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Transgabonaise Road

€67.5 million
Environmental and Social Review Summary

Environmental and Social Review Summary

Transgabonaise Road: Stage 1A – 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 and shareholder loans (quasi-equity investments) from Meridiam Infrastructure Africa Fund II SLP and Meridiam Infrastructure Africa Parallel Fund II SLP (jointly referred to as ‘Meridiam’), for investments into Société Autoroutière du Gabon (SAG or the Project Enterprise or PE) in Gabon, for a period of 20 years. SAG is tasked with the design, construction, financing, operation, and maintenance of an existing 93-kilometer (km) section of the Transgabonaise road in Gabon, from Libreville at km point (KP) 12 to Nsilé at KP 105 (the Project). The Summary of Proposed Guarantee for the Project is available here.

The Transgabonaise road owned by the GoG is an 828 km road, that connects Libreville (the capital and coastal city) and Franceville (3rd largest Gabonese city) and constitutes a major road axis across Gabon, connecting national roads (route national – RN) RN1, RN2, RN3 and RN4. Rehabilitation of the Transgabonaise road is planned in three stages: stage 1 from Libreville (KP 12) to Alembé (KP 248), stage 2 from Alembe (KP 248) to Mikouyi (KP 626) and stage 3 from Mikouyi (KP 626) – Franceville (KP 814). The MIGA guarantee is directed to the rehabilitation of stage 1A of the Transgabonaise road from KP 12 to KP 105. Road rehabilitation of the subsequent stages (stage 1B, 2 and 3) are not included in MIGA E&S due diligence. Originally a public road, Transgabonaise will become a toll road after rehabilitation. SAG will operate the toll gates.

Stage 1A rehabilitation activities consist of: (i) KP 12 – KP 24 2x2 lane refurbishment; (ii) KP 24 – KP 40 2x2 lane widening; (iii) KP 40 – KP 105 2x1 lane refurbishment; (iv) construction of three toll plazas at KP 20 (Bikele) 2x6 lanes, KP 55 (Ntoum) 2x3 lanes, and KP 96 (Kango) 2x2 lanes and the associated operating and intervention centers; (v)  repairs of four existing bridges and construction of a new 20-meter (m) bridge; (vi) installation of fiber optic cables from toll plaza 1 to 3; and (viii) installation of public lightning along the 2x2 road section. Construction activities include earthworks, upgrading the drainage system, pavement, safety and signage installation. The road rehabilitation works depend on the state of deterioration of the various sections of the road and traffic projections. The right of way (RoW) of the road is minimized as much as possible and within the public road domain RoW of 60 m . Some works, such as the development of toll plazas, may extend beyond the public domain of the road resulting in the creation of a new RoW.

SAG appointed Afcons Infrastructure Limited (Afcons) as the Engineering, Procurement and Construction (EPC) contractor and construction activities between KP 24 to KP 105 started in June 2021. The works are expected to be completed by Q2 2024.  SAG is in the process of appointing an EPC contractor to undertake rehabilitation works from KP 12 to KP 24, construct the three toll plazas, repair existing bridges and build a new bridge up to KP 105. The EPC contract award is expected by Q1 2024. Codalec was the company appointed in 2021 to move the electricity distribution lines and associated poles related with road widening works between KP 24 and KP 40. The work by Codalec was completed in 2022. The EPC contract for rehabilitation works from KP 12 to KP 24, construction of toll plazas and repair/ construction of bridges is from KP 12 to KP105 however for purposes of this ESRS, the EPC contract will be referenced as 'EPC for KP12-24’ or the ‘new EPC’ to avoid confusion with the Afcons EPC contractor responsible for the rehabilitation of the road between KP 24-105.

Additional temporary components of the Project during construction, include the following: (i) construction camps at KP 50 Base camp (~160 bed capacity), KP 95 (~15 bed capacity) and at Makora quarry (~50 bed capacity). An additional construction camp may be required for activities related to KP12- KP 24 works, location is still to be determined; (ii) two asphalt plants, batching plant, wastewater treatment plant, mechanical workshop, material storage area, fuel dispensing area, quality control laboratory unit and one electrical distribution station located within the KP 50 Base camp; (iii) the Makora quarry and crushing plant located in the department of Komo-Kango; (iv) 2 existing borrow pits at KP 40 (used for the Base Camp construction and no longer in use, pending restoration) and KP 52 (in use), a third borrow pit is under selection; and (v) spoil disposal sites.

The Makora quarry is owned by the Ministry of Defense, which issues licenses to different entities to explore and exploit. The quarry has been in operation for the last 25 years. Afcons was granted an exploration license by the Ministry of Defense on July 16, 2021 to explore the quarry, and initiated quarry activities in August 2021. There are currently two other companies also exploiting the Makora quarry. The Makora quarry is approximately 5 km from Makora village and 26 km south from Kango. Subsequent to crushing activities undertaken at the quarry, aggregates are diverted from the quarry on barges on river Bokoué to KP 95.

