Progress made by Kuwait Energy on the development and implementation of the group’s corporate E&S management program since IFC’s original due diligence in 2009 and subsequent due diligence in 2010 has been evaluated during this review. Kuwait Energy remains committed to completing the items that address key E&S issues as laid out in the Environmental and Social Action Plan (“ESAP”). Upon completion of the updated ESAP (attached to this ESRS), the project will comply with host country laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability, and follow relevant IFC Environmental, Health and Safety (“EHS”) guidelines.
The below Summary provides an update to the information previously disclosed as part of IFC’s previous Kuwait Energy investments (
Project # 28068;
Project # 29306).
PS1: Social and Environmental Assessment and Management System
Kuwait Energy continues to operate an integrated health, safety, environment and social responsibility (“HSESR”) management system across its operations. Overseeing the Kuwait Energy HSESR management system are numerous policies covering Alcohol and Drugs; Driving; Environment, Health, Safety, Environmental and Sustainability; Health; Training; Medical and First Aid; No Smoking; Personal Protection Equipment and Security. Overseeing the implementation of the HSESR management system is KEC’s Corporate HSE manager supported by HSE staff located at KEC’s operated assets, namely 6 HSE staff in Egypt, 2 in Ukraine and 3 in Russia.
Following IFC’s previous investment in 2010, Kuwait Energy has been following a process to have both corporate and site level HSESR’s certified to international standards. The HSESR management system is now fully implemented at Kuwait Energy’s operated asset level. To date, the Ukrainian operations have been certified to comply with ISO14001. Kuwait Energy has planned and budgeted for Kuwait Energy’s Egyptian operations to obtain OHSAS18001 certification during 2012 and for ISO14001 certification at both Kuwait Energy’s Egyptian and Russian operations during 2013. As per IFC’s requirements, Kuwait Energy will continue to periodically review the HSESR management system as the Kuwait Energy portfolio evolves to ensure consistency in relation to IFC’s Performance Standards.
Kuwait Energy inherited an HSESR management system as part of the acquisition of Oil Search Limited in 2008. Business critical HSESR operating procedures were initially adapted for the enlarged group. Additional procedures have subsequently been adapted or developed separately as the Kuwait Energy business evolved. There are some remaining non-critical items that the group has yet to adapt from the old Oil Search Limited HSESR management system. Kuwait Energy will review the applicability of these items and develop a transition plan to close them out where appropriate.
As required under the Kuwait Energy HSESR management system the group will undertake Environmental and Social Impact Assessments, consistent with national regulatory requirements and IFC’s Performance Standards, as part of future operational developments within the operated portfolio.
With regard to audit activities, Kuwait Energy has implemented pre-acceptance procedures for contractors to ensure consistency against IFC’s Performance Standards. As part of the HSESR management system, these procedures are fully implemented across the Kuwait Energy operated portfolio where most recently these have been applied for rig contractors and operating equipment contractors in Egypt. These pre-acceptance procedures form a part of contractor bid requirements and are scored against set criteria depending on the contracted activity. Consequently, HSE performance of contractors is integrated into the overall Kuwait Energy bid evaluation processes. Where contractor HSE performance does not meet the requirements of Kuwait Energy’s HSESR management system, these contractors are excluded at an early stage.
Kuwait Energy has developed a stakeholder management plan and grievance mechanism. These have been issued and approved by Kuwait Energy management and have been incorporated into Kuwait Energy’s management system. Due to Kuwait Energy’s expanding operations the social management role is currently being transitioned out of the HSE team. As part of the current investment, Kuwait Energy will designate a qualified individual to perform the Social Manager role within the group.
Consistent with Kuwait Energy’s policy, compulsory training is required depending on an individual’s assigned operational activity. These training programs include confined space entry; working at height; hazard identification; spill prevention and response; lifting operations; crane safety; basic first aid and basic fire fighting. As required by Kuwait Energy’s HSESR management system these training programs are periodically reviewed and updated in accordance with current good international industry practice.
PS2: Labor and Working Conditions
Kuwait Energy currently employs approximately 500 employees, of which for the current investment 119 are located in Egypt, 106 in Ukraine, 121 in Russia and 98 located in Kuwait. Following IFC’s 2010 investment, Kuwait Energy is making progress in implementing a corporate HR Policy and HR manual across all of Kuwait Energy’s operational locations providing a degree of consistency across the group in relation to terms and conditions of employment and HR policies.
Subsequent to the previous disclosure, Kuwait Energy has implemented a program of regular workplace monitoring of air quality, drinking water and noise in line with IFC’s EHS General Guidelines.
PS3: Pollution Prevention and Abatement
Kuwait Energy continues to work on greenhouse gas reduction programs across the portfolio. Principle focus and priority at present is to eliminate flaring at the Kuwait Energy operated ‘Area A’ asset in Egypt. The asset represents the single largest air emissions source across the Kuwait Energy operated portfolio. The group is currently in negotiations with the General Petroleum Company, a national E&P operator, to re-inject flare gas to existing or alternative reservoirs, with supporting design studies currently under way to develop the flare elimination project. The group expects to commence re-injection operations at the ‘Area A’ asset within six months of completing negotiations with the General Petroleum Company.
Licensed waste contractors dispose of process waste water, drill cuttings and spent drilling fluids, sanitary and general (including inert, hazardous and recyclable) wastes from the group’s operated sites. These are managed as required by the HSESR management system. As part of the current investment, the group will develop a change of custody procedure for waste consistent with IFC guidance.
Subsequent to IFC’s previous investment, Kuwait Energy has implemented an oil and chemical spill contingency plan also documenting response measures and staff training.
A number of pre-existing contaminated sites were identified during a baseline study carried out in 2006 for KEC’s ‘Area A’ operations. Feasibility options studies to address these have been undertaken and remediation is ongoing. De-contaminated material (principally sand) is being used as a base material for road construction in the field.
PS4: Community Health, Safety and Security
Kuwait Energy’s existing activities are not expected to result in health and safety risks to the general public.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS6 aspects continue to be managed as described in earlier disclosures.