Tango Water Project

MIGA has been requested to cover FCC Aqualia’s potential equity, quasi-equity, and/or shareholder loan investments related to the water utilities business of Georgia Global Utilities JSC (GGU).  

GGU is a water utility and renewable energy holding company based in Tbilisi. The scope of the proposed guarantee covers six GGU subsidiaries, including the following existing assets in the Tbilisi, Mtskheta, and Rustavi regions of Georgia (the Project):  (i) 7 water treatment plants; (ii) a wastewater treatment plant near the city of Gardabani; (iii) 141 pumping stations and 84 reservoirs; (iv) 4,300 kilometers (km) of water distribution network; (v) 5 business centers; (vi) 1,700 km wastewater network; (vii) and 4 existing hydropower plants (HPP) (130 Megawatt (MW) Zhinvali (commissioned in 1985), 4.2MW Saguramo (2016), 2.5MW Bodorna (2018), and 12.4MW Tetrikhevi (1955). The Zhinvali reservoir and dam form the city of Tbilisi’s primary storage source of potable water. The Project is not expected to include material construction, but rehabilitation and repair works for existing assets will be conducted. 

The six GGU subsidiaries include Georgia Water and Power LLC (GWP), which is the largest subsidiary and operates the majority of water distribution infrastructure, six water treatment plants, and the Zhinvali, Bodorna and Tetrikhevi hydropower plants. Saguramo Energy LCC operates the Saguramo hydropower plant. Georgian Energy Trading Company LLC is the electricity trading arm of GGU.  Rustavi Water LLC is a small water utility company, which serves customers in Rustavi area. Gardabani Sewage Treatment Plant LLC (GSTP) operates the wastewater treatment plant with the same name, and Georgian Engineering and Management Company LLC is an internal engineering services company.   

GGU issued a Green Bond in 2020, with participating investors including DEG, FMO and ADB. Green Bond Annual Reviews and Impact Reports are published on the GGU website. 

FCC Aqualia is a water management company based in Spain, with operating assets in 17 countries across Europe, Latin America, and the Middle Eastern region.  

The Project is provisionally categorized as B according to MIGA’s Policy on Environmental and Social (E&S) Sustainability (2013). The key E&S issues associated with the Project include implementation of the environmental and social management system, stakeholder engagement, community and worker’s health and safety, biodiversity, and legacy issues associated with the construction of the hydropower plants, including dam safety and cultural heritage. 

While all IFC Performance Standards 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 IFC 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 Resource  

• PS8:  Cultural Heritage 

Expansion or construction activities requiring land acquisition that would trigger PS5 are not foreseen as part of this Project, therefore PS5 is not applicable to this Project. In the eventual case of future land acquisition, GGU will revise its current land acquisition procedures for compliance with PS5 requirements prior to any land acquisition undertaken (as per the ESAP).   

No Indigenous People, as defined by PS7 have been identified in the Project area and therefore PS7 is not applicable to this Project. 

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

• General EHS Guidelines (2007) 

• Water and Sanitation (2007) 

The following documents were reviewed by MIGA:  

• ERM (2020). Environmental and Social Gap Analysis Report 

• ERM (2021). Project Tango: Final Environmental Social Governance Due Diligence Report 

• Sustainalytics (2021). GGU: Annual Review (GGU Green Bond Framework) 

• GGU (2022). Annual E&S Monitoring Report to ADB for the Georgian Green Bond Project 

• Gamma Consulting (2021). Saguramo Hydropower Plant: Environmental Audit 

• GWP (2018). Bodorna Reservoir and Hydropower Plant: Environmental Audit  

• GGU ESMS documentation 

• GGU HR policies and procedures 

• ILF Consulting Engineers (2020). Zhinvali HPP Dam Safety Due Diligence Report.  

In addition to reviewing the above documents, MIGA carried out an E&S due diligence visit on July 4-8, 2022 to GGU and its subsidiaries which included meeting with key E&S staff and management and government agencies, as well as visiting the Project sites and facilities. In addition, an Independent E&S Consultant (IESC) was appointed by Aqualia to conduct Environmental, Social and Governance due diligence for the Project in October 2021.  

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project, and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS.  Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards. 