The Project is classified as Category A under MIGA’s Policy on Environmental and Social Sustainability (2013). The key environmental and social (E&S) risks/impacts associated with the Project during construction and operation include: (i) the economic displacement of approximately 1535 Project Affected People (PAPs), as well as the physical displacement of 94 PAPs; (ii) biodiversity (presence of Critical Habitat-triggering species, including forest elephants at KP 84 and KP 101 and chimpanzees, along KP 104-105); (iii) labor and working conditions of workers (including the potential for gender based violence (GBV); (iv) community health and safety, including traffic safety, GBV and potential community unrest related to the establishment of tolls; (v) pollution related impacts such as generation of hazardous and non-hazardous waste, noise and air pollution; and (vi) cultural heritage, including displacement of a church and graves.

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
  • PS 8: Cultural Heritage

Performance Standard 7 on Indigenous Peoples is not applicable as the socio-economic baseline studies undertaken for the Environmental Social Impact Assessment (ESIA) did not identify Indigenous Peoples along stage 1A of the Transgabonaise road.

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 Toll Roads (2007)
  • WBG EHS Guidelines for Construction Materials Extraction (2007).

The IFC / EBRD guidance note Workers’ accommodation:  processes and standards (August 2009) was also considered in the context of the workers accommodation camps.

The following key documents were reviewed by MIGA:

  • Environmental and Social Due Diligence associated with the KP12-KP105 segment of the Transgabonaise highway, Gabon, Ibis, December 2022
  • Projet de reamenagement et d’exploitation de la transgabonaise - Etude d’Impact Environnementale et Sociale (EIES) à destination des bailleurs Etape 1a : PK 12 – PK 105, Artelia, June 2022
  • Rapport d’Audit de Securite Routiere PK24 au PK 105, Studi International, March 2022
  • Reglement Interieur pour Societe Autoroutiere du Gabon (Draft), undated
  • Reglement Interieur – Afcons Infrastructure Limited Gabon, October 2020
  • Afcons E&S Management Plans (Undated)
  • SAG E&S Management Plans (Undated)
  • Rapport de Cloture Phase Test – Projet plan de restauration des moyens de subsistence (2022)
  • Projet de reamegagement et d’exploitation de la transgabonaise – cadre politique de reinstallation, Artelia, January 2021
  • Plan de restauration des Moyens de Subsistance (PRMS) Transgabonaise PK 24 – 105, July 2021
  • Plan d’Action pour la reinstallation RN1 Troncon PK 24 au PK 50, INSUCO, July 2021
  • Plan d’Action pour la reinstallation RN1 Troncon PK 50 au PK 75, INSUCO, July 2021
  • Plan d’Action pour la reinstallation RN1 Troncon PK 75.1 au PK 105, INSUCO, July 2021

In addition to reviewing the above documents, MIGA carried out a site visit in March 2023. The visit included driving the length of the Project and a tour of the Base camp at KP 50 including the asphalt plants and batching plant. MIGA also visited the existing borrow pit location as well as sites along the road where works were ongoing. Meetings were held with SAG and Afcons staff, including staff responsible for environment, health and safety, human resources. The MIGA team also visited and met with community representatives from five affected communities. The team also met with consultants supporting the Project in the livelihood restoration program and in relation to management of gender-based violence risks.  

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: SAG developed and is implementing an Environmental and Social Management System (ESMS) Manual in line with PS 1, which sets out SAG’s operating framework to manage and oversee compliance with its environmental and social (E&S) commitments, applicable national laws and regulations, environmental license conditions, and Environmental and Social Impact Assessment (ESIA) commitments.

Policy: SAG developed the following E&S policies: (i) Environmental Policy (2021); Environmental and Social Governance Policy (2021), Health and Safety Policy (2021); Social Policy (2021). Afcons operates under a separate Occupational Health, Safety and Environmental Policy (2018) and a driving policy (2022) The new EPC contractor for KP 12 – 24 will be required to develop and implement Project specific E&S policies in response to commitments captured by existing SAG policies and cascade the Project specific E&S policies to its sub-contractors and oversee their implementation (ESAP #1).

Identification of Risks and Impacts: An ESIA was prepared in June 2022 covering Stage 1 KP 12 – KP 260 of the road for statutory purposes. Also in June 2022, the ESIA was revised and amended to focus on the Project; Stage 1A (KP 12 – KP 105) for the Lenders and submitted and approved by the environmental authority - Direction Générale de l'Environnement et de la Protection de la Nature (DGEPN) on August 2022. The ESIA was prepared in line with PS 1 requirements.

The temporary Project components, including the three construction camps (KP 50 Base camp (including ancillary infrastructure), KP 95 camp and Makora quarry camp), the Makora quarry and crushing plant were subject to Environmental Impact Notices and Hazard studies in line with local legislation. Additional auxiliary facilities required by the new EPC contractor will be subject to an ESIA in line with PS 1 requirements (ESAP #2). Site closure/ rehabilitation management plans will be developed for the auxiliary facilities (camps, spoil disposal sites, borrow pits) by Afcons and the new EPC contractor once activities are completed or ceased (ESAP # 3).

