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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
Performance Standard 5: Land Acquisition & Involuntary Resettlement is not expected to be applicable to this proposed investment as Mainstream leases land for all of its projects on a voluntary basis and is typically able to avoid physical and economic displacement via judicious turbine and infrastructure siting. Should compensation or other livelihood restoration measures be required for any Lekela project over and above agreed leasing arrangements, Mainstream will develop and implement a Livelihood Restoration Plan for that project. Performance Standard 7: Indigenous Peoples is not expected to be applicable to this investment as none of the medium or high probability pipeline project areas identified to date are home to known communities or Indigenous Peoples.

This corporate equity transaction will involve exposure to multiple large-scale wind and solar power projects in a number of African countries. Project-related risks for wind and solar projects under development and construction include land acquisition (although all land has been leased to date with no involuntary displacement); construction phase occupational health & safety; construction noise, dust and traffic management; construction contractor oversight; bird and bat collision risks and noise and shadow flicker impacts (wind); water usage (solar); potential cumulative impacts and stakeholder engagement. Given the significant capacity and footprint of many of the high-probability greenfield pipeline wind projects – at least five of which are greater than 100 MW in capacity) and their location in a diversity of national, local, natural and social contexts, this project has been categorized A.

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.

Policy & management systems
Both Mainstream and Actis, the two main shareholders of the Lekela renewables platform, are formally committed to meeting IFC Performance Standards (Equator Principles) and relevant World Bank Group Environmental, Health & Safety guidelines, in addition to relevant national E&S requirements for all target projects. This is captured in Mainstream’s ESG policies. Lekela, which is still in its formative stage, is in the process of establishing and adopting corporate ESG Code, establishing a formal ESG Board sub-committee to approve these policies and advise its teams, and hiring a corporate ESG Head. Lekela is committed to meeting all relevant World Bank Group E&S requirements mentioned above. Mainstream has commissioned independent third party Equator Principle reviews – including review against each IFC Performance Standard - of each of the more advanced assets in the Lekela pipeline to date. Lekela has also committed to ensuring that such a review is completed for each of its assets, including an E&S Action Plan (ESAP) necessary to address any compliance gaps.

At the corporate level, Mainstream (globally and in South Africa) is ISO 9001, ISO 14001 and OHSAS 18001 accredited - i.e. for quality, environmental and occupational health & safety (OHS) management. At the individual asset level, in addition to meeting the Performance Standards and instituting regular review of associated management plans, Lekela anticipates establishing management systems in line with ISO 14001 and OHSAS 18001 standards within three years of achieving commercial operations. Each Lekela project will also have its own ESG committee, in addition to the corporate board ESG committee mentioned above.

Identification of risks and impacts
Mainstream, which will develop and construct each of the Lekela assets, typically undertakes an initial E&S risk screening exercise during the asset identification and review stage. In South Africa the company has in-house developers with environmental expertise that assist the company to undertake a fatal-flaw analysis early on involving, amongst other aspects, potential E&S fatal flaws (e.g. overlap with protected areas, proximity to populated areas). Availability of relevant E&S information in South Africa is good, with various national databases containing useful information to feed into this analysis, for example a national bird atlas. Mainstream has a Geographic Information Systems (GIS) unit which assists in this early stage process to explore and, if need be, eliminate sensitive sites from the list of prospective wind and solar sites. In certain instances, Mainstream makes use of E&S consultants to assist with fatal flaw analysis.

Once a project is selected, the company commissions a comprehensive E&S Impact Assessment (ESIA) with corresponding E&S Management Plan (EMP) for each project. This assessment typically includes the necessary power transmission line infrastructure; where this has not yet been sited, a stand-alone ESIA and EMP are produced. The ESIA is conducted by a reputable E&S consultancy, e.g. in South Africa Mainstream has commissioned E&S assessments from firms such as CSIR, Savannah, ERM, Sivest and Aurecon. All wind projects in South Africa require a minimum of 12 months pre-construction bird and bat monitoring, in addition to other typical impact assessment aspects such as visual impact, noise, flora & fauna, socio-economics, cultural heritage (archaeology) and land use changes.

