While all Performance Standards are applicable to this investment, IFCs 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. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the 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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a category B Project as key impacts can be avoided or mitigated by adhering to generally recognized environmental, health and safety, and social management practices and standards which both the Sponsor and APIX have experience with through the E&S management of the Initial Project. The main E&S issues include: physical displacement of four households – in contrast to tens of thousands displaced by the Initial Project – and economic displacement of around 936 persons many of which with land that are currently unused; management of traffic safety and air quality (dust) during construction; and the crossing of a section of protected (though degraded) forest

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Identification of Risks and Impacts



An Environmental and Social Impact Assessment (“ESIA”) commissioned by APIX was conducted in 2013 with the aim to meet both local regulatory requirements as well as those of the World Bank Group. The ESIA includes sections on identification of risks and impacts, environmental and social management programs, as well as public consultation. However, a socio-economic baseline of the affected communities has not been conducted due to both lack of access to the PAPs. In compliance with environmental assessment process in Senegal, the ESIA was publicly disclosed for comments by the “Department de L’Environnement et des Etablissements Classés” (“DEEC”) as well as other stakeholders. The ESIA was approved but the environmental permit has not yet been issued by DEEC.



Management Programs, Organizational Capacity and Competency

SENAC has an existing corporate environmental and social management system (ESMS), as well as an environmental policy that was developed as part of the previous IFC financing of the Initial Project. However, SENAC will be required to strengthen the proposed ESMP in the ESIA to include further stakeholder engagement in particular with respect to location of footbridges, pedestrian bridges, passageways (overpasses/underpasses) for wildlife and livestock noting that contractually the final decision belongs to GoS; emergency preparedness and response, and baseline study on air and noise. SENAC has an experienced EHS and social team that will be responsible for overseeing the implementation of the ESMS for the Project. Although APIX is responsible for the RAP implementation, SENAC has hired a social consultant to shadow APIX and engage with the communities.



The EPC Contractor has an Environmental, Health and Safety Management Plan (EHSMP) for the construction phase and an onsite EHS coordinator to oversee its implementation. The EPC contractor EHS management system is certified: NF EN ISO 9001 for Quality and NF EN ISO 14001 for Environmental Management. The EHSMP includes EHS procedures for hazard prevention and control; hazard reporting, incident prevention and reporting, use of personal protective equipment, emergency preparedness and response, waste management, first aid, audits, and EHS training. SENAC and the EPC Contractor have a joint Environmental Management Plan (EMP) that takes into account the requirements of the concession agreement and also includes a health and safety check list.

Emergency Preparedness and ResponseAccidents and emergency situations most commonly associated with road construction or operation include single or multiple vehicles, pedestrians, and/or the release of oil or hazardous material. Both SENAC and the EPC Contractor have developed an emergency preparedness and response (“EPRP”) plan for the construction and the operation phase for the Initial Project. The Plan describes the procedures to follow when handling an emergency situation such as fire
, explosion, hazardous material or waste spills, and injuries. It includes emergency training, emergency simulation exercises and communication between SENAC and emergency services such as fire departments and National Gendarmerie. The plan is adequate for an installation of this type, however, it should be updated to include the Project area.



Furthermore, as per regulatory requirement the local government agencies have to prepare a “Plan Particulier d’Intervention” (“PPI”) which is an emergency response plan. Given the local government low capacity to respond effectively, SENAC will play an active role in preparing for and responding to emergencies associated with the Project. Given SENAC’s experience and existing EPRP as well as proximity of some communities, this is a good opportunity for SENAC to assist the local government in developing the PPI. As previously indicated SENAC has documented its emergency preparedness and response activities, resources, and responsibilities, however it will need to provide appropriate information to potentially Affected Communities and relevant government agencies.



Monitoring and Review

National regulations require as part of the ESIA procedures that supervision of the ESMP implementation by an independent external consultant and the DEEC. Furthermore, IFC supervision activities during the construction phase will include quarterly EHS visits by a third party consultant.



