census carried out in 2016 focused on the safety corridor in the most populated areas (first 15 km and the Nkoltang area). The number of people to be physically and economically displaced in these areas was determined to be respectively 291 and 200 individuals (out of which 29 individuals were considered vulnerable). SETRAG conducted additional surveys to update the census data from 2016 before starting resettlement in 2019. As of December 2021, for Phase I, 18 individuals were physically displaced and compensated, and 450 individuals (e.g. farmers, shop owners, and owners of fruit trees and gardens) were economically displaced and compensated, in line with PS 5 requirements. The higher number of economically displaced PAPs is due to a request by the Owendo Mayor’s Office to include all merchants operating in the same market (Owendo) to be displaced, i.e. including those located beyond the 30 m safety corridor, in order to avoid conflicts. In 2018, the 196 merchants operating at the Owendo market were compensated and displaced to a temporary installation. It was initially proposed that SETRAG build a new market for these PAPs, however the site selected by SETRAG has not been approved by the Owendo Municipality. Acknowledging the need to provide additional support to the Owendo market PAPs towards livelihood restoration, SETRAG has prepared an alternative strategy, which is being reviewed by the Lenders. All displaced people have been subject to a socio-economic survey and another survey will be carried out one year after displacement to ensure that livelihood or income levels are at least restored, and corrective actions are implemented if necessary (ESAP action item).

The rest of the railway corridor is sparsely populated and SETRAG will seek to avoid significant resettlement. Based on currently available information, it is expected that Phase II will require the physical displacement or economic displacement of approximately 300 individuals. To update the 2016 RAP and to address any gaps in implementation of the 2017 RAP, a Resettlement Policy Framework (RPF) has been developed and is disclosed together with this ESRS. Based on the RPF, SETRAG will develop specific RAPs or Livelihood Restoration Plans (LRP) for the sections of the railway where displacement is necessary, or where people have re-occupied the area due to the time elapsed since the census. The RAPs/LRPs will be developed in a phased manner in line with the sequencing of project works over the next 3 years (ESAP action item). The first RAPs and LRPs being developed under the RPF are for: (i) construction of the wall and footbridge at Ntoum (63 economically displaced individuals); (ii) deviations from the railway line in unstable areas at Andem (16 economically displaced individuals); and (iii) construction of the wall and footbridge at Lastourville (121 economically displaced shop owners).

A mid-term and a completion audit will be conducted by independent resettlement consultants to verify that the objectives of each RAP/LRP have been met. If it is identified during the completion audit that affected people were not able to replace their living conditions and/or restore their livelihoods, SETRAG will implement additional compensation measures as required to ensure the outcomes of the resettlement process are consistent with PS5 requirements (ESAP action item).

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

Gabon is very rich in terms of biodiversity, with significant forest cover and a high rate of species endemism. The railway traverses four main ecoregions:  Central African Mangroves, Congolian Coastal Forests, Northwest Congolian lowland forests and Western Congolian forest-savannah.

As mentioned in the Project Description, the railway runs through Natural Habitat and four protected areas: the Lope National Park (a World Heritage Site), the Bas Ogooué Ramsar Site, the Rapides de Mboungou Badouma Ramsar Site, and the Chutes et Rapides sur Ivindo Ramsar Site. Based on IFC’s due diligence during Phase I, Critical Habitat is triggered along parts of the railway, mainly overlapping with protected areas, and due to the presence of Critically Endangered (CR) and Endangered (EN) species and/or restricted-range species.

As discussed already, the Project entails refurbishment of existing infrastructure within an existing impacted corridor (i.e. Modified Habitat), thus no additional footprint on Natural Habitat or new adverse impacts on biodiversity are anticipated with the implementation of good practice management system procedures. Approximately 62 km of the railway line passes through the Lope National Park. The railway line (with associated baseline biodiversity risks and impacts) existed more than 20 years before the inscription of the park as a World Heritage Site. The Project does not include any footprint expansion in the World Heritage Site. The Project is also not expected to lead to measurable adverse impacts on Critical Habitat.