The E&S consultants contribute to the development of a ‘buildable area’ for each project, i.e. a detailed GIS-based map of each site that excludes environmentally or culturally sensitive areas such as bird nesting habitat, wetlands, grave sites, pockets of endangered fauna or flora species and/or other identified cultural artefacts. Project infrastructure is laid out accordingly, in conjunction with technical data which guides micro-siting of each turbine, panel, access road or other type of project infrastructure. In general, the quality of impact assessment studies reviewed by IFC for prospective Lekela projects in South Africa is in line with international standards as a result of strong regulations and the close involvement of Mainstream and its corporate policies throughout the project development process.

Mainstream sometimes acquires projects from local developers that have existing E&S assessments undertaken to national standards, for example in Ghana and Egypt. For any such projects in which Lekela plans to participate, Mainstream/Lekela will review the project against IFC Performance Standards (PSs) and commission any necessary supplemental studies. This may include, for example, a minimum of 12 months pre-construction bird and bat monitoring, more detailed field-based noise, fauna & flora, cultural heritage and socio-economic studies, and/or establishment of a well-structured project EMP to guide construction and operations (refer to ESAP action #1). The risk and impact identification process will take into account the findings and conclusions of applicable plans, studies or assessments prepared by the relevant authorities or other parties that are directly related to the project area of influence, e.g. strategic and/or cumulative impact assessments.

For example, in the 150 MW Ayitepa Phase 1 project in Ghana for which Mainstream recently took over the lead development role from a local partner, the company is currently reviewing and updating the E&S assessment, including commissioning supplemental bird, bat, noise and socio-economic studies. In Egypt, Lekela’s 50 MW wind project is located in an area set aside for multiple Feed-in-Tariff wind power projects; as such, the platform will participate and/or take into account the findings of area-wide bird studies focused on the cumulative impacts of the proposed wind projects.

Management programs
As noted above, an EMP (or ESMP) is, or will be, generated for each wind and solar project prior to the commencement of construction. Construction contractors are required to bid for work on Mainstream projects taking into account the approved EMP for each project. Walk-throughs are undertaken at each site with the relevant E&S experts to familiarize staff and contractors with potentially sensitive E&S aspects and no-go zones prior to the commencement of construction.

Organizational capacity
The Mainstream risk assessment and E&S due diligence process is described above under the identification of risks and impacts section. In brief, the company relies on a combination of experienced in-house technical staff and reputable E&S consultancies to identify and design mitigation programs for E&S impacts. During construction the responsibility for permit compliance is transferred to the construction contractor(s), which is required to appoint E&S Control Officers and Community Liaison Officers to monitor daily compliance and interact with local communities with respect to employment-related matters. Mainstream appoints an independent Environmental Control Officer for each project who audits environmental compliance in relation to EMP and any other E&S permit conditions on a monthly basis.

Mainstream also dedicates an in-house OHS officer to oversee construction health and safety performance and to coordinate with contractor OHS personnel and the Mainstream project manager. In addition, in South Africa, due to stringent Black Economic Empowerment and Local Economic Development requirements, each prospective Lekela project company has a dedicated Socio Economic Development (SED) Manager responsible for oversight of community development and stakeholder relations during construction and operations. A similar local economic development model is under consideration for operations in Ghana, Egypt and elsewhere in Africa as a means of building local license to operate (though not a national or World Bank Group requirement). At the Ayitepa wind project in Ghana, where a pre-feasibility stage assessment has been completed, Mainstream has appointed a local Community Liaison Officer to engage with potentially affected communities. Corporate and project level ESG Committees are discussed above under the policies and management systems section.

