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: PS1: Social and Environmental Assessment and Management Systems; PS2: Labor and Working Conditions; PS3: Pollution Prevention and Abatement; PS4: Community Health, Safety and Security Comasel St Louis plans to install distribution lines along existing roads and the Project is not expected to have any involuntary resettlement or need for compensation for right-of-way acquisition. Therefore, PS5: Land Acquisition and Involuntary Resettlement is not applicable. The Project concession area has some pastoral reserves, animal reserves, and historically valuable places dating from the Colonial era. The Company is aware of these settings and plans to select routings of distribution lines to avoid impacts, if any. Considering the scope and characteristics of the Project, project impacts related to PS6: Biodiversity Conservation and Sustainable Natural Resource Management and PS8: Cultural Heritage are expected to be insignificant. As a precaution, a Chance Finds Procedure will be established as part of the Company’s construction management system. There are no Project impacts related to PS7: Indigenous Peoples as there are no indigenous peoples living in the project area.

This is a category B project according to IFC’s Procedure for Environmental and Social Review of Projects because it has limited adverse social and environmental impacts that are few in number, largely reversible, and can be readily addressed through mitigation measures. Impacts arising from installation of solar kits and new distribution lines for rural electrification are not expected to be significantly adverse, and they will be appropriately managed by the Environmental and Social Management Plan (ESMP) prepared by the Company, and in accordance with ASER’s Environmental and Social Management Framework. IFC’s appraisal reviewed the following issues and opportunities: Environmental and social management framework for the rural electrification concessions established by WB and ASER; Company’s plan to manage environmental and social impacts and opportunities (e.g. construction management, operation and maintenance arrangement, right-of-way acquisition of connecting distribution lines, health and safety management); and Environmental benefit of the Project (e.g. greenhouse gas displacement by solar power generation). Comasel St Louis is committed to implementing the Project in accordance with not only the Senegalese environmental, health and safety requirements which includes ESMP, but also IFC Performance Standards. The WB/GEF Project (Electricity Services for Rural Areas Project for Senegal) that provide subsidies to the Comasel St Louis Project was also classified as Environmental Category B.

PS1: Social and Environmental Assessment and Management Systems S&E Assessment: As part of the WB/GEF Project (Electricity Services for Rural Areas Project for Senegal), ASER prepared an Environmental and Social Management Framework (ESMF) that describes a clear and systematic process for the effective assessment of any potential environmental and social impacts that result from concession projects. Senegalese Ministry of Environment approved the ESMF and disclosed it publicly. ASER requires concessionaires to follow the ESMF as appropriate. For the preparation of its proposal, Comasel St Louis undertook a detailed market survey and analysis of the concession area, visiting over 250 villages and obtaining the technical and socio-economic information required to prepare its Project proposal. This information is the basis of the Company’s business plan which identifies the villages that will be electrified and the technical installations required (e.g. solar kits vs grid connection). Management Program: As required by the concession, Comasel St Louis prepared an Environmental and Social Management Plan (ESMP) describing various mitigation measures, monitoring programs and management arrangement for both construction and operational phases of the Project. Key elements of the ESMP are summarized below: Planning and construction phase – medium / low voltage distribution lines Select distribution line routes in consultation with local authorities and National Forestry Commission to avoid adverse impacts on zones of ecological value. Collect and dispose oily waste from vehicles appropriately. Limit nighttime construction activities. Avoid installment of distribution lines on cultivated zones. If unavoidable, use compensation approach. Require contractors to ensure that workers entering rural villages respect local culture and the population. Use local labor to the extent possible to maximize employment benefits to the communities. Require contractors to ensure that electrical works be conducted by qualified workers, health and safety information sessions be carried out before construction starts, hazards markings be properly indicated by using symbols and local dialect as appropriate, and affected communities be informed before the start of construction. Operational phase (medium / low voltage distribution lines) Routinely check that vegetation is properly cleared under the 30kV distribution lines. Sensitize local communities to the risks of electrocution and falls of pylons. Construction phase (solar kits) Store sulfuric acid for batteries appropriately. Provide workers with personnel protection equipment (e.g. glasses, gloves and rubber sole shoes) adapted for handling of sulfuric acid for batteries of the solar kit. Inform villagers of the health and safety considerations of using solar kits. Ensure that only the trained workers have access to sulfuric acid. Ensure that batteries are not installed in the kitchen or the bedroom of houses. Operational phase (solar kits) Properly recover used batteries. Store sulfuric acid for batteries appropriately. Provide trainings to maintenance workers on the handling of sulfuric acid. Comasel St Louis will adopt and implement ONE’s established procedures to manage environmental, health and safety risks and impacts for rural electrification projects. Organization / Training / Monitoring and Reporting: Comasel St Louis will appoint an environmental supervisor to ensure that the environmental, health and safety mitigation measures are properly included in the specifications for the contractors, to monitor that the construction and operational activities are in line with the ESMP, and to prepare environmental, health and safety reports to Comasel St Louis and ASER, and to take any follow-up actions as necessary. As mentioned under Management Program, Comasel St Louis will ensure that contractors provide workers with necessary health and safety trainings to minimize injuries and accidents. These trainings will include the need to respect the rural culture and the population when conducting construction works within villages. Comasel St Louis plans to provide appropriate trainings to rural villagers so that they can be engaged in installing solar kits, maintenance and minor repair works. PS2: Labor and Working Conditions Human Resources Policy and Management / Worker’s Organization: Comasel St Louis was established to conduct the Project in Senegal in 2008 and is in the process of recruiting staff. During the construction phase, Comasel St Louis plans to mobilize contractors to install solar kits and distribution lines. The Company plans to have 41 employees consisting of 5 expatriate staff from Morocco and 37 Senegalese staff. The Company is committed to adopting the human resources policy and management systems in accordance with this IFC Performance Standard. These include documentation of and communication to all employees and workers directly contracted by the Company their working conditions and terms of employment, respect workers’ right to form or join workers’ organizations of their choosing or bargaining collectively. Comasel St Louis is committed not to discriminate or retaliate against workers who participate, or seek to participate, in such organizations and bargain collectively. Employment decisions are being made by the Company on the basis of job requirements. Grievance mechanism will be established and be communicated to workers. Occupational Health and Safety: The Environmental and Social Management Plan prepared by Comasel St Louis includes measures to provide the workers with a safe and healthy work environment. These includes Comasel St Louis’s actions to require contractors to: ensure that installment of distribution lines is conducted by qualified workers; ensure that health and safety information sessions are conducted at the beginning of the construction work including about handling of sulfuric acid for batteries associated with solar kits; ensure that hazards of the construction works are clearly marked by using symbols and local dialect; ensure that local communities are informed before the construction work starts; ensure that appropriate personnel protection equipment is provided to workers adapted for handling of sulfuric acid or the filling of the batteries with distilled water (e.g. glasses, gloves and shows with rubber soles); and Ensure that only trained workers have access to batteries. PS3: Pollution Prevention and Abatement Pollution Prevention – Resource Conservation and Energy Efficiency: As detailed in the ESMP, Comasel St Louis will implement measures to avoid or minimize the release of pollutants. These include measures related to handling sulfuric acid necessary for batteries of solar kits. In installing transformers, Comasel St Louis will ensure that they do not contain any Polychlorinated Biphenyls (PCBs). Waste / Hazardous Materials: All oily wastes from vehicles will be collected and disposed appropriately. Sulfuric acid for batteries will be stored appropriately at dry and closed places and trainings will be provided to ensure that workers can handle sulfuric acid safely. Information will be provided to local villagers about the potential risk of using batteries of the solar kits. Solar kits are expected to last 10 years except for batteries that need to be replaced every 2 years. Comasel St Louis will collect used batteries, dispose properly and install new ones. Greenhouse Gas Emissions: The Project will install total of about 400kW of solar kits. Assuming six hours per day of generation, the Project will generate 876,000 kWh of solar electricity per year. Senegalese oil-fired generation in 2004-2006 had 888 gCO2/kWh performance. The Project is estimated to displace about 780 ton CO2/year assuming that this amount of electricity be supplied by oil-fired generation. PS4: Community Health, Safety and Security The ESMP prepared by Comasel St Louis includes the following mitigation measures to avoid or minimize risks and impacts on the health and safety of the project affected villagers by the Project: Limit nighttime construction activities; Require contractors to ensure that workers entering rural villages respect local culture and the population; Require contractors to inform affected communities before the start of construction; Sensitize local communities to the risks of electrocution and falls of pylons; and Inform villagers of the health and safety considerations of using solar kits.

