26678 - Topic Tunisia

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Environmental & Social Review Summary

Project Number

26678

Company Name

TOPIC SA

Date ESRS Disclosed

Mar 24, 2008

Country

Tunisia

Region

Africa

Last Updated Date

Sep 30, 2022

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Dec 2, 2008
Signed : Jan 5, 2009
Invested : Dec 23, 2009

Sector

Oil and Gas Production (Includes Development)

Industry

Metals and Mining

Department

Regional Industry - INF Africa

Project Description

TOPIC, S.A. (TOPIC or the company) is a small Tunisian oil and gas exploration and production (E&P) company with interests in three oil and gas blocks in Tunisia:

- 100% interest in the offshore Halk el Menzel (“HelM”) concession block;
- 15% interest in the onshore Jelma exploration block; and
- 50% interest in the onshore Douleb West prospecting block.

The proposed project primarily involves:

- the development of an oil discovery in HelM; and
- acquisition of seismic data and drilling of exploration wells at HelM and TOPIC’s other blocks. The company is planning to begin full-scale oil production in HelM in third quarter 2009.

Overview of IFC's Scope of Review

The review of TOPIC consisted of an appraisal mission in February 2008 to the field development areas, meetings with management and key staff from TOPIC, and review of the Project’s technical, environmental and social reports.

E & S Project Categorization and Applicable Standard

While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

- Performance Standard 1: Social and Environmental Assessment and Management Systems;
- Performance Standard 2: Labor and Working Conditions;
- Performance Standard 3: Pollution Prevention and Abatement;
- Performance Standard 4: Community Health, Safety and Security;
- Performance Standard 5: Land Acquisition and Involuntary Settlement; and
- Performance Standard 8: Cultural Heritage.

TOPIC’s oil and gas development is a Category B project according to IFC’s Policy for Environmental and Social Review of Projects because it has limited adverse social or environmental impacts that are few in number, are site specific and will be reversible and readily addressed through mitigation measures. The IFC made this categorization based on:

- Site visits to the proposed project areas;
- Meetings with management and key staff from TOPIC; and
- Review of available environmental and social documentation.

The offshore HelM concession block is located 70km from coastal communities, and the onshore exploration and prospecting blocks are in remote areas which are not located near any large settlements. Biodiversity aspects will not be impacted.

Environmental and Social Mitigation Measures

TOPIC has interests in three oil and gas blocks in Tunisia as follows:

Halk el Menzel (HelM): TOPIC owns 100% of the HelM concession. The block covers an offshore area of 570 km2 in the Gulf of Hammamet in northern Tunisia. Water depth is 76 meters and the field lies approximately 70 km north east of the city of Monastir. This project is at early stages of development and TOPIC will be preparing Environmental and Social Impact Assessments for each of the phases of the project, the seismic activities and the development of the field.

TOPIC’s early assessment of the development of the field has indicated that the best option for this field will be the use an Early Production System consisting of a Mobile Offshore Application Barge (MOAB) and a moored storage tanker (FSO), that together will comprise the facilities. It is proposed that the oil will be pumped to the FSO through an undersea flowline system, which will be moored adjacent to the facilities. Further analysis will be undertaken to determine if the associated gas can be utilized as fuel for the operation. TOPIC will use best international oil and gas industry standards to develop the field and mitigate any potential impacts.

Jelma: TOPIC has a 15% interest in the onshore 7,216 km2 Jelma exploration block located in central west Tunisia. TOPIC’s partners in the block are HTC, a Swedish E&P company, PA Resources, which holds a 35% interest and is the operator, and Entreprise Tunisienne des Activités Pétrolières (ETAP), the state-owned Tunisian oil company, which holds the remaining 50% interest. The work planned for this block involves additional seismic work as well as two exploratory wells.

Douleb West: TOPIC has recently acquired a 50% interest in the onshore 224 km2 Douleb West (DW) prospecting block located in central west Tunisia. DW is at an early stage of exploration and is operated by TOPIC. During this early stage, TOPIC will:

- acquire and process 30 km of 2D seismic;
- reprocess of 300 km of existing seismic data; and
- prepare geological and geophysical studies.

As part of Tunisia’s Hydrocarbons Code, TOPIC is required to prepare Environmental and Social Impact Assessments (ESIA) for each of its activities, and includes preparation of an environmental management plan and a monitoring program.

TOPIC has prepared a Health, Safety, Security, Environmental and Quality Management System (“HSSEQ MS”), a HSSEQ MS – Self Assessment Guidelines and a HSSEQ MS for the Management of Contractors Guidelines.

TOPIC’s HSSEQ Policy includes a commitment by the company to

- achieve development in a sustainable manner;
- provide and maintain a safe and secure working environment;
- assess and reduce risk to levels as low as reasonably possible;
- ensure that decisions in their activities reflect those of the HSSEQ objectives and targets of the company;
- ensure that all suppliers and contractors understand the Company’s HSSEQ policies, objectives and targets and are held accountable for their performance and implementation; and
- provide training and the necessary means for the communication of these standards, and allow sufficient resources to maintain and update the HSSEQ MS.