Key environmental and social (E&S) issues associated with the Project business activities are summarized in the paragraphs that follow. 

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

Environmental and Social Assessment and Management System: 

GGU, has a corporate level Environmental and Social Management System (ESMS), which includes procedures for planning, implementing, monitoring, reporting, communicating, and documenting environmental, social, health and safety (ESHS) aspects of the company’s operation. It adopts several specific management plans to mitigate and manage ESHS risks and impacts. GGU will develop an ESMS Handbook or Manual that references the E&S management plans and procedures associated with the Project with the respective timeframe and budget for the development and implementation of the management plans (ESAP item). The ESMS is designed to facilitate consistent and structured E&S management for all GGU subsidiaries.   

GWP, having larger scale of operations and higher E&S risks compared with other subsidiaries, has developed its own E&S procedures and plans, which are consistent with the corporate ESMS. The other subsidiaries are smaller and adopt the corporate ESMS.  

Policy: 

GGU has an Environmental and Social Policy Framework including a policy statement setting out a commitment to environmental and social risk management, including compliance with applicable Georgian regulation and the Performance Standards and WBG EHS Guidelines. The Policy is applicable to and adopted by GGU as well as the six subsidiaries.     

Identification of Risks and Impacts: 

GGU has an internal ESHS risks and impacts identification process which follows the IFC ESMS Toolkit in terms of risk identification, process mapping, physical mapping and risk assessment.  

For any construction activities, GGU engages independent E&S consultants to conduct an E&S impact assessment (ESIA) if required per the Georgian Code on Environmental Assessment. The consultants are required to ensure that the ESIA and the corresponding E&S management plans comply with applicable E&S laws and regulations. ESIAs have been prepared for the construction and operation of Saguramo HPP in 2015, and Bodorna HPP in 2017, and operation of Zhinvali HPP in 2014, Tetrikhevi HPP in 2014, and Gardabani wastewater treatment plant in 2008.  

These ESIAs contain potential E&S risks of the assets and the proposed measures to mitigate these risks. Upon completion of upgrading/development works, an audit is conducted and submitted to the relevant authority to demonstrate the effectiveness of mitigation measures by reporting how the surroundings and natural environment changed due to Project activities as compared with what was described in the ESIAs. 

A climate risk screening was conducted for the Project site using MIGA’s Climate Risk Screening Tool and supplementary World Bank climate datasets and materials. Based on this information, Tblisi, Mtskheta, and Rustavi regions in Georgia are expected to face an increase in the frequency and severity of extreme weather events under climate change. Since the 1960s, Georgia has experienced increased temperatures of 0.3°C in western areas and 0.4–0.5°C in eastern areas. Increasing temperatures and heatwaves have been reported across the eastern region in Georgia, particularly for urban areas. By the 2090s, the average temperature in Georgia is projected to increase between 1.4°C to 4.9°C above the 1986–2005 baseline, for emissions pathways RCP2.6 and RCP8.5, respectively.  

Climate change scenarios show more extreme rainfall events, concentrated in a short period of time, thereby increasing the potential for flooding and landslides. These hazards could potentially lead to economic losses, interrupt the water businesses, and disrupt water supplies by damaging water supply infrastructure and/or the source of water quality. Given this vulnerability context, financing expenditures related to flood control and prevention systems is crucial. In this sense, GGU will conduct a climate risk assessment for their water business assets (ESAP item), in order to identify any potential exposures to physical climate risks, as well as to determine appropriate measures to reduce these risks and build climate resilience. This assessment will include different climate scenarios, the potential effects on the assets and operations, and an implementation plan to manage and reduce climate-related risks to the project.    

Organizational Capacity and Competency: 

At the GGU corporate level, the overall responsibility for the management of E&S aspects lies with the Chief Technical Officer, who oversees the E&S Division and the Health & Safety (H&S) Division. The E&S Division is composed of the E&S Division Head, the Environmental Supervisor, two Environmental Specialists and one Social Specialist. The H&S Division is composed of the H&S Division Head, and six H&S Specialists.  

At each subsidiary, selected staff from the Technical Department and contractors are also appointed and responsible for E&S management in addition to their technical/operational duties. The appointed E&S staff are trained to supervise E&S related matters on site and to regularly report to the corporate E&S Division. In addition, the appointed E&S staff on site is responsible for supervising contractors at construction sites.  

