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
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 according to IFC’s Environmental & Social Review Procedure as the E&S impacts associated with the project are limited as the project is sited within an existing industrial development area. The area is generally not suitable for agriculture and grazing and is not used for that purpose by local communities. The land ownership of the project area resides with the Ma’an Development Company (MDC), which is mandated by the Government of Jordan as the land owners of the MDA. There has been no physical or economic displacement with respect to this project, therefore PS5 on Land Acquisition and Involuntary Resettlement is not applicable to this proposed investment.

No significant biodiversity values are associated with the site as the MDA area is largely considered to be degraded. Although Jordan is known to be located within a the Red Sea / Rift Valley flyway for migratory birds, Important Bird Areas (IBA) as designated by BirdLife International, are not located in the vicinity (the nearest one, Petra IBA, is approximately 25km to the west of the project site). For these reasons, PS6 on Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable. There are no Indigenous Peoples in the project area, and therefore PS7 on Indigenous Peoples is not applicable. An Ottoman military camp, likely used during railroad construction (a culturally significant find), was recently identified via Jordan’s Ministry of Antiquities approximately 900-meters from the project site, on land allocated to another PV developer in the MDA. The site is being managed by that other developer and is fenced off. An on-site survey did not reveal cultural heritage on the sub-projects sites, therefore PS8 is not applicable. The project will implement in any case a Chance Finds Procedure.

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.

Adenium is in the process of developing an overarching E&S Policy and an H&S Policy that will apply to all three sub-projects, as included in ESAP Action Item number (#) 1. The policies will be specific to the activities in Jordan, reviewed and approved by the developer’s Managing Director and applicable to the EPC contractor / O&M provider and sub-contractors. The developer’s Environmental and Social Management System (ESMS) will consist of these policies; an Environmental and Social Management Plan (ESMP) for each sub-project, which includes monitoring actions; an overarching system for reporting and tracking non-compliances in a coordinated manner, project-wide; and, an organizational framework.



Currently, monthly updates are received by the developers from the management teams of each sub-project. Communication between the field teams for each sub-project and the developers occurs regularly.





Environmental and Social Assessment



Three separate ESIAs were prepared by a local consulting company (Arabtech Jardaneh) according to the requirements of the Jordanian Environmental protection law no. 52 / 2006 for each sub-project. The ESIAs include a scoping session held with the stakeholders and was designed to meet international standards. The ESIAs include a review of applicable legislation and standards with potential implications to the project; a description of the activities that will need to be performed over the life of the project; and identification of risks and impacts (including positive impacts). The ESIAs also include an E&S baseline study (covering, for example, air / noise quality, biodiversity, cultural heritage, etc.) against which impacts of the project can be assessed. An alternatives assessment was also carried out. Stakeholders were identified prior to the scoping sessions and methods of communication were explored. Mitigation and monitoring measures to minimize identified adverse impacts were also identified and included in the ESMP.



Regarding social-related impacts, based on IFC''s site visit and discussions with E&S specialists in Jordan, the use of the project area for grazing by semi-nomadic Bedouin communities is unlikely. Nonetheless, the company will strengthen the social-components of the ESIA and conduct a review to confirm that adverse social impacts are not incurred by local populations, including project-related impacts related to collective grazing as identified in ESAP Action Item #2. One review will be conducted for all three sub-projects. Mitigation measures will be determined, as necessary.



Management Program



Each ESIA contains an ESMP for the construction and the operations phases of the project. Management actions include solid waste management, soil management, dust control, wastewater disposal, occupational H&S, amongst other topics. The ESMP includes monitoring actions, frequency of monitoring, performance indicators and the responsible entity. As identified in ESAP Action Item #
3, the developer will report and track non-compliances in a coordinated manner across all three sub-project with respect to commitments made in the ESMP and monitoring outcomes.



The EPC contractor / O&M provider will ensure that staff understand all requirements, measures, and protocols stipulated within the ESMP. They will also ensure that all E&S personnel are competent to carry out their duties, or, where necessary, arrange for suitable training to be undertaken.