The operational strategy of TOPIC envisions the outsourcing of most of its activities to contractors. Therefore, as part of the strategy for, and management of contractors, TOPIC has developed HSSEQ MS guidelines to control and supervise contractors, in addition to those established under the Tunisian legislation. Under the company’s guidelines, contractors are encouraged to develop their own management systems that will reflect TOPIC’s commitment to quality, safety and the environment, as well as to the process that will help them mitigate or reduce the risk in their activities. Prior to hiring a contractor, TOPIC will assess them on various areas including HSSEQ. TOPIC has established a set of indicators to monitor the selection of their contractors as well as the progress and improvement shown through time. TOPIC has also explicitly stated in these documents that the Company will commit to implement IFC’s Performance Standards.

Since most activities will be outsourced to contractors, TOPIC’s own workforce will not exceed 25 persons. TOPIC has prepared a draft General Human Resources Policy (including a worker grievance mechanism) that will meet the requirements of Tunisian labor laws and regulations and IFC’s Performance Standard 2: Labor and Working Conditions.

TOPIC will require contractors and sub-contractors to provide certification that they are in compliance with TOPIC’s policies and Tunisian labor laws and regulations and this will be monitored. It is expected that the workforce will peak at 250 during the construction phase and will amount to approximately 100 workers during the operations phase. Priority will be given to hiring local workers who have the required skills.

Unarmed private security guards will be used for the protection of certain sites and will be deployed in accordance with the applicable Tunisian law and in line with requirements of IFC’s Performance standards. Under Tunisian law private security guards are not permitted to carry firearms.

TOPIC has committed to the preparation of a Framework Public Consultation and Disclosure Plan (PCDP), to establish principles and provide an approach to stakeholder consultation for its projects, that will meet Tunisian requirements and the IFC’s Performance Standards. This will build on existing established processes of interaction with government leaders and representatives of local communities concerning the development and operation of projects.

Existing activities in onshore exploration and prospecting blocks require certain lands to be acquired on temporary basis for exploratory work (seismic surveys, exploratory drilling, appraisal, approach roads etc). At a later stage there may be further exploration and land may be required permanently for development of project facilities. There is an established process in Tunisia for the temporary use of land or permanent acquisition of land for project development. This can be undertaken in direct negotiations between the operator and landowners or through using the services of the local administration (Governorate). TOPIC has committed to the preparation of a Framework Land Acquisition and Compensation Plan (LACP), which will outline the principles, guidelines and approaches to be followed in acquiring land in all its current and future investments, in order to meet the requirements of Tunisian national regulations and IFC’s Performance Standard 5: Land Acquisition and Involuntary Resettlement. More detailed LACPs may be prepared in future, if required, for site specific projects.

In the Jelma exploration block the Jelma Permit Operator (HTC) currently acquires land through direct negotiations with landowners. TOPIC is not the operator at Jelma but will make its best effort to ensure that HTC will use, and observe the commitments of, the Framework LACP.

In respect of the HelM development TOPIC will address any impacts to fishermen affected by offshore operations in accordance with Tunisian national regulatory requirements and IFC’s Performance Standards.

It is not expected that there will be any impacts to cultural property as a result of activities in the exploration and prospecting blocks. Known archaeological sites will be avoided since there is some flexibility in the siting of exploratory wells, approach roads, etc. However, TOPIC will prepare a “chance finds” procedure to address impacts to, and protection of any cultural property encountered in the course of project activities.

Stakeholder Engagement

There is an established process in Tunisia for consultation with local authorities at the Governorate, ‘Délègation’ and Municipal levels and with local community leaders. As part of Tunisia’s Hydrocarbon Code there is also a requirement for public meetings with communities located adjacent to project developments to provide information on project impacts identified in the ESIA, and related aspects (hazards, emergency procedures, opportunities for employment, etc). TOPIC will prepare a Framework Public Consultation and Disclosure Plan (PCDP) to ensure that stakeholder engagement is in accordance with Tunisian regulations, IFC’s Performance Standards and international best practice.

Since its inception, TOPIC has voluntarily contributed to the national “Solidarity Fund 26:26”, which provides assistance to marginalized communities in Tunisia. TOPIC will also prepare a Community Development Strategy (CDS) to guide its approach to providing assistance to, and ensuring that, neighboring communities benefit from opportunities associated with project implementation and activities.

Client Documentation

File Name	Actions
Action Plan final.pdf

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and 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 an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.

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Environmental & Social Review Summary

Project Description

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E & S Project Categorization and Applicable Standard

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Environmental and Social Categorization and Rationale

Environmental and Social Mitigation Measures

Environmental and Social Mitigation Measures

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