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Environmental & Social Review Summary
Project Number
37567
Company Name
GIA LAI ELECTRICITY JOINT STOCK COMPANY
Date ESRS Disclosed
Feb 5, 2016
Country
Viet Nam
Region
East Asia and the Pacific
Last Updated Date
Apr 20, 2023
Environmental Category
A - Significant
Status
Completed
Previous Events
Approved : May 12, 2016
Signed : May 27, 2016
Invested : Jul 7, 2016
Sector
Small Hydro (<10MW) - Renewable Energy Generation
Industry
Infrastructure
Department
Regional Industry - INF Asia & Pac
Project Description
Gia Lai Electricity JSC (“GEC” or “the Company”), founded in 1989, is one of the Vietnam’s largest private-sector independent small hydroelectric power producers. GEC owns and operates 15 existing hydro power projects (“HPPs”) totaling 84MW in installed capacity. The majority of GEC’s portfolio is small hydro power projects, ranging from 0.3MW to 16MW. It has around 278 staff.
GEC’s business model mainly consists of the development and acquisition of small HPPs, wind and solar projects. While GEC’s ownership varies from project to project, it usually assumes an active leading role in design, construction, and operation depending on the project stage.
The International Finance Corporation (IFC) – the private sector investment arm of the World Bank Group – is considering an equity investment in GEC to support renewable energy development in Vietnam.
GEC’s business model mainly consists of the development and acquisition of small HPPs, wind and solar projects. While GEC’s ownership varies from project to project, it usually assumes an active leading role in design, construction, and operation depending on the project stage.
The International Finance Corporation (IFC) – the private sector investment arm of the World Bank Group – is considering an equity investment in GEC to support renewable energy development in Vietnam.
Overview of IFC's Scope of Review
IFC undertook an environmental and social appraisal of GEC on 7-10 December 2015 including:
a review of a series of documents including labor and occupational safety management procedures and reports, examples of environmental and social impact studies (ESIAs) and interviews with representatives of GEC Corporate management;
site visits to: Hmun HPP and Ayun Thoung HPP (Gia Lai Province), Da Khai HPP (Lam Dong Province), Thuong Lo HPP (Thua Thien Hue Province), and interviews with GEC project managers and staff at each site.
meetings with members of communities and government officials in the vicinity of the Thong Lo project
a review of a series of documents including labor and occupational safety management procedures and reports, examples of environmental and social impact studies (ESIAs) and interviews with representatives of GEC Corporate management;
site visits to: Hmun HPP and Ayun Thoung HPP (Gia Lai Province), Da Khai HPP (Lam Dong Province), Thuong Lo HPP (Thua Thien Hue Province), and interviews with GEC project managers and staff at each site.
meetings with members of communities and government officials in the vicinity of the Thong Lo project
E & S Project Categorization and Applicable Standard
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
PS 7 – Indigenous Peoples
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
PS 8 - Cultural Heritage – is not applicable as there is presently no specific evidence of potential adverse impacts on cultural heritage from GEC’s proposed investments and potential impacts will be evaluated in the environmental and social impact assessment process of future projects.
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
PS 7 – Indigenous Peoples
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
PS 8 - Cultural Heritage – is not applicable as there is presently no specific evidence of potential adverse impacts on cultural heritage from GEC’s proposed investments and potential impacts will be evaluated in the environmental and social impact assessment process of future projects.
GEC’s proposed investments primarily consist of small run-of-river hydropower projects with installed capacities of less than 10MW and regulating reservoirs of less than 100,000m3 in capacity. However, given Vietnam’s geography which is characterized by the presence of ethnic minorities and potentially sensitive ecosystems in its mountainous regions also most apt for hydropower development, it is possible that some of these future projects will be located in areas representing potentially significant environmental and social risks. For these reasons, this investment is classified as Category A according to IFC’s Environmental and Social Review Procedure.
Environmental and Social Mitigation Measures
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.
Environmental and Social Policy – GEC’s corporate business policies include environmental and social (E&S) guiding principles whose objective is to comply with local E&S regulations. These principles include: environmental protection in harmony with economic development, social security; development and conservation of biodiversity; adaptation to climate change in order to ensure the rights of all people to live in a clean and healthy environment; rational use of natural resources and waste minimization and prioritizing prevention of pollution, accidents and environmental degradation.