Organization



The E&S management team will consist of one on-site E&S focal point for the project (i.e., one individual covering all of the three sub-projects) during construction and one E&S focal point during operation based off-site, as identified in ESAP Action Item # 4. Additional E&S support staff will be procured during the construction phase as required to ensure that environmental management practices are carried out. A community liaison officer will be retained in coordination with other developers in the solar park and the MDA for both the construction and operations phase and will report to the E&S focal point. The community liaison officer will develop and implement a local benefits community action plan and will manage the community grievance mechanism. The E&S focal point will be responsible for the implementation of the ESMP, including monitoring actions.



Monitoring and Reporting



Monitoring requirements are included in the ESMP for the construction and the operations phases of each sub-project as mentioned in the sub-section above on ‘Management Program’ in this document. Environmental monitoring by the Ministry of Environment in Jordan is not required for this sector.





Emergency Preparedness and Response



An Emergency Preparedness and Response Plan (ERP) is required for the license issuance for each sub-project and will be designed to be location-specific (referencing muster point, nearby emergency facilities, responsible entities on-site or in the region, etc.). Each ERP plan will follow the US National Fire Protection Association (NFPA) standard and will be developed for construction and operation phases of the project. The EPC contractor / O&M provider will provide adequate training to staff to ensure that workers on-site are familiar with the ERP.

The developer will create 30 indirect jobs during construction and 25 indirect jobs during operations. In total, 9 direct jobs will be created throughout the construction and operation phases. All jobs are projected to be offered to Jordanian nationals. Adenium will develop a local hiring plan to encourage recruitment from Ma’an city and will use best efforts to coordinate local hiring efforts with neighboring PV developers in the MDA.



As identified in ESAP Action Item #5, Adenium will put in place a Human Resources Policy and Procedures in line with IFC’s Performance Standard 2 and with Jordanian labor law that applies to all sub-projects. Given the nature of the industry, the Human Resources policy and procedures will place emphasis on the management of contractors and will apply to the EPC contractor / O&M provider and sub-contractors. The HR policy and procedures will stipulate that the terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation and holiday, are established according to national labor regulations, and will be included in employee contracts. Additional workers’ benefits for full-time operations staff will include health insurance and medical assistance, among others. Working conditions (including health, safety and security), employee termination, prohibition to employ minors, disciplinary actions, workers’ rights and obligations, employer’s rights and obligations will also referenced.



As also indicated in ESAP Action Item #5, Adenium will ensure that the Human Resource Policy and Procedures as developed by the EPC contractor / O&M provider are consistent with their own Human Resources related documents.



Jordan is a signatory to numerous international conventions and treaties. Examples relevant to labor rights include ILO Convention 98 on the Right to Organise and Collective Bargaining Convention; ILO Convention 100 on Equal Remuneration; ILO Convention 111 on Discrimination (Employment and Occupation).



In line with Performance Standard 2, the developer’s Human Resources Policy will not impede workers from freedom of association and collective bargaining. Although Jordan is not a signatory to the ILO Convention 87 on Freedom of Association and Protection of the Right to Organize, workers will be able to organize among themselves and will not be discriminated against for doing so, as will be specified in the Human Resources Policy and Procedures.



The developer is committed to avoid all forms of discrimination against its employees, based on the age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs of its counterparties. The requirements of non-discrimination and equal opportunities will be extended to all contractors and subcontractors as part of contractual obligations.



The developer’s Human Resources Policy will exclude the use of any
form of forced or compulsory labor, in accordance with national law and IFC PS 2.



As indicated in Action Item #6, training for direct and indirect workers will be covered in the developer’s HR procedures. Induction training on the Human Resources Policy and Procedures and basic safety awareness training will be provided to all newly hired workers. Other types of technical skills training will be identified for staff on an as-need basis.



As indicated in ESAP Action Item #7, the project will develop and make available a grievance mechanism for workers. The developer will inform the workers of the grievance mechanism, through the EPC contractor / O&M provider and otherwise, and describe how to make use of it during the induction training. The grievance mechanism will also be accessible to other contractors and subcontractors performing work in core business processes of the project.





Occupational Health and Safety



Key occupational, health and safety (OHS) risks for a PV project include slips and falls, potential hazards from on-site moving machinery, heavy load lifting, exposure to electric shocks and burns. Taking into account the hot and arid project site, construction workers might be at risk of dehydration, heat exhaustion and heat stroke if not hydrated properly.