Monitoring and review
Project-specific monitoring requirements are incorporated into EMPs produced for each project. Daily and monthly monitoring and auditing of EMP compliance involving contractor staff, environmental compliance officers and Mainstream OHS and social staff is described in the section above. Mainstream utilizes E&S consultancies to undertake any specialized E&S monitoring required, for example bird and bat post-construction monitoring. Any E&S performance issues or incidents are reported to the Mainstream project manager for discussion and resolution and elevated as necessary to the regional or global management teams. Lekela has undertaken to develop a regular program of site safety and environmental audits in co-ordination with Mainstream as part of its forthcoming corporate ESG policies and procedures.

Lekela has recently commenced recruitment of senior executives. Mainstream currently employs around 40 staff in its African operations, mostly concentrated in the South African hub office in Cape Town. Of these, around 5-10 expatriate staff are employed in African operations at any given time. Many of these staff members will be engaged in the development of assets that will be acquired by Lekela in future. Construction is handled by way of two main contracts, namely turbine supply agreements covering manufacture, transport, erection and commissioning of turbines, and balance of plant agreements covering civil, electrical and other works excluding turbine supply. In South Africa Mainstream has worked predominantly with Siemens on turbine supply and with locally-based multinational construction group consortium of Murray & Roberts - Conco on balance of plant works to date, although other contractors may be utilized in future both in South Africa and in the rest of Africa.

Mainstream renewable energy projects of the type intended for Lekela ownership typically take 18 – 24 months to construct and involve 200 - 800 hundred workers during peak construction periods. For example, the 80 MW Noupoort WPP visited by IFC had around 200 workers on site at the time of IFC appraisal in July 2015 and will have a peak construction workforce of 350 workers. Operations phase staffing is much lower for both wind and solar projects, typically involving a handful of technical staff supported by varying numbers of lower-skilled security, maintenance and monitoring staff and contractors.

Both South Africa and Egypt have legally mandated minimum thresholds for use of local/national workers which Mainstream is currently in compliance with (in South Africa, construction is not yet underway in Egypt). Mainstream plans to uphold the principle of maximizing local employment wherever feasible at all of its project sites, irrespective of whether legal requirements are in place or not, in order to build and maintain social license to operate.



Human resource policies & procedures
Lekela, as a newly formed entity, does not yet have Human Resources (HR) policies or procedures but is expected to develop these in due course in keeping with international standards and the national labor laws of the countries in which its assets are to be located. Mainstream, the project developer, construction manager and future operator of Lekela power projects, has corporate HR policies and procedures, a Dublin-based HR team and HR consultants in countries in which it operates. Mainstream has an Employee Handbook which describes employee rights related to hours of work, wages, overtime, compensation and benefits and other working conditions. All employees receive clearly understandable written contracts specifying their rights and obligations and obligations under company and national employment regulations.

Working conditions and terms of employment
Mainstream employees in Africa are generally highly-skilled. Although there are currently no labor unions represented in the workforce, as expected given this profile of employee, both Mainstream and Lekela are committed to freedom of association and non-discrimination in the workplace as well as to offering reasonable working conditions and terms of employment. Some of the construction contractors utilized on Mainstream projects have unionized workforces and as such are subject to collective bargaining agreements.

To date there have been no worker accommodation camps at the Mainstream projects being targeted by Lekela. Should such accommodation be necessary in future, Mainstream will put in place and implement policies on the quality and management of the accommodation and provision of basic services in accordance with PS 2 requirements. This will entail requirements for construction contractors in relation to minimum space, supply of water, adequate sewage and garbage disposal systems, appropriate protection against heat, cold, damp, noise, fire and disease-carrying animals, adequate sanitary and washing facilities, ventilation, cooking and storage facilities and natural and artificial lighting, and in some cases basic medical services.

Non-discrimination and equal opportunity
Both Mainstream and Lekela are committed to non-discrimination and equal opportunity in the workplace. In South Africa Mainstream is obliged to comply with Black Economic Empowerment regulations with respect to the employment of a certain proportion of personnel from previously disadvantaged groups. As per PS 2, such special measures to remedy past discrimination in compliance with national law are not deemed to be discriminatory.