As noted in E&S Action Plan (ESAP) action #1, GEC will develop and implement a corporate Environmental, Health Safety and Social (EHSS) policy defining its EHSS objectives and principles to achieve sound performance. This policy will specify that all GEC’s business activities will comply with the applicable laws and regulations of Vietnam and be consistent with applicable IFC Performance Standards. This policy will indicate who within the company will ensure conformance with the policy and be responsible for its implementation. The company will communicate the policy to all levels of its organization.
Environmental and Social Assessment - The Ministry of Natural Resources and Environment is responsible for enforcing the Government’s 2005 Law on Environment Protection, which sets out the requirements for environmental impact assessment, including requirements that environmental management aspects of capital projects be addressed in Environmental and Social Impact Assessments (ESIAs) and via public consultation. It is in this context that GEC procures environmental licenses for projects it acquires or develops. Before acquiring shares and during its internal due diligence process, GEC reviews the legal status of each project including the applicable environmental licensing requirements. If the project is at a very early stage of development, GEC or one of the other project partners (including the original developer) assumes the responsibility for completing the environmental licensing process, including contracting of qualified consultants to prepare ESIAs. In some cases, GEC’s review of the environmental legal requirements during the project acquisition process has resulted in a decision to significantly redesign the project in order to reduce the significance of potential E&S impacts while complying with E&S legal requirements (as in the case of the Thuong Lo HPP in Thua Thien Hue Province). Other potential projects may be discarded if they have considerable E&S impacts such as land take requirements that are disproportionate to the installed capacity of the project. If the project is already in advanced stages of construction or in operation, GEC’s due diligence focuses on whether the project’s environmental and other licenses are valid or need to be renewed.
In practice, the environmental licensing process for new projects involves the prepara
tion of an ESIA by qualified, government registered, consultants. ESIAs in Vietnam follow a standard approach to the identification of E&S impacts including collection of baseline information from primary or secondary data sources, description of potential impacts, and presentation of proposed mitigation measures. The preparation of the ESIA report is followed by consultation with the local People’s Committee (PC) as well as other stakeholders such as local inhabitants and project affected persons. The ESIA is formally reviewed by an ESIA Evaluation Committee appointed by the local PC and the Department of Natural Resources and Environment (DONRE). This committee approves the ESIA and sends its recommendation to the national authority for ESIA approval. Recent legislation provides exemptions for the preparation of ESIAs for HPPs which are less than 10MW installed capacity, have reservoirs with less than 100,000 m3 of storage, and create limited losses of forest or agricultural land as defined by the regulation.
As per ESAP action #2, GEC will develop and implement a written screening procedure to formalize it’s current practice of avoiding acquisition of HPPs in environmentally and socially sensitive areas, i.e. conservation areas and areas where significant involuntary resettlement would be required. GEC will also revise its terms of reference (ToR) for assessment of environmental and social impacts (ESIAs) to ensure consistency with IFC requirements. The revised ToR will include adequate environmental and social baseline studies including such aspects as: identification of key community stakeholders and culturally distinct groups; material culture or natural elements of cultural significance; and fauna and flora to identify the presence or absence of listed species and evaluation of potential presence of Critical Natural Habitat (as defined in IFC’s PS6). For existing operational assets, GEC will conduct an EHSS audit of facilities and develop time-bound corrective measures for any key findings (e.g. hearing protection and fall protection measures).
Management Program – Management of E&S risks is currently part of the business process with a focus on compliance with Vietnamese legal requirements. As previously described, preliminary review of E&S risks is included as part of the overall business review of potential acquisitions of HPPs under various stages of development or operation. Recommendations are made by GEC’s Planning and Investment Department to the GEC Management Team and Board of Directors. At the project level the company monitors compliance with legal obligations, including E&S, occupational safety and labor. Projects which require ESIAs have project-specific environmental and social management plans (ESMPs) that comply with the environmental licensing conditions. These license conditions depend on the stage of project development and on the specific E&S impacts of the project but may include such aspects as c
ompensation for economic or physical displacement, prevention of impacts to biodiversity through placement of signs prohibiting hunting near worker camps, or occupational safety requirements in the construction site.