A cumulative impact assessment (CIA) was undertaken as part of the ESIA. The CIA takes into account known, confirmed and planned projects in the short to medium term (2 – 10 years) that may interact with the road development. The assessment considered cumulative impacts generated from 6 projects including three hydropower plants, one water abstraction facility, one educational establishment and one airport. The ESIA includes recommendations for SAG to contribute to the development of a regional development plan undertaken by the Municipalities.

An assessment of alternatives was also undertaken as part of the ESIA which included the no-go alternative, project conception alternatives, pavement design and materials alternatives, and location alternatives associated with the three toll plazas. An environmental assessment for the new borrow pit location and spoil disposal sites will be undertaken taking into account E&S considerations and potential alternative locations (ESAP#4).  

Climate change is likely to increase the frequency and intensity of precipitation in Gabon; on average, the region experiences 3,000 mm of rainfall each year and future projections indicate a rising trend for precipitation. Mean temperatures are also expected to increase to +1.6°C by 2050. This poses high climate risks in the region, and in the absence of mitigation, could present challenges to the Project. To properly manage climate-related risks, culverts have been verified for a 10-year return event, with no overflow for 50-year return events. This verification confirms that the planned roads could withstand flood intensities and occurrences without having the roads being overflowed by 1–in-50-year events. Additionally, in accordance with the standards recommended for tropical climate zones, the design of pavements would use a set temperature threshold for asphalt mixes to avoid cracking and other deterioration of roads exacerbated by such climate hazards.

To manage the risk of gender-based violence (GBV) in communities surrounding the project, and in the workplace within construction sites or workers camps a Gender Action Plan has been prepared by Afcons as part of its ESMS which contains measures to prevent GBV (e.g. minimizing influx by promoting recruitment of local workers); report (proper handling of GBV complaints reflected in the Mechanism of Requests and Complaints Management Plan); respond (partnerships with NGOs); and monitor GBV risks (monitoring plan in place). Recommendations to monitor progress in implementing these measures are reflected in PS2 and PS4.  SAG will prepare a Gender Action Plan to address GBV risks and require the new EPC contractor for KP 12 – 24 to develop and implement a Gender Action Plan (ESAP #5).

Management Programs: SAG has developed a set of management plans as part of its ESMS manual in line with the Framework Environmental and Social Management Plan (FESMP) for the construction and operations phase included in the ESIA. Afcons has also developed a set of management plans in accordance with the FESMP, reviewed and validated by SAG. The management plans range from Occupational health and safety, air emissions, dust and noise management plan, hazardous and non-hazardous waste management, hygiene health and safety plan for communities among others. The EPC contractor for KP 12 – 24 (when appointed) will also be required to develop management plans and procedures in line with the FESMP (ESAP #6). SAG will review and update the management plans for the road operations and maintenance respectively prior to the commencement of operations (ESAP #6).

Organizational Capacity and Competency: SAG’s organizational structure includes: (i) Head of Environmental, Social and Governance (ESG) operations, reporting directly to SAG’s Chief Executive; (ii) E&S manager; (iii) four community liaison officers (CLOs) for KP 12 – 24, KP 24 – 40, KP 40 – 75, KP 75 – 105; (iv) Monitoring and Evaluations officer; (v) grievance mechanism project leader; and (vi) two community Health Safety and Environment (HSE) officers. Per ESAP #7 SAG will recruit an additional CLO to support stakeholder engagement activities and fill all vacant E&S positions as per its organogram and maintain and adequate team throughout MIGA’s guarantee.

Afcons, as the EPC contractor, has appointed a HSE Manager, reporting directly to the Project Manager. The HSE manager is supported by one HSE engineer and eight HSE officers deployed along the working zones of Stage 1A of the Transgabonaise road, at the KP50 base camp, at KP 95 camp and at the Makora quarry. A female CLO was recruited in March 2023. SAG will also review the organizational capacity of the new EPC contractor and appoint as a minimum an HSE Manager, HSE officers to achieve a ratio of 1 HSE officer for 50 workers and CLOs (ESAP #7). SAG will validate a training plan and program developed by the new EPC, including training related to preventing and addressing GBV, which will be cascaded to the EPC contractor and sub-contractors (ESAP #8).

Emergency Preparedness and Response: Afcons developed an Emergency Preparedness and Response Plan (EPRP) in line with SAG’s ESMS manual requirements. The EPRP includes descriptions of potential emergency scenarios related to construction as well as natural disaster and project-induced emergency situations and a description of the roles and responsibilities of Project personnel, available local services that can support in an emergency. The EPRP 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 EPRP however does not capture emergency scenarios related with fluvial transportation of equipment and materials from the Makora quarry to KP 95, emergency events during nighttime and emergency drills involving members of the local villages along the road and at Makora quarry. The EPC contractor will review and update the EPRP which will be supported by the lessons learnt from emergency drills covering a range of different scenarios (ESAP #9). The new EPC contractor will also be required to develop and implement an EPRP.  The emergency drill reports will be shared with MIGA as part of the Annual Monitoring Report (AMR) submission. SAG will develop and implement an EPRP for operations (ESAP #9).