Retrenchment
Mainstream is a relatively new company, established in 2008, and is currently in expansion mode in Africa. It has a lean staff complement and relies upon contractors and suppliers for much of the labor-intensive work required to construct and maintain its power projects. As such, no collective dismissals from Mainstream-developed, constructed and operated Lekela projects are envisaged in the foreseeable future (retention rates are high and there have been no retrenchments to date in African operations). Lekela is a platform relying on Mainstream and Actis staff as well as a small cadre of senior technical and executive personnel which are currently being hired. As such collective dismissals are not foreseen.

Grievance mechanism:
Mainstream has developed a worker grievance mechanism in line with PS 2 requirements which is incorporated into its Employee Handbook. Contractor worker grievances are generally dealt with via national labor regulations. Mainstream will ensure that contract workers at projects in which Lekela plans to participate will have access to a viable worker grievance mechanism, in keeping with PS 2 requirements.

Protecting the workforce
Neither Mainstream nor Lekela allows the use of child or forced labor directly or by contractors. Procedures are in place to ensure that all workers provide suitable proof of identification and age prior to employment.

Occupational Health & Safety
Both Mainstream and Actis, the two main shareholders in Lekela, are strongly committed to OHS performance, and this is reflected in the Lekela business plan and draft ESG policies which commit the platform to adhere to internationally recognized OHS standards across all project sites. Mainstream has a Safety Committee at corporate level and deploys OHS officers to each project site during the construction phase. The company assesses the OHS risks of all of its activities in advance and provides active oversight during the key construction phase to ensure that employees and contractors are safe. Prime contractors are expected to be OHSAS 18001 certified and to meet strict OHS contract specifications. Prior to the commencement of construction, each project is required to have a site safety plan, work control procedures, OHS risk assessments and method statements. This will be reinforced during operations via the commissioning of assurance audits in accordance with OHSAS 18001 requirements.

Mainstream corporate OHS performance has been strong to date. In 2014 during which the company was involved in construction of wind and solar farms in South Africa, Canada, Chile, and Ireland, the corporate Lost Time Incident Rate was 0.2, which is below the global benchmark for the industry. In South Africa, Mainstream recorded 1.2 million man hours without a Lost Time Incident at the 138 MW Jeffrey’s Bay WPP, its first project in Africa involving around 700 workers at the peak of construction, 45% of whom were unskilled operatives from local communities. Mainstream circulates a quarterly OHS report with details of incidents, lessons learned and procedural updates.

Workers engaged by third parties
As described above, Mainstream relies on reputable construction and turbine supply contractors to help design, supply and construct the projects in which Lekela will participate. Measures taken to ensure adequate E&S and OHS oversight of these contractors, including incorporation of EMP requirements and strict OHS specifications into contracts, site walk-throughs before handover, site-level supervision by Mainstream staff and other related matters are covered in the paragraphs above. Lead construction contractors will be required to develop Emergency Response Plans for each site prior to the commencement of construction, as per ESAP action # 5.

Resource efficiency (greenhouse gases and water consumption)
Neither wind nor solar projects to be developed by Mainstream for the Lekela platform will have operational air emissions and both types of project will avoid carbon emissions versus existing thermal power generation profiles in South Africa, Ghana, Egypt and other African countries. For example, the 80 MW Noupoort WPP under construction in the Northern Cape (South Africa) will avoid approximately 300,000 tons of carbon emissions each year once operations commence in 2016, whilst the Khobab and Loeriesfontein II WPPs (both of 140 MW capacity, also in the Northern Cape) will each avoid an estimated 420,000 tons of carbon emissions per annum.

Construction phase water consumption is relatively limited and is a temporary impact; water is typically abstracted from available municipal sources or from private boreholes. Operations phase water consumption is very low for wind farms, and reasonably limited for solar PV projects. Mainstream is committed to implementing panel cleaning techniques that minimize water use, particularly at arid sites where water availability may be a constraint to local communities or municipalities. Estimated avoided water consumption at the operational 50 MW De Aar solar PV site which IFC visited during appraisal is reportedly 100 million liters per annum (versus existing thermal power generation alternatives in South Africa).