As per ESAP action #2, GEC will develop and implement a formal, documented, environmental and social management program consistent with Vietnamese and IFC requirements. The company’s program will include plans and procedures applicable to GEC’s construction and operation activities, including management of aspects such as liquid effluents and solid wastes; noise and vibrations; erosion management; removal and reinstatement of soil and vegetation; water quality monitoring; ; fauna and flora rescue programs (including monitoring, rescue, and transfer); archeological resource management; occupational health and safety; labor management; workforce mobilization and demobilization; community safety; emergency preparedness and response; contractor management (including specific contract language); and environmental conservation in the areas surrounding the reservoir, among others.
Organizational Structure – GEC presently does not have a dedicated E&S management team and E&S management functions are therefore delegated to other departments through different parts of the corporation. For example, during the process of selection of potential acquisition targets, the Planning & Investment Department (PID) which is responsible for the identification of new investment opportunities prepares a summary report with key information, including significant E&S issues, to inform GEC’s Corporate Management Team and Board of Directors in the investment decision process. If the HPP is still under development, E&S management (including contracting the preparation of the ESIA) is the responsibility of the management team of the subsidiary company developing the project or of GEC’s Project Management Unit – PMU, if the project is being developed by GEC’s parent company. Occupational safety aspects in operating assets are primarily handled by GEC’s Safety Officer of the Technical & Production Department and partly by the Insurance Officer of the Human Resources (HR) Department. The Safety Officer is responsible for such aspects as: managing occupational safety and hygiene aspects; fire prevention and control; organizing occupational safety training and testing; and managing and upgrading technical skills and testing documents related to safety. The Insurance Officer is responsible for performing procedures on social/medical/unemployment insurance and personal insurance for company’s employees as well as for organizing of annual health checkup for employees.
As per ESAP action #3, GEC will establish a corporate level Environmental and Social (E&S) Management Unit to manage the assessment and impact mitigation of the company’s projects in accordance with national requirements and IFC’s Performance Standards. The E&S management unit will i
nclude a qualified and experienced manager and specialists covering environmental, social, and occupational health and safety aspects. The newly created unit will be responsible for oversight of development and implementation of the E&S Management Program.
The unit will also develop and implement a corporate level training program applicable to management and operational level personnel and covering E&S aspects of construction and operations, with a focus on OHS management, emergency planning, environmental monitoring, and stakeholder engagement. and the unit will maintain registries of the training courses, recording attendance and topics covered.
Emergency Preparedness and Response (EPR) – Emergency preparedness and response planning is performed at the construction or operating facility level. At the operating facility level, emergency plans are part of the operational safety management process with a focus on events causing the interruption or potential interruption of power generation. These facility plans cover preparedness and response to electricity generation and transmission equipment failure, disasters (floods and landslides), and fires. The plans include a communication protocol to alert local fire authorities and GEC company management.
As per ESAP action #5, GEC will enhance EPR plans and procedures to include response to occupational accidents such as exposure to fires, electrical shock, falling in the water, and natural hazards (first aid, rescue and evacuation, particularly in remote areas); notification and coordination with downstream communities and local authorities in the event of emergency water releases or threats to dam safety (including alarms and formal call procedures); use of EPR response equipment; comprehensive emergency contacts; and training (including maintenance of a registry).
Monitoring and Review – E&S monitoring activities are presently limited to compliance with environmental licensing requirements for new construction projects and some limited internal occupational health and safety auditing activities, also focusing on compliance with local regulations.
As per ESAP action #4, GEC will develop and implement an E&S monitoring program to help track key E&S indicators and performance measures, including but not limited to: regulatory compliance status of all of its operations, internal OHS audit results, OHS incidents involving employees and contractors, waste management (types, quantities and forms of disposal), compensation programs for project affected persons, etc. GEC will also prepare E&S performance reports to communicate to company management key aspects of ESMP implementation. Management reports shall be prepared at a minimum on a quarterly basis or more frequently as determined by the company Management.