Monitoring and Review: SAG’s ESMS includes monitoring and reporting provisions in line with the Project’s ESIA commitments. Monitoring requirements are captured in the individual management plans prepared by Afcons. Monthly internal audits and reporting are conducted by Afcons to review E&S compliance of the Project in relation to national laws and regulations, ESIA commitments, PSs as well as compliance with Afcons policies and ESMS requirements. SAG also undertakes regular E&S inspections of Afcons activities. The new EPC contractor will also be required to incorporate monitoring requirements in the management plans and conduct regular audits (ESAP #6).  DGEPN also carries out quarterly audits in line with national requirements. An Independent Environmental and Social Consultant (IESC) will be appointed to undertake independent monitoring of HSE, labor and social aspects of construction activities. The Project will also provide MIGA with an AMR during construction and operations.

Stakeholder Engagement: SAG is currently implementing a Stakeholder Engagement Plan (SEP) in line with PS requirements. The SEP includes stakeholder identification and matrix with consideration of vulnerable groups, roles and responsibilities and engagement approach during the construction phase. Information about the Project is disseminated mainly by CLOs, with support from Local Committees, in charge of disclosing information to local communities and Project Affected People (PAPs). Stakeholder engagement has been undertaken as follows: (i) as part of the ESIA, and (ii) as part of the land acquisition process. Consultations during the ESIA process were held with representatives from local and customary authorities as well as local communities from and in and around Ntoum, Ndjole, Bifoun, Kango and Kiele in January 2021. Consultations undertaken as part of the development of the Resettlement Action Plan (RAP), are ongoing (refer PS 5). Stakeholder engagement has been undertaken through a process of informed consultation and there is general support for the Project.

Per the SEP, community engagements on construction-related activities fall under SAG and EPC responsibilities. SAG is coordinating stakeholder engagement activities between its CLOs and EPC CLO with support from third party social consultant company.  The SEP will be updated to reflect activities during operations (ESAP #10).

External Communication, and Grievance Mechanisms: SAG has developed and is currently implementing a Grievance Redress Mechanism (GRM) for external grievances. The GRM Procedure describes the steps to collect, record, evaluate and respond to complaints and grievances raised by external stakeholders. The nature of the grievances registered under the GRM involve concerns related to resettlement and concerns typical of construction activities such as incidences of dust, vehicle safety among others. SAG has four dedicated covering four sections of the road. Furthermore, the GRM communication channels (phone numbers and emails) will be widely disseminated; and communication plan established to periodically inform local communities about construction works advancements. Specifically, to the Makora quarry, the GRM will be disseminated through periodic awareness meetings with community members living in the Makora village. In addition, local community members will be selected to act in support of CLOs to communicate of grievances raised by local communities (ESAP #11).

PS2:  Labor and Working Conditions

As of January 2024, the Project employs approximately 425 workers, of which 11 are women. Construction activities are expected to be completed by the fourth quarter of 2025 and the start of operations is expected the first quarter of 2026. During operations it is anticipated that between 100 to 170 workers will be hired by SAG for operations and maintenance of the road as well as for manning the tolling stations and toll collection.

Working Conditions and Management of Worker Relationship:  Approximately 70 percent (%) of workers are from Gabon and 30 % are expatriate workers. During recruitment, priority is given to local community members and qualified local community members are prioritized, but a large proportion of the workforce for specialized construction work is sourced from outside the project area. Expatriate staff has been retained for project management and specialized construction related work.

Human Resources (HR) Policies and Procedures: SAG employs approximately 128 workers. SAG’s workers are mostly employed in managerial, advisor or supervisor role covering topics such as project management, E&S, HR and administration. SAG has developed a Reglement interieur (Internal HR procedure) in line with local labor laws (reviewed and approved by the Ministry of Employment, Public Service, Labor and Vocational Training) and PS 2 requirements.

Afcons has developed HR procedures as part of its ESMS that articulates Afcons’ commitments to labor and working conditions and sets out minimum requirements for labor management for the construction phase. This includes a HR management plan, Local Recruitment plan and local outsourcing strategy, a Gender Action Plan, and an Internal Grievance Redress Mechanism. Afcons has appointed a HR Manager and two HR officers. The new EPC will be required to develop and implement HR policies and procedures in line with PS 2 requirements reflecting the following commitments, but not limited to: (i) freedom of association, unionization and collective bargaining; (ii) non-discrimination and equal opportunity; (iii) protection of workforce (including commitment against child and forced labor); (iv) commitment against GBV (ESAP #12). The new EPC subcontractor will be required to appoint an HR coordinator for interface with the new EPC’s HR team (ESAP #13).