SENAC current EHS monitoring program includes information on incidents/accidents, ESMP implementation monitoring, grievances, and recommendation from the EHS team. In addition SENAC currently submits an annual environmental and social monitoring report (“AMR”) to IFC which was mostly designed for the operation phase. SENAC will update its EHS monitoring program to include construction phase monitoring of solid and liquid waste generated, water consumption, incidents/accidents, and job creation within the local communities. An updated AMR will be developed in conjunction with IFC to take into account specific operational phase monitoring such as the forest management plan, and key RAP implementation monitoring indicators.



Particular attention will be given to incidents/accidents during construction as well as baseline dust monitoring. SENAC has put in place robust safety measures and an awareness program following a couple of fatalities in the Initial Project, therefore, and similar measures will be implemented upfront in the Project. With regards to air quality, significant levels of dust were observed in some populated areas such as Deni Biram and Yam, though others developments are also causing an increase in trucks movements on the same route. SENAC will establish a dust baseline even though the construction phase has begun: this will cover particulates less than 10μm (PM10) and less than 2.5μm (PM2.5).

SENAC has a human resources policy and procedures in compliance with local labor laws and generally with Performance Standard 2. Prior to employment, employees are required to take a medical exam to confirm their physical aptitude to meet the job requirements. SENAC does not hire candidates under 18 years of age and requires proof of identification prior to employment. Each employee (open ended or short term) is provided with a written contract that stipulates or references relevant labor code, and collective bargaining agreement and includes: (i) salary; (ii) terms of contract; (iii) terms of reference of the job; (iv) holidays (entitled after one year of service); (v) maternity leave; (vi) medical benefits ;(vi) probation period; (vii) pension. As per Senegalese labor laws, the employees have the right to join a union and to collectively bargain and as such there is a union in place with 10 elected workers’ representatives. Workers’ grievances are addressed through workers’ representatives and management. Currently SENAC has 240 employees of which 25 percent are women. Most of the employees including those in the management team are local hires. The Labor Code of the Republic of Senegal does not authorize women to work between the hours of 10 pm and 5 am with exception of the hospitality and medical industries; this limits SENAC’s ability to increase the number of women employees.



SENAC contractually requires that the EPC contractor verifies that all subcontractors respect Senegalese labor laws and undertake a basic due diligence on the subcontractors through a screening process before they are approved. Fire and life safety aspect as well as occupational health and safety are addressed in the Company’s Health Safety and Security Plan.



Approximately 800 workers will be employed during the construction phase of which about 80 percent can be sourced locally. Approximately 70 permanent staff will be employed during the operational phase, including toll booth operators, supervisors, in addition to subcontracted maintenance staff. Hiring for these jobs will be handled by a recruitment agency. SENAC has however, already provided information about job openings for toll booth operators in local high schools within the Project area.



As defined in the ESMP, the EPC Contractor is required to develop and implement a workers’ management plan that complies with Senegalese law. However, SENAC will ensure that its grievance mechanism is accessible to third party workers and will inform them of its functioning.



The Occupational Health and Safety (“OHS”) plan within the ESMP provides the overarching framework for OHS management during construction albeit both SENAC and EPC contractor have established OHS plans. All employees and contracted workers are expected to adhere to all OHS-related programs and requirements adopted by SENAC. Personal protective equipment such as steel-toed boots, uniforms, hard hats, goggles, ear plugs, and harnesses wil
l be provided to staff based on works undertaken. SENAC is committed to providing resources essential to the implementation and control of the ESMP.