As noted in E&S Action Plan (ESAP) action #1, GEC will develop and implement a corporate Environmental, Health Safety and Social (EHSS) policy defining its EHSS objectives and principles to achieve sound performance. This policy will specify that all GEC’s business activities will comply with the applicable laws and regulations of Vietnam and be consistent with applicable IFC Performance Standards. This policy will indicate who within the company will ensure conformance with the policy and be responsible for its implementation. The company will communicate the policy to all levels of its organization.
Environmental and Social Assessment - The Ministry of Natural Resources and Environment is responsible for enforcing the Government’s 2005 Law on Environment Protection, which sets out the requirements for environmental impact assessment, including requirements that environmental management aspects of capital projects be addressed in Environmental and Social Impact Assessments (ESIAs) and via public consultation. It is in this context that GEC procures environmental licenses for projects it acquires or develops. Before acquiring shares and during its internal due diligence process, GEC reviews the legal status of each project including the applicable environmental licensing requirements. If the project is at a very early stage of development, GEC or one of the other project partners (including the original developer) assumes the responsibility for completing the environmental licensing process, including contracting of qualified consultants to prepare ESIAs. In some cases, GEC’s review of the environmental legal requirements during the project acquisition process has resulted in a decision to significantly redesign the project in order to reduce the significance of potential E&S impacts while complying with E&S legal requirements (as in the case of the Thuong Lo HPP in Thua Thien Hue Province). Other potential projects may be discarded if they have considerable E&S impacts such as land take requirements that are disproportionate to the installed capacity of the project. If the project is already in advanced stages of construction or in operation, GEC’s due diligence focuses on whether the project’s environmental and other licenses are valid or need to be renewed.
In practice, the environmental licensing process for new projects involves the prepara
tion of an ESIA by qualified, government registered, consultants. ESIAs in Vietnam follow a standard approach to the identification of E&S impacts including collection of baseline information from primary or secondary data sources, description of potential impacts, and presentation of proposed mitigation measures. The preparation of the ESIA report is followed by consultation with the local People’s Committee (PC) as well as other stakeholders such as local inhabitants and project affected persons. The ESIA is formally reviewed by an ESIA Evaluation Committee appointed by the local PC and the Department of Natural Resources and Environment (DONRE). This committee approves the ESIA and sends its recommendation to the national authority for ESIA approval. Recent legislation provides exemptions for the preparation of ESIAs for HPPs which are less than 10MW installed capacity, have reservoirs with less than 100,000 m3 of storage, and create limited losses of forest or agricultural land as defined by the regulation.
As per ESAP action #2, GEC will develop and implement a written screening procedure to formalize it’s current practice of avoiding acquisition of HPPs in environmentally and socially sensitive areas, i.e. conservation areas and areas where significant involuntary resettlement would be required. GEC will also revise its terms of reference (ToR) for assessment of environmental and social impacts (ESIAs) to ensure consistency with IFC requirements. The revised ToR will include adequate environmental and social baseline studies including such aspects as: identification of key community stakeholders and culturally distinct groups; material culture or natural elements of cultural significance; and fauna and flora to identify the presence or absence of listed species and evaluation of potential presence of Critical Natural Habitat (as defined in IFC’s PS6). For existing operational assets, GEC will conduct an EHSS audit of facilities and develop time-bound corrective measures for any key findings (e.g. hearing protection and fall protection measures).
Management Program – Management of E&S risks is currently part of the business process with a focus on compliance with Vietnamese legal requirements. As previously described, preliminary review of E&S risks is included as part of the overall business review of potential acquisitions of HPPs under various stages of development or operation. Recommendations are made by GEC’s Planning and Investment Department to the GEC Management Team and Board of Directors. At the project level the company monitors compliance with legal obligations, including E&S, occupational safety and labor. Projects which require ESIAs have project-specific environmental and social management plans (ESMPs) that comply with the environmental licensing conditions. These license conditions depend on the stage of project development and on the specific E&S impacts of the project but may include such aspects as c
ompensation for economic or physical displacement, prevention of impacts to biodiversity through placement of signs prohibiting hunting near worker camps, or occupational safety requirements in the construction site.