GGU has established a training center managed by the Human Resource (HR) department. In accordance with the ESMS Training, Awareness and Competence Procedure, E&S trainings activities are conducted regularly for staff with E&S and H&S responsibilities (Competency ESMS Training), leadership positions (ESMS Awareness Training), as well as for new employees and other staff (technical and operational training) at all levels. 

Emergency Preparedness and Response: 

GGU will develop a corporate Emergency Preparedness and Response Plan (EPRP) that covers its subsidiaries, as part of the ESMS (ESAP item). The EPRP will identify contingencies for a variety of potential emergency situations relevant to operations, including accidental leaks and spills, fire, vehicle accidents, natural hazards, pandemic (e.g. COVID-19) and security events (among others). The EPRP will outline the response mechanisms, roles, responsibilities, training and equipment requirements, and internal and external communication mechanisms in case of an emergency. GGU will closely coordinate with external agencies regarding the EPRP to provide early warning and emergency rescue as needed (refer to PS4 for dam safety). 

Monitoring and Review: 

GGU has a monitoring program which includes baseline, compliance, and performance monitoring.  The monitoring program defines monitoring parameters, activities (location, time, frequency), performance indicators, and data collection and analysis. Monitoring is performed by the site-based E&S staff and the corporate E&S management staff through scheduled site inspections. Responsible E&S and H&S staff use checklists to verify ESHS performance and compliance. E&S monitoring and reporting include H&S incidents, E&S inspections/audit, monthly E&S performance, external monitoring (quarterly, annually), and non-conformances. 

GGU also has a corporate level Non-conformance Preventive and Corrective Action Procedure that defines the process for reporting non-conformances, as well as identification and implementation of corrective actions. A non-conformance tracking register (non-conformance log) will be developed to document and track the process of addressing any non-conformance. This will ensure the proper accounting and management of non-conformances (ESAP item). 

Stakeholder Engagement: 

GGU’s corporate Stakeholder Engagement Plan (SEP) defines relevant stakeholders, engagement strategies, responsibilities, grievance mechanism, monitoring, and reporting. The E&S Division, in collaboration with the Communications Directorate, is responsible for external stakeholder engagement, information disclosure and grievance management for GGU and its subsidiaries. The corporate SEP will be updated to include the company’s plans, activities and engagement strategies in relation to informed consultation and participation in line with PS1 requirements (ESAP item).  GGU will develop SEPs for subsidiaries which have specific characteristics and depending on the relevant stakeholders and specific engagement activities for the subsidiaries and their engagement strategies (ESAP item).  

Public consultations and stakeholder engagement are generally conducted as part of the ESIA process for the assets that require an ESIA (e.g. HPPs, wastewater treatment plant). For activities where an ESIA is not required such as water distribution, GWP uses several communication channels to inform customers and the public about planned and ongoing works and water supply restrictions through SMS, TV channels, news agencies, and the company website. 

External Communication and Grievance Mechanisms, Ongoing Reporting to Affected Communities: 

GGU’s External Communication Procedure describes accessible channels (e.g. website, email, phone, social media) to disseminate news, events and announcements, and a procedure for receiving, documenting, and responding to public inquiries.  Although this procedure applies to the subsidiaries, E&S related public inquiries are directed to GGU.  

The corporate grievance redress mechanism described in the SEP will be updated to include the details of the mechanisms and the procedure for accepting and addressing complaints such as roles and responsibilities, communication channels, and timelines for each step of the procedure (ESAP item).  Any complaint/comment can be submitted through boxes in the offices, GGU’s website, e-mail, phone and social media.   

There are multiple channels of communication used by GWP to inform about the planned and ongoing works, duration of projects, location and water supply restrictions, if applicable. These include SMS being sent to customers, TV channels and news agencies and company website.  

PS2:  Labor and Working Conditions 

GGU employs a total of 2,685 staff (as of June 2022), across the holding company and its six subsidiaries. Out of the subsidiaries, GWP is the largest employer. Overall, 323 employees (11.5%) are women.  