Potential environmental impacts during the construction and operation of the highway mainly include increased rate of surface water runoff; generation of solid waste; air emissions in particular dust during the construction phase; traffic and heavy equipment noise. The EPC contractor is responsible for obtaining all permits and approvals. SENAC is required contractually under the concession agreement to execute the construction and operation phase in accordance with environmental protection regulations of the Government of Senegal and to implement an ESMP and monitoring program based on the mitigation measures in the ESIA and permits. As previously indicated, the EPC contractor is ISO certified for Quality and Environmental Management. SENAC will, similar to the Initial Project, verify that the following relevant recommendations and mitigation measures called for in the ESMP, and according to the applicable norms (surveys, permits, etc.), are integrated into a specific procedure by the EPC contractor, which include:(i) Dust control measures;(ii) Control of erosion and sedimentation;

(iii) Control for potential flooding within the forest crossing;(iv) Solid and liquid waste management (spill prevention, and waste disposal);(v) Noise mitigation; (vi) Emergency Response Plan; and(vii) Rehabilitation and restoration of disturbed areas.The ESIA does not outline data such as estimated water consumption, waste generation, baseline data on air emission and noise. SENAC is currently in the process of estimating such data based on its experience from the Initial Project.

Typical community health and safety issues associated with road projects generally involve dust and noise generation, pedestrian safety, traffic safety and emergency preparedness and response. Planning for the project includes the provision of footbridges, pedestrian bridges, passageways for wildlife and livestock, overpasses or underpasses and as previously outlined, their location should be discussed with affected communities to optimize their locations.



In this project, three sensitive areas have been identified: (i) crossing Deni Biram district; (ii) crossing Yam village; (iii) crossing the protected area of Sebikhotane forest. During construction, measurements for decreasing the speed of trucks will be provided at these sensitive social and environmental receptors to reduce traffic safety risks and nuisance impacts from dust, an issue which has been raised by some of the people interviewed and visible during IFC’s site visit. SENAC will ensure that the EPC contractor install and maintain speed reduction and traffic control devices at pedestrian crossings, in residential areas, and in the neighborhood of villages downwind from traffic.



As per the Initial Project, appropriate measures to mitigate potential risks and impacts with regards to community health, safety and security will be incorporated in this Project. This includes proper design of roads and installation and maintenance of all signs, signals, and markers, as well traffic safety measures such as speed controls, use of flagmen and dust suppression to improve visibility. Furthermore, a robust community awareness campaign will be organized to involve the communities in understanding and helping to play a role with regards to community safety.



As per phase I there are traffic wardens who are responsible for facilitating pedestrian crossing, traffic, and signaling trucks to reduce speeds as necessary. There are currently no armed security guards or plans to hire some.

Since 1950, the forest of Sebikhotane has been classified as a protected forest. It is currently managed by the Department of Water, Forestry, Game and Soil Conservation. The classification of this forest was motivated by two factors: (i) the creation of a partial game reserve to introduce and multiply certain game species. The ultimate goal was the creation of a wildlife reserve where hunting is prohibited and (ii) the protection of the villages below the ”plateau Diass” which are subject to a high risk of water erosion that threatens human settlements and crop areas. The forest covers an area of 1730 ha of which 520 ha are located in the regional department of Rufisque and 810 ha in that of Thiés. The Project crossing in the forest is a 5.5 kilometers stretch totaling 59.6 hectares which represents approximately 3.45% of the total forest. The ESIA indicates that the Project does not cross any area of high biodiversity value, however, it plays a role in both provisioning and regulating ecosystem services. The forest is Sahalian, the flora is mostly populated with shrubs and trees and dominated by species such as: Acacia ataxacantha, Acacia seyal, Borassus aethiopium and Adansonia digitata, which are partially protected according to the Forest Code of Senegal (R63) and cannot be destroyed or removed without prior authorization of the Department of Water, Forestry, Game and Soil Conservation. The ESMP outlines the measures to be undertaken to meet regulatory compliance.



The fauna is barely populated with some wild cats, guinea fowls, wild rabbits etc. The forest is very degraded mainly due to the use of wood as energy for subsistence as well as transformation into charcoal as an economic activity. The forest is also used for farming, herding and localized hunting.



The relevant portion of the forest located in the department of Rufisque was declassified by decree 2013-595, dated May 03 2013. A supplementary decree will be required to open up a section of the forest located in Thiés, covering 46.1ha.