As per ESAP action #2, GEC will develop and implement a formal, documented, environmental and social management program consistent with Vietnamese and IFC requirements. The company’s program will include plans and procedures applicable to GEC’s construction and operation activities, including management of aspects such as liquid effluents and solid wastes; noise and vibrations; erosion management; removal and reinstatement of soil and vegetation; water quality monitoring; ; fauna and flora rescue programs (including monitoring, rescue, and transfer); archeological resource management; occupational health and safety; labor management; workforce mobilization and demobilization; community safety; emergency preparedness and response; contractor management (including specific contract language); and environmental conservation in the areas surrounding the reservoir, among others.
Organizational Structure – GEC presently does not have a dedicated E&S management team and E&S management functions are therefore delegated to other departments through different parts of the corporation. For example, during the process of selection of potential acquisition targets, the Planning & Investment Department (PID) which is responsible for the identification of new investment opportunities prepares a summary report with key information, including significant E&S issues, to inform GEC’s Corporate Management Team and Board of Directors in the investment decision process. If the HPP is still under development, E&S management (including contracting the preparation of the ESIA) is the responsibility of the management team of the subsidiary company developing the project or of GEC’s Project Management Unit – PMU, if the project is being developed by GEC’s parent company. Occupational safety aspects in operating assets are primarily handled by GEC’s Safety Officer of the Technical & Production Department and partly by the Insurance Officer of the Human Resources (HR) Department. The Safety Officer is responsible for such aspects as: managing occupational safety and hygiene aspects; fire prevention and control; organizing occupational safety training and testing; and managing and upgrading technical skills and testing documents related to safety. The Insurance Officer is responsible for performing procedures on social/medical/unemployment insurance and personal insurance for company’s employees as well as for organizing of annual health checkup for employees.
As per ESAP action #3, GEC will establish a corporate level Environmental and Social (E&S) Management Unit to manage the assessment and impact mitigation of the company’s projects in accordance with national requirements and IFC’s Performance Standards. The E&S management unit will i
nclude a qualified and experienced manager and specialists covering environmental, social, and occupational health and safety aspects. The newly created unit will be responsible for oversight of development and implementation of the E&S Management Program.
The unit will also develop and implement a corporate level training program applicable to management and operational level personnel and covering E&S aspects of construction and operations, with a focus on OHS management, emergency planning, environmental monitoring, and stakeholder engagement. and the unit will maintain registries of the training courses, recording attendance and topics covered.
Emergency Preparedness and Response (EPR) – Emergency preparedness and response planning is performed at the construction or operating facility level. At the operating facility level, emergency plans are part of the operational safety management process with a focus on events causing the interruption or potential interruption of power generation. These facility plans cover preparedness and response to electricity generation and transmission equipment failure, disasters (floods and landslides), and fires. The plans include a communication protocol to alert local fire authorities and GEC company management.
As per ESAP action #5, GEC will enhance EPR plans and procedures to include response to occupational accidents such as exposure to fires, electrical shock, falling in the water, and natural hazards (first aid, rescue and evacuation, particularly in remote areas); notification and coordination with downstream communities and local authorities in the event of emergency water releases or threats to dam safety (including alarms and formal call procedures); use of EPR response equipment; comprehensive emergency contacts; and training (including maintenance of a registry).
Monitoring and Review – E&S monitoring activities are presently limited to compliance with environmental licensing requirements for new construction projects and some limited internal occupational health and safety auditing activities, also focusing on compliance with local regulations.
As per ESAP action #4, GEC will develop and implement an E&S monitoring program to help track key E&S indicators and performance measures, including but not limited to: regulatory compliance status of all of its operations, internal OHS audit results, OHS incidents involving employees and contractors, waste management (types, quantities and forms of disposal), compensation programs for project affected persons, etc. GEC will also prepare E&S performance reports to communicate to company management key aspects of ESMP implementation. Management reports shall be prepared at a minimum on a quarterly basis or more frequently as determined by the company Management.