Working Conditions and Management of Worker Relationship:  

GGU has a Human Resources (HR) Policy and a Labor Relations Policy, applicable to all GGU subsidiaries and includes a set of procedures that provide a framework for governing working conditions, and workers’ rights and responsibilities. The policies are aligned with Georgian Labor law. 

The Labor Relations Policy details working conditions and terms of employment, such as employment contracts, appointments and termination, record keeping, etc. GGU employees receive an induction on the human resources policies when they sign their contracts and have access to the policies through GGU’s internal intranet system. 

The policies include antidiscrimination provisions and recognize freedom of association and the right to collective bargaining. Worker’s accommodations are not expected to be part of this Project.  

GGU also has a Diversity Policy in place, including commitments to non-discrimination in terms of ethnicity, gender, sexual orientation or age, and a specific policy related to prohibition of sexual harassment.  

GGU’s employee grievance procedure is accessible at all its sites and allows for anonymous grievances. GGU maintains a grievance log that tracks the date of the filed grievance, the type and description of issue, identifies the relevant department and subsidiary, tracks resulting corrective actions, and the date the grievance is resolved and closed out. The mechanism is currently not communicated to contractors and the grievance process does not outline timeframes for acknowledging, investigating, and closing out grievances and there is no process determining whether the complainant is satisfied with the outcome of the grievance. The grievance procedure will therefore be revised to comply with PS2, including making it accessible to contractor staff and strengthened to provide for grievances related to Gender-Based Violence (ESAP item). In addition to the grievance procedure, the anti-sexual harassment policy includes a grievance reporting procedure providing for GBV-related complaints.  

Protecting the Work Force: 

As mentioned above, GGU HR policies align with Georgian law which includes protections against child labor, and in addition the E&S Policy Framework commits to the International Labor Organization core labor standards on Forced Labor and Child Labor.  

Occupational Health and Safety:  

Occupational health and safety (OHS) is managed through the implementation of the GGU OHS Management Plan which is supported by several site specific procedures and work instructions at each subsidiary. The documentation addresses key topics including Risk Assessment; Occupational Health; Review and Audit; Training; Emergency Response; Accident and Incident Reporting; Permit to Work System; and a set of work instructions for various tasks involving OHS risks.  

Implementation of the OHS management plan is overseen and coordinated by the GGU OHS Manager, supported by a team consisting of a Lead Health & Safety Officer and 7 Field Safety Officers across the subsidiaries. Accidents and incidents are tracked and summarized in an annual Health & Safety Report.    

GGU has established a COVID-19 Emergency Response Plan based on WHO recommendations and including for example training for staff, medical screenings, restrictions and guidelines regarding physical distancing, use of Personal Protective Equipment, and monitoring of cases.    

Workers Engaged by Third Parties: 

GGU has a corporate level Contractor Management Plan, which outlines how to manage the risks arising from contractor activities and compliance with GGU H&S standards and HR policies, including the International Labor Organization (ILO) Core Labor Standards. The plan aims to enable project managers at the various subsidiaries to develop a good understanding of the contractual requirements with contractors and the responsibilities of the parties involved and establish a system to monitor contractor activities and compliance with applicable requirements, including E&S provisions. All contractors have to submit a site specific E&S Management Plan to GGU prior to commencement of works. As mentioned above, the GGU grievance mechanism will be revised and make available to contractor staff.  

PS3: Resource Efficiency and Pollution Prevention 

Resource Efficiency:  

GGU has developed water and energy management plans which describe the key objectives to be achieved for efficient water and energy consumption. The Water Management Plan includes a strategy to reduce the overall demand for water to ensure the best use of existing water resources through a more flexible and sustainable supply system. The Plan covers both surface and ground water quality and quantity. There is ongoing work being conducted for the maintenance, rehabilitation and repair of the existing water supply network and the installation of new water connections to end users to improve water efficiency and prevent water losses.  

Electricity needs for GGU are covered by company’s own hydro power plants and from the national grid. The project will not lead to additional GHG emissions during operations. In the contrary, the water and energy efficiency improvements will lead to reduction of the GGU’s carbon footprint. GGU will report on greenhouse gas emissions as part of the annual monitoring to MIGA.  