Working Conditions and Terms of Employment: Afcons outsources hiring of local workers to four local labor providers (i.e. manpower companies). Majority of local workers are employed under short-term fixed contracts (Contrat à Durée Déterminée). Majority of Afcons foreign workers are from India, directly recruited through Afcons holding company. Local workers are employed through short-term fixed contracts held for a specific duration or task and can be renewed for up to two years, after which, if renewed the contract is automatically converted to a long-term contract. The working terms and conditions included in the short-term fixed contracts include provisions related to salary, statutory payments, and contributions. Salary conditions falls under the Collective Bargaining for Construction Works (October 1983) that sets out minimum wage and bonuses for different categories of work. SAG will validate a short-fixed term contract template prepared by the new EPC to be used by the local service providers in compliance with the Gabonese labor code, specifically in relation to termination clauses and in line with PS 2 requirements (ESAP #14).

Afcons set up three temporary construction worker camps: i) KP 50, KP 95 and at Makora quarry to accommodate expatriate workers taking into account the IFC / EBRD guidance note Workers’ accommodation:  processes and standards (August 2009). The new EPC will also be required to set up the workers camp in line with IFC/ EBRD guidance note (ESAP #15).

Throughout construction, independent labor audits will be undertaken every six months of Afcons and the new EPC contractor HR practices and of its subcontractors and the results of the audit will be shared with MIGA (ESAP #16). The labor audits will comprise all facilities, including the Makora quarry and will, among others assess the following: (i) employment terms and conditions of expatriateand local workers in line with PS 2 requirements and Gabonese Labor Code; (ii) status of workers’ contracts (no work to be undertaken without a valid contract); (iii) working hours; and (iv) recruitment practices of local and expatriate workers. The standard of workers’ accommodation at existing camps (Base camp, KP 95 and Makora quarry camp is subject to internal regular audits by SAG. Communication and accessibility of the workers’ GRM and assessment of workers’ knowledge and understanding of the Project’s HR policies and procedures is reviewed by the Independent E&S consultant.

Afcons developed a Gender Action Plan containing provisions to address GBV risks such as promoting local employment (via local recruitment plan and local outsourcing strategy); providing separate facilities for women at work; raising awareness on GBV; establishing collaboration with NGOs; enforcing a code of conduct with clear provisions against GBV; and corresponding mechanism in the GRM for handling GBV related complaints. Several measures are also in place to ensure safety of women workers. For example, Afcons mobilized a female-only van for employees working at the base camp and Afcons limits night works for female working in traffic management. Progress on commitments made in the Gender Action Plan will be monitored and reported to MIGA . As mentioned above, the new EPC contractor will also be required to develop and implement a Gender Action Plan to address risks of GBV (ESAP #5). Corresponding capacity to manage GBV risks in the project at SAG level will be increased through GBV-training of CLO staff and of local community members supporting the CLOs in managing grievances (ESAP #8). 

Workers’ Organizations: Gabonese labor law recognizes the establishment of workers organizations and stipulates the election of workers representatives in companies with 10 or more workers employed for longer than 6 months. Each of the local labor provider has elected a workers’ representative.

Non-Discrimination and Equal Opportunity:  The Gabonese Labor Code includes provisions related to the prohibition of discrimination in employment and working conditions and remuneration relating to "race, color, sex, religion, political opinion, national extraction or social origin". Afcons HR Management Plan reflects these provisions.

Grievance Mechanism: Afcons developed an Internal grievance redress mechanism to document and address workers’ complaints.  Grievances are received through grievances boxes or with support of HSE officers or Mediation Committee comprising representatives of workers from the four local labor providers.    Grievances received to date relate mainly to fair treatment of workers, work hours, termination, and salary payment. Information on GRM, accessible channels for submitting complaints, and monitoring its resolution is included in the workers induction and in toolbox talks for wider dissemination among workers. The new EPC contractor will develop and implement a GRM (ESAP #17).

Child and Forced Labor: SAG does not employ any person under the age of 18 nor does it permit any contractor to use child labor or employ persons under the age of 18. SAG also prohibits the use of forced labor. Conditions related to the prohibition of employment of any person under the age of 18 and forced labor is incorporated in the current and new EPC contract.

Occupational Health and Safety: During construction, workers are exposed to hazards and risks including from moving machinery; noise, dust and exhaust emissions; confined spaces and excavations; working at heights; working over water bodies; hazardous and flammable materials; and hazardous waste. Additional risks include road accidents. Occupational Health and Safety (OHS) measures are captured in Afcons’ Hygiene, Health and Safety at Work Management Plan, Subcontractor Management Plan and Traffic Management Plan. The Base camp includes a clinic staffed with one doctor, two nurses and a translator. An ambulance is stationed at the KP 50 Base camp. In addition, Afcons has a contract with the Military Hospital at KP 9 for medical services. A full-time nurse has been deployed at the clinic for Afcons workers in Makora quarry. Emergency transportation is provided in a light vehicle. The Traffic Management Plan prepared by Afcons includes measures to be followed in proximity of working zones including safety signs, barriers, speed limits appropriate for construction zones and visible Personal Protective Equipment (PPE).  SAG’s HSE team is supported by an independent Health and Safety Coordinator. In addition, SAG has a monitoring system to track implementation of management plans including a tracker for HSE events and conducts weekly meetings with Afcons on health and safety performance. The new EPC contractor will develop and implement an OHS management plan (ESAP #6)

Workers Engaged by Third Parties: Apart from workers engaged by local labor providers, Afcons has engaged subcontractors for specific services such as security personnel, crusher maintenance, drain works, and blasting works. A Subcontractor Management Plan is in place to monitor and manage performance of subcontractors, including but not limited to training and awareness raising on safety, environmental management, and non-compliance reporting. Afcons is responsible for monitoring and reporting to SAG on compliance of HSE requirements of its subcontractors. The new EPC will also develop and implement a Subcontractor Management Plan (ESAP #6). As indicated above, Afcons and the new EPC contractor will undertake semi-annual labor audits which includes review of sub-contractor labor and working conditions.