Pollution prevention
Construction phase pollution mitigation measures are incorporated into project-specific E&S assessments and associated management plans, a number of which were reviewed by IFC during appraisal of this project. These measures are generally designed to prevent site soil erosion; avoid pollution of soils and surface or groundwater sources by oils, greases, fuels or other potential contaminants; control dust generated by vehicle traffic; manage noise and vibration associated with site excavations (including blasting for turbine foundations) and civil works; store, manage and dispose of waste and hazardous materials in a responsible manner; and minimize emissions associated with heavy machinery use on site. Based on documentation reviewed for the more advanced South African WPP projects and site visits conducted in May 2015, construction phase pollution prevention strategies being implemented by Mainstream and its contractors are in line with PS 3 requirements.

Key pollution sources for operational wind farms include noise and visual impact, including potential shadow flicker effects. Mainstream implements appropriate set-back distances between turbines and inhabited structures which it applies to all projects as a way of minimizing the risk of potential noise and shadow-flicker impacts. Mainstream has undertaken detailed (field-based, quantitative) noise and visual impact studies for its South African projects which are incorporated into the respective E&S assessments and management plans. Outputs from these studies have been used to adjust the buildable area within each site in such a way as to minimize related impacts on surrounding communities and/or important public view sheds. Shadow flicker has not been an issue for these projects (e.g. Noupoort, Khobab and Loeriesfontein II WPPs) given their remote locations in scarcely populated parts of South Africa. The only real operational impact associated with solar projects besides panel-cleaning water disposal is visual impact. Visual impact assessment is included in the project-specific E&S assessments and management plans and forms part of the public consultation process with interested and affected parties.

Community health & safety
Though turbine and solar PV plant sites are generally located away from human settlements and other sensitive receptors, the main risk to local communities in addition to noise, dust and visual impacts (covered in the pollution prevention section above) is construction phase road traffic. This typically involves a combination of site-based traffic movements and increased traffic on main access routes to the site to facilitate worker and equipment access. It includes the need to transport large components such as nacelles, blades and wind tower sections to site on abnormal load vehicles with emergency response escorts. To mitigate these impacts, Mainstream incorporates traffic and transport studies and plans into its third party E&S assessments and management plans for each project. Relevant actions, e.g. driver safety awareness training, institution of speed limits and coordination with local authorities and communities, are incorporated into EMPs for implementation by construction contractors. Mainstream will, on behalf of Lekela, ensure that construction contractors (including turbine suppliers and their transportation agents) implement all agreed traffic and transport-related mitigation measures.

Security personnel
Mainstream retains the services of a security consultancy which undertakes security assessments for each of its projects as part of its corporate due diligence process. This firm also provides periodic training to staff on possible security risks and evasion techniques and supports staff in situations where there are indications of security threats such as threatened community protests. Mainstream requires its construction contractors at each site to engage private security contractors to prevent theft and control site access. To date, none of these security personnel have been armed. The only security incidents reported to date at the projects in the Lekela pipeline have been minor incidents of theft at the Noupoort WPP site. These have been addressed via installation of a security alarm system.

Should armed security personnel be required on future Mainstream/Lekela sites, either in South Africa or elsewhere (e.g. Egypt, where security risks are elevated currently), the company will undertake security risk assessments commensurate with the national and local context and ensure that its prime contractors act in accordance with PS 4 requirements (refer to ESAP action # 3). This will include screening past records of any armed security personnel employed; providing security personnel with clear objectives and codes of conduct vis-à-vis community interactions and use of force; training of security personnel in avoidance of abusive conduct; establishing and communicating clear protocols for use of weapons and recording/investigating all security incidents. Any bona fide complaints against security personnel will be investigated and appropriate disciplinary actions implemented and the worker/community grievance mechanisms described in the PS 2 and stakeholder engagement sections will be made available for aggrieved community members or employees in the event of alleged violations of codes of conduct for security personnel.