Pollution Prevention: 

Environmental issues associated with operations of the various subsidiaries include odor control, waste and water management, sludge management, treatment and disposal, water supply and effluent quality. GGU has developed a Spill Prevention and Response Plan that describes the risks and mitigation measures related at each of its subsidiaries.  

The Gardabani Wastewater Treatment Plant is treating between 220,000-440,000 cubic meters (m3) wastewater per day. The Plant received upgrades in 2018 with the installation of new coarse and fine screens, a refurbished primary settlement tank, and a sludge stabilization/aeration process for sludge thickening and reduction of smell at the sludge disposal area.  

No special permit is required for wastewater discharge but wastewater discharges from the Gardabani Plant into the Mtkvari river are regulated by Maximum Permissible Discharge (MPD) levels agreed with the Ministry of Environmental Protection and Agriculture (MoEPA) based on “The technical regulation on calculation of the maximum permissible discharge levels of polluting substances together with waste-water into surface water bodies” adopted by the Government of Georgia (by resolution No. 414 (31.12.2013)). MoEPA regulates five key wastewater components in line with EU regulations; suspended solids and particulates; Biochemical Oxygen Demand (BOD); Chemical Oxygen Demand (COD); total Nitrogen and, total Phosphorus. The Maximum Permissible Discharge (MPD) levels document was developed by GSTP in line with the abovementioned normative act (GoG technical regulation) and is agreed with MoEPA for the period of 5 years (2019 - 2024). Planned improvements to wastewater treatment processes at the Gardabani Plant are expected to resolve non-compliances with Nitrogen and Phosphorus levels. GGU will evaluate the planned improvement options currently being assessed and provide a plan to achieve compliance with applicable limits to MIGA (ESAP item). Compliance with applicable effluent standards will also continue to be monitored daily during operations and reported to MIGA in the Annual E&S Monitoring Report. 

The Project generates both hazardous and non-hazardous waste. Hazardous waste predominantly results from GWP’s and RWC’s laboratory activities. All hazardous waste is disposed of/utilized by a licensed contractor.  Other non-hazardous waste results primarily from Gardabani Wastewater Treatment Plant’s activities, including sludge and flocculation agent (iron trichloride) used in the settlement tank and materials collected by the coarse and fine screens, grit and sand. Screened materials are also disposed of by a licensed contractor on the municipal landfills. Currently the sewage sludge, after stabilization, is removed to nearby sludge drying beds on land owned by GSTP. Improved biological treatment at the Gardabani Plant will generate significantly higher quantities of sludge that will require treatment and options for its use. GGU will evaluate the options currently being assessed in a sludge use study and provide a sludge use/management plan to MIGA (ESAP item). A study of heavy metals concentrations in the sludge that was conducted in 2018, indicated that sludge contained relative low levels that were well within the limits in the EU Directive (86/278/EEC, June 1986) on the protection of the environment and in particular of the soil, when sewage sludge is used in agriculture. GGU is seeking alternatives to sludge disposal with other options, apart from agricultural use including, composting, greening/landscaping, cement kilns, wetlands, biodiesel. 

PS4: Community Health, Safety and Security 

Community Health and Safety   

Impacts on and key risks to community health, safety and security from the Project activities are addressed through existing management plans and control measures. Key community health and safety risks resulting from the Project includes: dam safety; drinking water quality; contamination of water and exposure to hazardous substances, chemicals management (primarily chlorine), contamination from untreated wastewater leaks, security personnel, construction activities, pedestrian and road safety during excavation for pipeline repairs and replacements.  

The Zhinvali Dam was constructed in 1985, has a height of 102 m, and a gross capacity of around 500 million m3. An independent dam safety consulting firm was appointed in 2020 to review the status of the dam and that previous rehabilitation works were completed in accordance with good international industry practice. Several recommendations from the review have been completed by GGU, while some items that require a longer timeframe are still under implementation. This includes for example reconstruction or bypassing of sections of the tailrace that have reduced water passage. GGU will complete the outstanding items and report to MIGA as part of the ESAP.  

Raw water for consumption is treated at the water treatment plants. Both treated and raw input water is tested in GGU laboratory facilities. Georgia national water quality standards are in line with the WHO Guidelines for drinking-water quality: Fourth edition (March 2022). Monitoring data indicate that drinking water is compliant with these standards. At the water treatment plants, community and occupational health and safety management plans are in place with safety equipment including respirators provided for staff who have been trained in its use. The Chlorine tank area is fitted with Chlorine leak detectors, and the building is fitted with water screens to prevent any release of the gas to the surrounding area. 