During Phase I, SETRAG drafted a Biodiversity Action Plan (BAP), which included a Critical Habitat Assessment (CHA), as part of the project impact identification process in consultation with the Gabonese National Park Agency, the Ministry of Water and Forests responsible for anti-poaching patrolling, and World Wildlife Fund. The BAP, disclosed with the Phase I ESRS, incorporates management measures to minimize the impact of the railway on protected areas, in particular the Lope National Park, and to achieve Net Gain for Critical Habitat along the corridor.  The CHA and the BAP will be updated with the support of a biodiversity specialist consultant to incorporate the Phase II works, including assessment and, if needed, management measures related to the Chutes et Rapides sur Ivindo Ramsar Site and the measures related to sand extraction operations (ESAP action item). A Terms of Reference has been drafted for this update work. SETRAG will also hire a senior biodiversity specialist to oversee the implementation of the BAP (ESAP action item). The International Union for Conservation of Nature (IUCN), which is the advisory body on nature to the World Heritage Convention, will be consulted during the development of the revised BAP.

As part of the ESAP agreed with IFC, in 2021, SETRAG completed a Critical Habitat Assessment and Biodiversity Impact Assessment for the sand quarry operations in the Ogooué River. The studies conclude that the sand extraction site provides Critical Habitat for five EN and/or restricted-range species of aquatic plants (Podostemaceae) and one CR freshwater stingray species (Fontitrygon ukpam). Environmental DNA (eDNA) samplings indicate that a new Dasyatis stingray species (different from Fontitrygon ukpam) may also be present in the Ogooué River. As per the studies, the sand extraction operations are not anticipated to result in any significant impacts on the habitat or on the species of biodiversity value, provided that adequate management measures are implemented. The measures identified in the biodiversity impact assessment to prevent, minimize and mitigate potential impacts will be incorporated into the Environmental and Social Management Plan for sand extraction and will be implemented prior to the sand extraction campaign in summer of 2022 (ESAP action item). In addition, mitigation measures to achieve Net Gain for the six Critical Habitat triggers will be developed and documented in the updated BAP.

Since 2008, SETRAG has in place an agreement with a non-governmental organization and the Ministry of Waters and Forests to collaborate in anti-poaching patrols in the railway corridor; to undertake awareness raising of SETRAG staff, train users, and local communities about wildlife species; and to carry out patrols of trains, workers’ camps, railway stations, and associated facilities. Bush meat (i.e. illegal venison) confiscated during those anti-poaching patrols is monitored and documented. The collaboration focuses also on developing procedures in case of train collisions with wildlife, providing accommodations to National Park wardens to facilitate their work, and providing a train to develop nature tourism. Potential net gains of biodiversity values will be delivered through these joint efforts, with specific actions to be detailed in the updated BAP. A revised action plan for collaborating with the National Park Agency is currently under discussion, and SETRAG is also planning to develop and implement agreements with other stakeholders to further control and mitigate illegal bush meat hunting and traffic of wildlife products, and to prevent collision of trains with wildlife (e.g. NGOs, other Gabonese authorities).

PS8: Cultural Heritage

A chance find procedure is available and is being implemented by SETRAG. In addition, it was identified during community consultations that a cultural heritage site would be affected by the railway line deviation works in an unstable area at Andem. The site is a sacred Ceiba tree used by male members of a local community to perform rituals. It is considered to be non-critical and replicable, as the community indicated that the tree could be cut down and the sacred site moved to another location to be selected by initiated community members, provided that a ceremony is performed. The ceremony was conducted and SETRAG provided compensation to the affected community in 2020.

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

The following listed documentation is available electronically as PDF attachment to this ESRS at

For additional information on the Project, please contact:

  • Isabelle Teboul, Sustainability Director – SETRAG

Address: P.O. Box 2198, Libreville, Gabon

Phone: (+241) 11 70 86 09

Fax: 241-01-70-01-06



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