PS3:  Resource Efficiency and Pollution Prevention

The ESIA identified potential environmental impacts resulting from construction and operational activities including impacts on air quality; noise and vibrations; wastewater; waste generation among others. The relevant recommendations and mitigation measures suggested in the ESIA have been incorporated into the Afcons management plans and will be incorporated in the management plans of the new EPC contractor (ESAP #6).

Resource Efficiency: The Project will require several resources such as water, aggregate, and fuel. All required resources will need to be used efficiently and all wastes managed in accordance with the waste management hierarchy. The Project is obtaining construction materials (soil, gravel and aggregates) from existing commercial and licensed sources. Aggregates are being sourced from the Makora quarry and one borrow pit at KP 40, an additional borrow pit is under selection. Afcons or the new EPC contractor will conduct the necessary E&S assessments and obtain the required permits or licenses prior to opening up new borrow pits (ESAP #4).

Greenhouse Gases (GHG): GHG emissions were calculated for the construction and operations phase of the Project in accordance with the Greenhouse Gas Protocol, considering scope 1 and 2. GHG emissions are estimated to be approximately 40,668 tonnes of Carbon Dioxide equivalent per year (CO2e/year) during construction and approximately 9,512 tonnes of CO2e/year during operations. During construction, GHG emissions accounting will be undertaken on an annual basis and provided to MIGA as part of the Annual Monitoring Report.

Water Consumption: Water is supplied by two water wells at KP 50 Base camp and one at Makora quarry for domestic purposes. Water for the camp at KP 95 is supplied through the Société d'Energie et d'Eau du Gabon (SEEG) water network. Water abstracted from River Bokoué is used for dust suppression. The volume of groundwater abstracted at the wells is monitored on a monthly basis.

Pollution Prevention

Air Emissions and Noise: During construction, air emissions will consist of combustion gases from vehicles used for construction activities, and dust/particles generated from vehicle movement. Noise will be generated during the Project’s construction as a result of vehicles and machinery used for installing the Project’s components and through road use during operations. Afcons developed an Air Quality and Noise Management Plan that includes adequate mitigation measures and a monitoring program. Air quality and noise monitoring is undertaken by a third-party consultant. As part of the stakeholder engagement plan, project affected persons along the road will be consulted with regards to noise mitigation measures (e.g. use of noise insulation materials, noise wall, resettlement). The new EPC contractor will also develop and implement an Air Quality and Noise Management Plan that includes a monitoring program along the Project’s working zones and in response to grievances (if any raised) (ESAP #18).

Wastes: Afcons developed a Waste Management Plan. Most of the waste will be produced during the construction phase. These wastes include earth material from excavations, hazardous waste and domestic waste. Afcons follows the waste hierarchy of prevention, re-use, recycle, recovery and disposal. Effluent waste generated during construction include domestic and industrial effluents. Effluent waste except for concrete batching plant effluent, is diverted into enclosed underground concrete tanks and collected by a licensed waste management service provider. The effluent waste from the concrete batching plant will also be diverted to an enclosed tank and monitoring of effluents of the underground tanks undertaken (ESAP #19).

Hazardous Materials Management: Hazardous materials such as lubricants, fuel, bitumen, aerosols will be used during construction and operations. A Hazardous Materials Management Plan has been developed by Afcons and implemented for construction that sets out the requirements for storage, transportation, and disposal of hazardous materials. The new EPC contractor will also develop a Hazardous Materials Management Plan.  SAG will develop and implement a Hazardous Materials Management Plan for operations (ESAP #20).

Pesticide Use and Management: 

Pesticides are not used during construction. During operations, regular maintenance of the RoW to control vegetation may require the use of pesticides. SAG will develop and implement a pesticide use and management plan for operations (ESAP #21).

PS4:  Community Health, Safety and Security

Community Health and Safety: Potential negative community health and safety impacts during construction stem from dust and noise due to the movement of heavy equipment, materials and project personnel, traffic accidents as well as influx of workers. A Hygiene, Health, and Safety (HSS) Plan for Communities is in place to manage risks arising from construction activities and includes mitigation measures related to dust generation and exhaust gas emissions, noise, spread of communicable and infectious diseases; road accidents; and risks of GBV. The new EPC contractor will develop a community health and safety plan and SAG will develop and implement a community Health and Safety Plan for operations (ESAP #22).