GGU has a Community Health, Safety and Security Management Plan (CHSSMP) in place as part of the ESMS, based on the requirements of PS4 and includes; infrastructure and equipment design and safety; hazardous materials management and safety; emergency preparedness and response. The CHSSMP also includes related mitigation measures to avoid and manage community risks, including use of signage, technical functioning of machinery, dust suppression, traffic management, selection of access routes. GGU has identified and prioritized high risk areas where the water supply and wastewater networks may be subject to leakage resulting in flooding or damage to the infrastructure or agricultural land. Emergency response teams respond to reported leakages in the system. 

GGU has an internal and external communication system in place in case water supply interruptions are needed for repairs and rehabilitation works. For any planned service outages, TV channels, social media, short message service and public announcements are used to inform clients.  

Security Personnel: 

GGU employs a mix of private and public security services and has a Security Management Plan (SMP) in place applicable to all subsidiaries. The SMP includes for example provisions for screening, training, incident response and principles governing use of force and is based on the Voluntary Principles on Security and Human Rights.   

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources 

GGU has a corporate Biodiversity Strategy (2020) in place which demonstrates its commitment to comply with biodiversity related requirements defined in the ESIAs and other relevant E&S documents. GGU will develop a PS6 compliant biodiversity management framework that specifies the process to identify and assess potential biodiversity risks; describes roles and responsibilities; and guides the drafting of management and monitoring plans  specific to the risks identified (ESAP item). This framework will be adopted by all relevant subsidiaries. 

GWP also developed a Biodiversity Management Plan (2020) which presents GWP’s activities and its potential impacts on the natural environment, nearby protected areas, characteristic flora and fauna in the region, and general actions to protect plant and animal species from the potential impacts of GWP’s activities. GWP will update the Biodiversity Management Plan to incorporate the proposed corporate biodiversity management framework (ESAP item).  

The operations and activities of GGU and its subsidiaries are located mostly in urban areas with modified habitats and these are not located within legally protected areas, except for a portion of Saguramo HPP which overlaps with Saguramo Nature Reserve (a part of Tbilisi National Park). Baseline ecological surveys, which relied on secondary sources particularly fauna data, were conducted for the four HPPs and the Gardabani WWTP, as part of the ESIAs. The assessments were made after Zhinvali HPP, Tetrikhevi HPP and Gardabani WWTP were constructed, thus the sites’ characteristics reflect already altered environments. Monitoring plans for the HPPs and WWTPs will be included as relevant in the biodiversity management framework mentioned above.  

Alien invasive species management for the hydropower stations is considered in the Biodiversity Management Plan. According to studies conducted in 2020, no invasive species were found in the Project areas, nevertheless preventive and control measures for a spread of invasive species have been developed. 

PS8:  Cultural Heritage  

Although material construction activities are not foreseen as part of this Project, GGU has a Chance Find procedure in place defining steps to be followed in case of a discovery of an object or site with cultural heritage value, in line with Georgian regulation and PS8 requirements. 

In addition to the Chance Find procedure, a cultural heritage baseline study and management plan was completed for GGU assets in 2020, designed to guide GGU and its subsidiaries to avoid or mitigate adverse impacts on cultural heritage in the course of its business operations, in case of renovation or refurbishment works for water pipelines or other infrastructure.  

For legacy impacts related to operational assets, GGU will undertake a desktop assessment and identify whether there are any ongoing impacts that need to be managed in line with PS8 (ESAP). 

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

The documentation listed below is available electronically: 

• ESIAs (in Georgian only) for the operational assets are available on GGUs website through the following link:  https://www.gwp.ge/en/Environmental 

• Annual Impact Report and review of the GGU Green Bond Issuance is disclosed on the GGU website through the following link: - https://www.ggu.ge/green-bonds . 

The above documentation is also available for viewing at the following location: 

Georgia Global Utilities JSC 

Environmental and Social Affairs Service 

E-mail: nsulkhanishvili@ggu.ge  

Phone: +995 574 73 88 71  

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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