Human Resource Policy and Management - GEC currently employs 278 permanent staff (87.4 % male and 22.6 % female). The company has a Human Resources policy that meets the 2013 Vietnamese labor regulatory requirements (“Labor Code”) established by the Ministry of Labor, War Invalids and Social Affairs, the scope of which applies to all permanent employees. The general provisions of the Labor Code cover: (i) wages, including deductions; (ii) hours of work; (iii) overtime arrangements; (iv) leave, (v) benefits, including public health insurance, pension schemes, (vi) right to organize and bargain collectively, (vii) disciplinary procedures, (viii) termination procedures and rights, (ix) conditions of work, (x) safety, hygiene, emergency aspects, (xi) promotion criteria, (xii) training, and (xiii) other requirements according to national law, e.g. labor outsourcing. In keeping with the Labor Code certain categories of persons (e.g., pregnant women or mothers of babies less than 12 months old, junior employees, senior employees, and disabled employees) benefit from more generous protection and from discrimination. Compulsory Social Insurance applies to enterprises, entities, and organizations that employ employees under indefinite-term labor contracts or under definite-term labor contracts with a duration of three months or more. Both employees and employers are required to contribute to the social insurance fund at statutory rates. The social insurance fund pays allowances for sick leave, maternity leave, work-related accidents, occupational disease, and pensions.
GEC ensures construction contractor compliance with the Labor Code as well as its own HR policies and practices, through its contractor screening and selection process, contract agreements with third-parties, and project site contractor supervision. GEC also requires contractors to meet environmental, occupational safety, life and fire safety and security standards established by the concerned authorities applicable to each project site.
Recruitment and staffing at the project level for both construction and operations is the responsibility of the GEC project manager. GEC project managers are directly responsible for construction contractors and other service providers with regard to compliance of the Labor Code, including payment of minimum wage, social benefits, OHS training and provision of PPEs, and contractor adherence to minimum age of employment (18 years).
Workers Organizations - Under the Vietnam Labor Code, all employers are required to facilitate the establishment of a trade union organization within their company. All GEC employees are members of the Vietnam National Union of Industrial and Commercial Workers, one of 18 affiliated unions under the Vietnam General Confederation of Labor (VGCL), the country’s sole national trade union. The VGCL is mandated to further the goals and policies of the country’s ruling Communist Party. Union representatives are elected
from among all GEC employees at the individual project level and at the corporate level. The main function of a trade union is to represent and protect employees’ legal rights and interests. Therefore, most decisions relating to employee benefits should involve the trade union representative, such as execution of a collective labor agreement, decisions regarding labor discipline, and termination of labor contracts. The standing collective bargaining agreement between GEC management and its employees is reviewed by all union membership annually. Recommendations for updating this agreement are put forward for GEC management consideration by the union leadership and are incorporated into the agreement prior to its renewal each year.
Grievance Mechanism - A Labor Conciliation Council, established within the company, handles most employment disputes. The Labor Code also provides for District Conciliators appointed by the District Department of Labor as well as for Provincial Labor Arbitration Councils (consisting of various advocates or professionals), which conduct statutory conciliation of either individual or collective disputes before the disputes are brought to the specialized Labor Court of the People’s Court. In certain disputes, parties may bring cases directly to the courts for settlement without conciliation. Proper legal grounds must exist in order for an employer to terminate a labor contract with an employee, such as performance issues, prolonged illness, a force majeure event, or winding up of the company. Employers are required to follow a number of statutory steps such as sending a warning letter to employees and/or sending advance written notice regarding the termination of employment to employees within a statutory time limit.
Occupational Health and Safety (OHS) – During the construction phase, GEC contractually delegates OHS management activities to construction companies (contractors and subcontractors), including those specialized in certain aspects such as tunneling or large civil works like dams. During the operational phase, GEC applies OHS procedures focusing on electrical safety at HPP sites, including electrical source isolation procedures as required by Vietnamese regulations.
As per ESAP action # 7, GEC will develop and implement OHS management plans and procedures covering all relevant aspects if its business activities, including but not limited to: review and update of construction and O&M contractor requirements (with specific standards to be included in service contract language); operational phase standards and procedures covering such aspects as: electrical safety; Personal Protective Equipment (PPE); fall prevention; hearing conservation; drowning prevention and rescue; work in confined spaces; use of lifting equipment; etc; training; internal auditing; accident and incident investigations and root-cause analysis; emergency planning; and monitoring and reporting.