Afcons has also developed and is implementing a Traffic Management Plan (TPM) that includes mitigation measures that are implemented in proximity of working areas including segregation measures such as road traffic signage, physical barricades, flag persons. The new EPC contractor will develop a TPM for its activities (ESAP #23). Blasting activities are undertaken at the quarry site in Makora. The Makora village is approximately 5 km from the quarry. Explosive management and blasting activities at the quarry are sub-contracted to a third party licensed by the Ministry of Defense with the involvement of the Gendarmerie. Explosives are brought to Makora quarry on a strictly needed basis. There is no storage of explosives on site. 

SAG developed an Influx management plan that takes into account issues associated with the possible migration of job seekers and informal service providers to the Project area. The influx management plan considers main influx areas, expected impacts as a result of influx and mitigation measures to reduce negative impacts and enhance positive impacts.

Labor influx is also a contributing factor to risks of gender-based violence in the community. Both the HHS Plan and Gender Action Plan (GAP) (refer to PS2) contain provisions to manage GBV risks which include measures related to implementation of awareness campaigns with local communities, workers and health practitioners on sexual exploitation abuse and harassment (SEAH), and other health-related risks such as sexually transmitted infections and alcohol consumption.  Progress on the implementation of the measures provided in both the HHS Plan and GAP will be monitored on a quarterly basis to review the adequacy of measures being implemented.  Makora quarry is in a remote location and the local community is isolated. SAG will hire an NGO specializing in the fight against GBV to support the implementation of its GAP and to support its CLO to report and respond to GBV-related risks, and to develop additional actions as needed (ESAP #24). 

Infrastructure and Equipment Design and Safety: Communities raised road safety concerns particularly regarding safety of children going to school, and safety of community members who regularly cross the road as part of their daily activities (fetching water, selling goods, etc). A Road Safety Audit for the Project was conducted in 2022. SAG is implementing the proposed safety measures (speed bumps, chicanes, pedestrian crossings and others) together with interested and affected stakeholders.

Security Personnel: Afcons engages security personnel through one of the local labor providers (which is also an accredited security provider). Afcons developed a Security Management Plan (SMP). The new EPC will also develop a SMP will be supported by the following: (i) security and human rights training plan covering topics such as appropriate use of force, human rights, gender considerations, appropriate conduct towards workers and affected communities; and (ii) training (to be provided by a qualified security firm with experience and knowledge of PS 4 requirements (ESAP #25). Private security forces will be used during operations. In addition, police stations will be located at KP 55 and KP 96 toll plazas. SAG will develop and implement a SMP for operations (ESAP #25). A Memorandum of Understanding with the Gendarmarie (public security force) deployed for explosive transportation and blasting activities will be developed between the new EPC and Gendermarie, if needed (ESAP #26).

PS5: Land Acquisition and Involuntary Resettlement

Project Design: The project involves upgrading of an existing public road (KP12 to 105). Rehabilitation works comprise lane refurbishment, lane widening in certain segments (KP24-KP40) and construction of toll plazas. The existing RoW will be used to minimize resettlement; however, some sections of the road will be extended beyond the existing RoW. 

Compensation and Benefits for Displaced Persons: The total number of physically and economically displaced Project Affected People (PAPs) is approximately 1628, within which 1535 PAPs will be economically displaced (predominantly roadside small business selling food and agricultural products, craftsmen/service shops), and 94 PAPs will be physically displaced. Approximately 28 PAPs are considered vulnerable among those physically and economically displaced. Compensation to PAPs in between KP 12 – 24 has not yet started. As of December 2023, between KP 24 to KP 105 about 44 of the 1267 or 3% of the total PAPs are yet to be compensated.

A Resettlement Policy Framework (RPF) was prepared by SAG in 2021 and updated in October 2022 focusing on Stage 1A. It provides key principles and tools to assess and manage resettlement impacts related to the Project in line with PS 5. Three Resettlement Action Plans (RAP) and respective Livelihood Restoration Plans (LRP) were also prepared covering road sections (i) KP 24 to 50, (ii) KP 50 to 75, and (iii) KP 75 to 105. SAG is finalizing RAP and Livelihood Restoration Plans (LRP) corresponding KP 12 to 24, and tollgates (ESAP #27).

Community Engagement: An engagement strategy and procedure is outlined in the RPF and corresponding RAPs contain methods of consultations and participation used to communicate with stakeholders and PAPs regarding project-related information and concerns.  Regular meetings are organized and tracked monthly to inform PAPs and stakeholders of the progress of the different phases of implementation, principles of compensation, method of inventory, and process for filing complaints. Local Committees, composed of three individuals nominated by the community, have been established to disclose project information to local communities and PAPs. SAG’s CLO also support with RAP, LRP related engagement activities, and can receive resettlement related complaints through the GRM.

Grievance Mechanism: A grievance redress system is in place to manage complaints related to RAP and LRP implementation. Complaints may be filed through Local Committees, Village Chiefs, SAG CLOs verbally or in writing. The CLOs receive, register, investigate and resolve complaints through the SAG team and the Land Committee depending on the nature of the grievance. Complaints are tracked and monitored including processing time to close grievance.   