The developer has identified OHS issues related to construction activities in each of the three ESIAs. As identified in ESAP Action Item #8, the developer will ensure that the EPC contractor / O&M provider develop a site-specific OHS Procedure for the construction and operations phases for each of the three-subprojects. The procedure will be designed to be specific to the PV solar sector (in terms of industry specific hazards) and the sub-project sites.



The developer will also ensure that the EPC contractor / O&M provider assesses and tracks its OHS performance during both construction and operations. OHS performance evaluations will be carried out for employees considering lagging (or trailing / downstream) indicators and leading (or upstream) indicators. The E&S focal point will record and track any OHS incidents through an incident tracker and will report on OHS performance during both construction and operation phase.

Given that the project involves PV rather than Concentrated Solar Power (CSP) technology, water consumption will be minimal. The frequency of washing and cleaning of the PV panels is still under investigation by the developer. Dry brush cleaning solutions will be considered. Potable water and wastewater will be hauled out of the site in appropriate vessels. Provisions for freshwater or wastewater drainage will not likely be needed.



Both solid and hazardous waste generated by the projects during construction will be minimal. Solid (paper, wood, plastic, scrap metals, glass, mud and food waste) and hazardous (absorbent material, batteries, tires, metal drums, empty chemical containers and waste oil from machinery lubricants) waste streams will be segregated and volumes recorded. Solid waste collection will be managed by a licensed third party and disposal will take place in the municipal and construction waste landfills designated by the municipality of Ma’an. During operation, waste generated will be limited to wastewater from maintenance and cleaning activities in addition to domestic waste. A self-standing Solid Waste Management Plan will be developed and implemented as part of the overall ESMP. Hazardous waste will be collected by a licensed third party and disposed of in a Hazardous Waste Treatment Center (designated by the municipality of Ma’an). Hazardous materials will be stored in a dedicated area; a register will be maintained and Material Safety Data Sheets displayed.



In terms of carbon dioxide emissions, the project overall will avoid emissions that would be otherwise produced in case fossil fuels were used for power generation. According to the ESIA, the expected reduction during the lifecycle of the PV project will reach 46,229 tons of carbon dioxide-equivalent per year (CO2eq/year) collectively at full capacity. During decommissioning, the developer is considering joining a PV recycling program. The ESIA covered the alternatives for this project such as importing fuel which incurs additional greenhouse gas emissions and is costly given the current shortage in the region. The PPA agreement specifies that NEPCO will apply, register and benefit from carbon credits.

A licensed private security company will be hired by the project to manage security and the MDA will have its own security arrangements including a perimeter fence, controlled access, and possibly checkpoints. The licensed security provider will supply guards trained in the use of weapons and appropriate use of force. Given the potentially volatile security situation in the region, and recent protests in Ma’an, the company will ensure that key elements of PS 4 are implemented, as follows: when the developer retains a security provider to safeguard its personnel and property, it will assess risks posed by its security arrangements to those within and outside the project site, including the residents of the nearest towns. In making such arrangements, the developer will be guided by the principles of proportionality and good international practice in relation to hiring, rules of conduct, training, equipping, and monitoring of such workers, and by applicable law. Adenium will make reasonable inquiries to ensure that those providing security are not implicated in past abuses; will train them adequately in the use of force (and where applicable, firearms), and appropriate conduct toward workers and nearby communities; and require them to act within the applicable law. The developer will not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat. These safeguards will be captured in a Security Management Plan that includes a training module for security staff, as included in ESAP Action Item #9. The developer will provide a grievance mechanism for nearby communities to express concerns about the security arrangements and acts of security personnel, as included in ESAP Action Item #10 below.

Meetings with the General Manager of the MDA, Ma’an Chamber of Commerce, and the university were held as part of the stakeholder engagement initiatives undertaken by the developer as part of the scoping session in the developing of the ESIA. MDA is working with the municipality to follow the Jordan mandate for socioeconomic development. Civil society and academia, Ma’an governorate advisory council give attention to the solar park development; the deputy governor has attended all the scoping sessions.

The developer has taken initiatives where they brought the various solar companies in the solar park together to collectively decide on the approach to serve the community on a wider scale. Direct and indirect benefits could cater for commercial needs and training of the existing Ma’an community. Each developer has agreed to contribute to a corporate social responsibility (CSR) fund and work with community representatives as mentioned above to strengthen outreach to the community through offering public services that emerge from need assessments.