Biodiversity protection and conservation
As described in the identification of risks and impacts section under PS 1 above, Mainstream screens each of its prospective development sites against biodiversity criteria such as proximity to protected areas or known importance of the area to concentrations of endangered species. This is part of an initial fatal flaw analysis which makes use of GIS databases, staff and consultant know-how and public information such as the South African bird atlas produced in consultation with BirdLife and other key biodiversity stakeholders. To date, none of the sites earmarked for Lekela ownership in South Africa has been located in close proximity to ecologically sensitive sites or protected areas.

Each wind and solar project to be developed in South Africa for the Lekela platform either has, or will be, subjected to specialist biodiversity (fauna, flora and habitat integrity) studies as well as stand-alone bird and bat studies in the case of wind power projects. As per South African legal requirements the biodiversity studies undertaken to date have been both field and desktop based and have been used to delineate buildable areas within each project site through avoidance of potentially sensitive species and habitats identified. Search and rescue efforts are implemented prior to construction to move any identified protected species from the buildable area, and maps demarcating no-go areas (sensitive biodiversity sites) are developed and shared with the construction contractor prior to commencement of construction. Mainstream will ensure that a similar approach, i.e. field and desktop studies by reputable experts feeding into detailed project design, is taken with respect to renewable energy sites to be developed elsewhere in Africa for the Lekela platform (as per ESAP item # 1).

Bird studies in South Africa, where the three most advanced projects targeted by Lekela are located, have been based on the South African Best Practice Guidelines for Avian Monitoring and Impact Mitigation at Proposed Wind Energy Development Sites produced by BirdLife South Africa and Endangered Wildlife Trust (Jenkins et al, 2011, to be updated imminently). These guidelines recommend a minimum 12 month pre-construction bird baseline study, which has since been translated into South African impact assessment regulations. Pre-construction bat studies are based on the South African Guidelines for Surveying Bats at Wind Energy Facility Developments - Preconstruction (Sowler, Stoffberg et al, latest edition 2014), whilst post-construction monitoring will be based on the South African Good Practice Guidelines for Operational Monitoring for Bats at Wind Energy Facilities (Aronson et al, 2014).

In Ghana, the proposed Ayitepa WPP project is located approximately 10 km west of the Songor Lagoon, a designated Ramsar site and one of the two major lagoon systems associated with the Volta river estuary. This lagoon habitat, though modified through salt mining and other human activities, is reportedly an important roosting area for migratory water birds, particularly in September-October each year. Mainstream has reviewed the existing E&S report prepared for this project and has commissioned supplemental avian studies involving a reputable international E&S consulting firm and the Ghanaian Wildlife Society (GWS). These baseline studies are based on the South African standard of a minimum 12-month pre-construction monitoring period and will utilize a mix of internationally recognized sampling methods and a reference site. Findings will be incorporated into detailed project design and the updated E&S impact assessment and management plan. As noted in the project description section above, IFC is likely to lead the debt financing of this project should it proceed and as such has begun engaging with Mainstream in relation to producing an internationally acceptable avian impact assessment and post-construction monitoring protocol. A comprehensive project-specific E&S Review Summary report incorporating more detailed analysis of avian impacts and proposed mitigation measures will be disclosed for that project.

In Egypt, Mainstream’s prospective 50 MW WPP site is located on the west bank of the Gulf of Suez, in the general vicinity of the Red Sea/Rift Valley flyway, a major international bird migration route. Whilst this area has been the subject of a number of ornithological studies by wind developers, the Egyptian government and international conservation organizations such as BirdLife, the project is at too early a stage to identify what the bird-related risks are. At least a year of pre-construction avian baseline studies will be undertaken at all wind power sites targeted by Lekela by reputable ornithologists using internationally recognized sampling methods. In addition, at least two years of post-construction bird monitoring by qualified experts will be undertaken at such projects (longer if monitoring results indicate problems or if the site is located in a particularly sensitive area such as an international flyway; refer to ESAP action # 4).