Resettlement and Livelihood Restoration Planning and Implementation: Compensation and benefits are captured in an entitlement matrix that considers project related impacts (physical and economic) and profiles of PAPs (owner/land user/tenant) including vulnerable PAPs. PAPs that are physically displaced are provided three options: (i) self-construction (own construction by the affected households); (ii) construction by the project (house to be built by SAG); and (iii) monetary compensation. SAG provides security of tenure of physically displaced PAPs that selected self-construction and built by SAG option.

The LRP includes support measures to both physically and economically displaced PAPs and these are: (i) customized support for vulnerable PAPs; (ii) budget management; (iii) restoration of commercial activities; (iv) advanced support for entrepreneurship; and (v) support for self-construction (to PAPs who opted to self-construct). Vulnerable households are identified following six indicators (socio-demographic, socio-health, housing quality and comfort, possession, and socio-economic) and those who meet the threshold are provided (i) support during contract signature and compensation process (e.g. bank management support, training in financial management) and (ii) dedicated follow-up during the implementation.

SAG is regularly monitoring and evaluating resettlement and compensation processes with the support of a Social Consultant and the status of the RAP and LRP implementation will be made available for MIGA review ). After completion of the RAP and LRP mitigation measures, the Project will commission an external completion audit of the RAP and LRP to assess whether the provisions have been met and implement supplemental measures, where applicable, as well as any additional livelihood restoration measures (ESAP #28).

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

General: Gabon is rich in biodiversity, with significant forest cover and a high rate of species endemism. The Project overlaps two ecoregions: Central African Mangroves and Atlantic Equatorial coastal forests. The project is an existing road that traverses areas largely impacted by human activities, and does not intersect any nationally or regionally protected areas, globally recognized areas, or high priority areas for great apes.

As part of the ESIA, baseline surveys, a Critical Habitat Assessment, and a Biodiversity Impact Assessment have been conducted by Gabonese and international specialists. Consultation with the ARRC Taskforce has been initiated and will continue during BAP preparation.  

Protection and Conservation of Biodiversity: The Project is in Modified Habitat except for a portion of about 10 km south of Kango, characterized by the presence of secondary forests. Fragments of degraded secondary forest on both sides of the road between KP 75 to 105 may be used by CR forest elephants (Loxodonta cyclotis), EN Central African chimpanzee (Pan troglodytes troglodytes), and other fauna such as the EN grey parrot (Psittacus erithaceus). The last kms of the project (between Kango and KP 105) overlap with Critical Habitat for chimpanzees and forest elephants.

The Project mainly entails refurbishment of existing infrastructure within an already impacted RoW. There will be no road widening, or additional footprint in areas of Natural or Critical Habitat. The location of Kango toll plaza was changed from KP 102 to KP 96 to avoid impacting 1.53 hectares (ha) of secondary forest supporting forest elephants and chimpanzees and an identified corridor for those two species.

No significant adverse impacts on biodiversity and/or on Critical Habitat triggers are anticipated due to the upgrade works, following the implementation of good practice mitigation measures during construction. A Biodiversity Management Plan (BMP) will be developed to cover the finalization of construction activities, including restoration and rehabilitation, and biodiversity mitigation and monitoring requirements for operations (ESAP #29).

Per ESAP #30, SAG will develop and implement a Biodiversity Action Plan (BAP), in consultation with key stakeholders. The BAP will detail the project strategy to achieve Net Gain for forest elephants and chimpanzees. It is anticipated that for forest elephants, conservation measures may focus around reducing human-elephant conflict. For great apes, conservation measures may focus on reducing local threats to chimpanzees (e.g. from bushmeat hunting) and/or contributions to regional conservation priorities. A framework BAP will be prepared to inform and guide the final BAP which will be concluded following planned studies to refine current mitigation proposals.

Ecosystem Services: The ESIA identified fishing activities as a priority Ecosystem Service. The BMP will include mitigation measures to minimize localized impacts on this, and other communities' uses of watercourses during bridge construction and refurbishment activities.   

Supply Chain: Aggregates will be sourced from an existing quarry which has been in operation for 25 years. Therefore, no associated clearance of Natural or Critical Habitat will take place.

PS8: Cultural Heritage

The ESIA identified three low to medium priority archeological sites on top of small hills located close to the road but outside of the project footprint, where shards of pottery and carved stone artifacts were found. Afcons developed and is currently implementing a Cultural Heritage Management Plan, covering tangible and intangible cultural heritage sites and a Chance Find Procedure which includes criteria for potential temporary work stoppages in the event of a chance find. Afcons routinely conducts training / awareness of workers on the chance find procedure and will keep a record of chance finds (if applicable). The new EPC contractor will develop and implement a Cultural Heritage Management Plan and Chance Find Procedure (ESAP #31). Displacement of 56 graves and one church were relocated in the context of the RAP. The list of graves identified and displaced was submitted to the Ministry of Public Works, Equipment and Infrastructure.


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


For additional information on the Project, please contact:


Address:  Immeuble Narval – RDC - Thaiti – BP 8106 – Libreville – Gabon


Phone: +241 61 00 49 94

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




MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.


Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.


Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:


Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400