Adenium plans to develop a CSR program and will use best efforts to align initiatives with neighboring PV solar companies in the Ma’an Development Area. The CSR program will be used a as a means to engage with the communities. CSR efforts will include vocational training through the existing training facility as well as other topics directly relevant to community interests. At the time of the IFC team visit, a meeting was conducted between the sponsor and the governor in Ma’an to find means to assess the community needs as an initial step.

As identified in ESAP Action Item #10, the developer will use best efforts to develop a joint Stakeholder Engagement Plan (SEP) in coordination with neighboring companies, as feasible; in the absence of a collective SEP, the company will develop one for its own operations in compliance with PS1. The SEP will include a stakeholder identification and analysis. It will also include the development of a grievance mechanism in collaboration with neighboring companies and the MDC, as feasible; in the absence of a collective grievance mechanism, the company will develop a grievance mechanism, in compliance with PS1, for its own operations.

Some companies in the MDC are working closely with the Energy, Water and Environment Association (EDAMA), which is the local industry association that seeks sustainable solutions for energy and water independence and productivity. EDAMA is chairing the Ma’an vocational training center and is organizing the opening and job fairs. Academic engagement is the starting point due to the presence of the university in close proximity to the development area. The review of curricula to bring RE technologies into focus is being discussed. The developer will use best efforts to participate in these initiatives with other developers through EDAMA and MDC.

Client’s contacts:

Mohammed Ghalayini
General Manager
Adenium Solar Jordan
Mob: +962 78 5959 770
Mob: +1 416 666 8077
Fax: + 971 4 385 7996
Email: mailto:mohammed.ghalayini@adeniumcapital.com
http://www.adeniumcapital.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Adenium Energy Capital will develop its own Environmental and Social (E&S) and Health and Safety (H&S) policy that is relevant to business activities in Jordan.	12/30/2014 05:00:00 PM	In Progress	Due date revised as agreed with IFC client
Adenium Energy Capital will conduct a review on the use of the project area by semi-nomadic Bedouin communities for grazing and any potential related impacts. Mitigation measures will be developed, as necessary.	12/30/2014 05:00:00 PM	In Progress	Due date revised as agreed with IFC client
Adenium Energy Capital will report and track non-compliances in a coordinated manner, across all three sub-projects in accordance with monitoring actions included in each of the sub-project's Environmental and Social Management Plan (ESMP).	1/31/2015	In Progress	In Progress
Adenium Energy Capital will ensure that there is an on-site environmental and social (E&S) focal point during construction, and support staff, included a community liaison officer, as needed; and, one E&S focal point during operation based off-site.	06/30/2015 05:00:00 PM	In Progress	Due date revised as agreed with IFC client
Adenium Energy Capital will develop a Human Resources Policy and Procedures in line with IFC’s Performance Standard 2 and with Jordanian labor laws and will ensure that the Human Resource Policy and Procedures as developed by EPC contractor / O&M provider are consistent with commitments made in their own Human Resources related documents.	12/30/2014 05:00:00 PM	In Progress	Due date revised as agreed with IFC client
Adenium Energy Capital will ensure that basic training on Human Resource policies and procedures are provided as part of induction and will ensure that the EPC contractor / O&M provider provides an overarching E&S training to all employees and contractors.	12/30/2014 05:00:00 PM	In Progress	Due date revised as agreed with IFC client
Adenium Energy Capital will develop and make available a grievance mechanism for workers.	12/30/2014 05:00:00 PM	In Progress	Due date revised as agreed with IFC client
Adenium Energy Capital will ensure that a site-specific Occupational Health and Safety (OHS) Procedure is developed for the construction and operations phases for each of the three-subprojects.	08/31/2015 05:00:00 PM	In Progress	Due date revised as agreed with IFC client
Adenium Energy Capital will develop a Security Management Plan, including a training module for security staff, that aligns with the requirements of Performance Standard 4.	12/30/2014 05:00:00 PM	In Progress	Due date revised as agreed with IFC client
Adenium Energy Capital will use best efforts to develop a joint Stakeholder Engagement Plan (SEP) and collective community grievance mechanism, in coordination with neighboring companies, as feasible; in the absence of a collective SEP and grievance mechanism, Adenium Energy Capital will develop both for its own operations in compliance with PS1. The SEP will also include a stakeholder identification and analysis.	1/31/2015	In Progress	In Progress