Protection of cultural heritage in project design and execution
Cultural heritage assessments are almost invariably built into the E&S impact assessment requirements of each country of interest, although the degree of effort mandated by national regulations may vary, e.g. fieldwork required (South Africa) versus a desktop-only study (Ghana). Detailed field-based cultural heritage assessments have been conducted for each prospective Lekela project site being developed by Mainstream in South Africa. A number of potentially significant cultural heritage sites and artefacts have been identified at each site (e.g. old burial mounds, gravesites and ancient rock paintings). In each case, these sites or artefacts have been either removed from the buildable area or otherwise protected, in keeping with permit conditions from the relevant authorities.

In order to ensure consistency of approach and to meet PS 8 requirements, Mainstream will ensure that suitably detailed field and desktop based cultural heritage studies are undertaken at each of its power project sites earmarked for Lekela ownership during the E&S assessment phase, and that associated findings are incorporated into project design and into project EMPs (as per ESAP action # 1). Construction contractors will be required to systematically develop and implement a Chance Find Procedure for any unanticipated finds, as well as an Emergency Response Plan as part of standard contractual obligations, if not already part of the EMP (refer to ESAP action # 4).

Pre-construction stakeholder engagement, disclosure and consultation in Mainstream’s South African projects earmarked for Lekela ownership has been focused around the legally mandated E&S assessment process. This involves a multi-stage public consultation and disclosure process in which key stakeholders are identified, provided with a summary of the proposed project, provided with opportunities to raise issues for consideration in the main E&S assessment phase, and then provided with the outcome and recommendations of these detailed studies and approached for final comments. Advertised public meetings are generally held at least once during the E&S Scoping phase, and again during the detailed E&S investigation phase and conclusion. Summaries of public comments and associated responses, where applicable, are disclosed as part of the final impact assessment documentation which must be publically disclosed for a set period of time prior to approval by the authorities. Separate and more in-depth consultations are typically entered into with landowners whose plots are to be leased by the project, as well as with any nearby communities with respect to understanding their socio-economic challenges and employability.

Once construction begins, Mainstream expands its engagement process significantly to encompass South African’s mandatory local economic development requirements. As noted in the organizational capacity section of PS 1 above, each prospective Lekela project company has a dedicated Socio Economic Development Manager responsible for oversight of community development and stakeholder relations during construction and operations. Mainstream sets aside a modest budget allocation for social spending during construction, whilst in the operations phase a much more substantial annual sum – based on a percentage of project revenue – is made available for social spending.

A similar local economic development and engagement model is under consideration for operations in Ghana, Egypt and elsewhere in Africa as a means of building local license to operate. A Mainstream Community Liaison Officer has been appointed at the Ayitepa project in Ghana to better understand and interact with affected communities and help arrange the leasing of project land from local clans. The company has also prepared a draft Stakeholder Engagement Plan, in keeping with PS 1 requirements, to identify key stakeholders and show how each group will be engaged with during key project phases. In general, although the impact assessment-related stakeholder engagement process in South Africa does not incorporate a formal Stakeholder Engagement Plan as per PS 1 requirements, the combination of this process with the subsequent intensive local economic development engagement model appears to substantively meet the objectives of the PS. In future, in keeping with PS 1 requirements, a Stakeholder Engagement Plan will be developed and implemented for each Lekela designated project outside of South Africa. This plan will include all key aspects required under PS 1 including, amongst others, a community grievance mechanism and a process to ensure ongoing reporting to communities on matters that impact them during construction and operations (refer to ESAP action # 2).

Mainstream’s Project Manager and Socio Economic Manager play a key role in overseeing interactions with project stakeholders during the construction and operations phase, in collaboration with construction contractor Community Liaison Officers. This involves ongoing and iterative engagement with key stakeholders throughout these phases.

Mainstream develops and communicates community grievance mechanisms for each of its sites during the E&S assessment process. These mechanisms are designed so as to be accessible to all segments of the affected communities and describe the procedure for receiving, documenting, addressing and resolving complaints related to project activities. During construction, both a company representative and a construction contractor representative are identified as contact persons for grievances redress and liaison with local landowners, communities and authorities.