As per the ESIA, a forest management plan including an offset will be prepared by APIX in collaboration with the Department of Water, Forestry, Game and Soil Conservation. A similar collaboration is in place for the Initial Project where implementation of the forest management plan is still ongoing. The Initial Project’s offset included two trees for every one destroyed and SENAC had to financially contribute. Based on discussion with APIX, itis expected that a similar action will be undertaken in the Project, however, the forest management plan has not yet been elaborated. The ESMP however indicates that the forest management plan will seek to preserve the ecosystem services of the forest and enhance the forest resources. SENAC will liaise with APIX and ensure that all construction works within the forest comply with the forest management plan, with particular attention to managing potential flood risk. Furthermore, SENAC as part of its m
onitoring plan will request periodic updates from APIX on the implementation progress of the forest management plan as well as on the ground results.

As part of the ESIA process, public hearings/consultations took place from June 17-21, 2010. APIX met with the villages within the highway right of way and held public meeting in each one of them. APIX provided information on the Project as well as answers to concerns raised by the communities. Stakeholder engagement was mostly based on local authorities, technical services, and village leaders and did not involve specific engagements with NGOs, women groups, and economic groups such as farmers and herders. Based on documentation, stakeholder engagement mainly took place during public consultations; it does not appear that a stakeholder analysis and engagement planning, disclosure of information, informed consultation and participation was thoroughly undertaken. Both APIX and SENAC have informed IFC of further engagement with communities and affected people during the RAP process however this has not yet been documented by either parties. As a requirement of this investment, SENAC will develop and implement a Stakeholder Engagement Plan which will identify key stakeholder groups; ensure that affected communities have access to sufficient Project information as soon as possible and in an understandable format; document all efforts to consult with affected communities and their representatives on Project impacts that affect them; and which incorporates a fit-for-purpose community grievance mechanism. As previously indicated, SENAC has hired a social consultant to supplement its capacity for the Project, noting that the consultant has been shadowing APIX in the RAP implementation and engaging with the affected communities. In addition the EPC contractor has an EHS coordinator who liaises with SENAC on any community related issues.

Some of the concerns raised by the communities were: (i) alleged land grabs by several projects such as the new University, the International Conference Center, the Project, and potential other projects that in the end might not leave them space to expand their villages; (ii) the Project taking their land without compensating them, a situation which they claim to have experienced with another project; (iii) access to potable water; (iv) employment opportunities during both construction and operation phases; and (v) access to education - secondary schools. The Stakeholder Engagement Plan will provide SENAC’s responses to key concerns raised.
SENAC has commissioned a few boreholes for use during the construction phase and has granted the communities with access to these boreholes which will be handed over to the villages after the highway construction is completed. SENAC will ensure proper handover to the communities or local authorities of the operation and maintenance of the boreholes.

SENAC S.A.
Avenue Felix Eboué/ Route des Brasseries
BP 737
Dakar
SENEGAL
Didier Payerne (mailto:didier.payerne@eiffage.com)

Broad Community Support is not applicable for this project

SENAC 2(33098) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
SENAC will develop and implement a stakeholder engagement plan which will include a community grievance mechanism	01-Aug-2014	Completed	Completed
SENAC will supplement the ESIA studies with baseline data on particulate matters on the highway right of way around areas with population density	01-Aug-2014	Completed	Completed
SENAC will update its emergency preparedness and response plan to include the Project area and provide appropriate information to potentially affected communities and relevant government agencies; and offer assistance to the local government in developing the “Plan Particulier d’Intervention.	01-May-2015	Completed	Completed
SENAC will ensure that its grievance mechanism is accessible to third party workers and will inform them of its functioning	01-Aug-2014	Completed	Completed
SENAC will ensure that the displaced school has access to potable water	01-Aug-2014	Completed	Completed
SENAC in collaboration with APIX will commission an external completion audit of the RAP to assess whether provisions have been met and submit the report to IFC	30-Jun-2019	In progress	Due date revised as agreed with IFC Client