As part of its main role to manage the country’s rural electrification programs, ASER has been in charge of disseminating information on its on-going activities (www.aser.sn). After Comasel St Louis was selected as the concessionaire to implement the Project, the Company prepared an Environmental and Social Management Plan based on Comasel St Louis’s Project design specifications. The document is being disclosed by the Company at Comasel St Louis’s office in St Louis. In preparation for the start of the construction of the Project, and in accordance with ASER’s public consultation process (“Description du Processus de Consultation des Populations des Conseils Ruraux, des Conseils Regionaux et des Parlementaires”), ASER plans to have 16 public consultation meetings with the affected villages to inform them of the updated status of the Project including Comasel St Louis’s ESMP. These meetings are planned to be held at each of the 16 rural communities within the concession area in July and August 2009. Comasel St Louis will participate in these meetings. Since the Project will provide significant benefits to villagers, there is expectation of strong support for the Project. Complaints, if any, related to the concession framework or the Project design and implementation, will be handled by ASER and/or Comasel St Louis accordingly depending on their roles and responsibilities. Comasel St Louis will assign a community liaison officer to ensure that ongoing community engagement with affected villages is properly conducted in accordance with IFC Performance Standards. A grievance mechanism will be established as part of Comasel St Louis’s business operation to receive communities’ concerns and grievances and facilitate resolution of such. Comasel St Louis will inform the affected villages of the mechanism in the course of implementing the Project. Information related to household tariffs and tariff adjustment mechanisms, service standards, investment obligations, the form and extent of any ongoing government support, and concession fees will be disclosed by Commission de Régulation du Secteur Electricité (Electricity Regulatory Commission) (www.crse.sn).

Comasel St Louis prepared an Environmental and Social Management Plan (Plan de Gestion Environnemental et Social). The document is available at: Comasel St Louis office in St Louis Address: Quartier Ngallele, Route Gaston Berger, BP 270, Saint Louis, Senegal Telephon: +221-33-961-3434 Contact: Mr. FARAH El Mostapha Comasel St Louise office in Dakar Address: 3 Paul Holle, Dakar, Senegal Telephone: +221-77-806-0013 Contact Person : Mr. FARAH El Mostapha