No significant objections or opposition have been reported to date in relation to the projects being developed by Mainstream for Lekela ownership, although many day to day issues have arisen. For example, some concerns were recently raised by community members regarding local labor and supplier recruitment at the Noupoort and Loeriesfontein II WPPs in South Africa. These concerns have been addressed by a revision of the labor and supplier recruitment procedures in order to increase transparency and clarity on the process and through ongoing meetings with the local municipality and community leaders.

It is not envisaged that any of the high probability Lekela projects will involve significant adverse social impacts on local communities. The three wind projects in South Africa are all located in the sparsely populated Northern Cape Province and no local communities are directly affected. In the case of the Khobab and Loeriesfontein II projects, the nearest community is located in the town of Loeriesfontein around 60 km from site, whilst at Noupoort the site is located several kilometers from the small town of Noupoort. The west Gulf of Suez WPP in Egypt is located in a semi-desert area with no adjacent communities. The Ayitepa WPP site in Ghana has no people living on it, but is surrounded by a number of local clans. As noted above, project land will be leased from these clans on a voluntary basis and other project social impacts are not expected to be significantly adverse. As a result, IFC does not foresee a need to undertake a broad community support assessment for any of these projects prior to Board, in line with the IFC Sustainability Policy (2012).

Emmet Curley
Head of Communications
Mainstream Renewable Power Ltd.
Top Floor Arena House
Arena Road
Sandyford, Dublin 18
Ireland
Tel: +353 (0)1 290 2027
mailto:emmet.curley@mainstreamrp.com

Broad Community Support is not applicable for this project

MainstreamAfrica(36845) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Projects acquired from other developers in which Lekela will participate which have existing E&S assessments/approvals will be reviewed against IFC requirements by reputable E&S consultants and supplemental studies necessary to meet any gaps will be commissioned. This may include, for example, 12 months pre-construction bird and bat monitoring, detailed noise, fauna & flora, cultural heritage and socio-economic studies, a livelihood restoration plan if any economic displacement is required and compiling of a well-structured project EMP to guide construction and operations. Impact assessment will involve field and desktop studies by reputable experts and feed into project design. The risk and impact identification process will take into account the findings and conclusions of applicable plans, studies or assessments prepared by the relevant authorities or other parties that are directly related to the project area of influence, e.g. strategic and/or cumulative impact assessments.	31-Dec-2017	Completed	Completed	11/30/2017
A Stakeholder Engagement Plan will be developed and implemented for each Lekela designated project outside of South Africa. This plan will include all key aspects required under PS 1 including, amongst others, a community grievance mechanism and a process to ensure ongoing reporting to communities on matters that impact them during construction and operations.	31-Dec-2017	Completed	Completed	12/30/2017
Should armed security personnel be required at Lekela-designated sites in future, security risk assessments will be undertaken and contractors will be required to act in accordance with PS 4 requirements. This will include screening past records of any armed security personnel deployed; providing personnel with objectives and codes of conduct vis-à-vis community interactions and use of force; training of personnel in avoidance of abusive conduct; establishing and communicating clear protocols for use of weapons; recording/investigating security incidents and providing aggrieved community members or employees with access to grievance mechanisms in the event of alleged violations.	31-Dec-2017	Completed	Completed	11/30/2017
At least a year of pre-construction avian baseline studies will be undertaken at all wind power sites targeted by Lekela by reputable ornithologists using internationally recognized sampling methods. In addition, at least two years of post-construction bird monitoring by qualified experts will be undertaken at such projects (longer if monitoring results indicate problems or if the site is located in a particularly sensitive area such as an international flyway).	31-Dec-2017	Completed	Completed	12/30/2017
Construction contractors will be required to systematically develop and implement a Chance Find Procedure for any unanticipated finds, as well as an Emergency Response Plan as part of standard contractual obligations, if not already part of the EMP.	31-Dec-2017	Completed	Completed	11/30/2017