GEC ensures construction contractor compliance with the Labor Code as well as its own HR policies and practices, through its contractor screening and selection process, contract agreements with third-parties, and project site contractor supervision. GEC also requires contractors to meet environmental, occupational safety, life and fire safety and security standards established by the concerned authorities applicable to each project site.
Recruitment and staffing at the project level for both construction and operations is the responsibility of the GEC project manager. GEC project managers are directly responsible for construction contractors and other service providers with regard to compliance of the Labor Code, including payment of minimum wage, social benefits, OHS training and provision of PPEs, and contractor adherence to minimum age of employment (18 years).
Workers Organizations - Under the Vietnam Labor Code, all employers are required to facilitate the establishment of a trade union organization within their company. All GEC employees are members of the Vietnam National Union of Industrial and Commercial Workers, one of 18 affiliated unions under the Vietnam General Confederation of Labor (VGCL), the country’s sole national trade union. The VGCL is mandated to further the goals and policies of the country’s ruling Communist Party. Union representatives are elected
from among all GEC employees at the individual project level and at the corporate level. The main function of a trade union is to represent and protect employees’ legal rights and interests. Therefore, most decisions relating to employee benefits should involve the trade union representative, such as execution of a collective labor agreement, decisions regarding labor discipline, and termination of labor contracts. The standing collective bargaining agreement between GEC management and its employees is reviewed by all union membership annually. Recommendations for updating this agreement are put forward for GEC management consideration by the union leadership and are incorporated into the agreement prior to its renewal each year.
Grievance Mechanism - A Labor Conciliation Council, established within the company, handles most employment disputes. The Labor Code also provides for District Conciliators appointed by the District Department of Labor as well as for Provincial Labor Arbitration Councils (consisting of various advocates or professionals), which conduct statutory conciliation of either individual or collective disputes before the disputes are brought to the specialized Labor Court of the People’s Court. In certain disputes, parties may bring cases directly to the courts for settlement without conciliation. Proper legal grounds must exist in order for an employer to terminate a labor contract with an employee, such as performance issues, prolonged illness, a force majeure event, or winding up of the company. Employers are required to follow a number of statutory steps such as sending a warning letter to employees and/or sending advance written notice regarding the termination of employment to employees within a statutory time limit.
Occupational Health and Safety (OHS) – During the construction phase, GEC contractually delegates OHS management activities to construction companies (contractors and subcontractors), including those specialized in certain aspects such as tunneling or large civil works like dams. During the operational phase, GEC applies OHS procedures focusing on electrical safety at HPP sites, including electrical source isolation procedures as required by Vietnamese regulations.
As per ESAP action # 7, GEC will develop and implement OHS management plans and procedures covering all relevant aspects if its business activities, including but not limited to: review and update of construction and O&M contractor requirements (with specific standards to be included in service contract language); operational phase standards and procedures covering such aspects as: electrical safety; Personal Protective Equipment (PPE); fall prevention; hearing conservation; drowning prevention and rescue; work in confined spaces; use of lifting equipment; etc; training; internal auditing; accident and incident investigations and root-cause analysis; emergency planning; and monitoring and reporting.
GEC requires that construction contractors comply with the environmental license conditions and the requirements of project-specific ESMPs, covering such aspects as fugitive dust from earth moving activities; noise and exhaust from construction machinery; sanitary effluents from worker facilities (typically disposed of via septic systems), and non-hazardous and hazardous solids wastes (typically disposed of through registered contractors or at the local waste disposal facilities in the case of non-hazardous wastes). Sanitary wastes as well as hazardous and non-hazardous wastes are similarly disposed of in operating facilities although the lack of local availability of companies that can properly manage waste oils means that this material is stockpiled on-site until enough is available to justify collection efforts. During the construction phase, ambient noise concerns are managed by restrictions on construction site operating hours while noise from operating facilities is not considered an issue due to their located at considerable distances from residential areas.
GEC’s current and planned hydroelectric power projects fall under the category of small hydroelectric projects, meaning that they have relatively small (hourly-daily) storage at the headworks to regulate flow through the power station. This type of project design tends to have less of a negative impact on the quality of surface waters such as changes in water temperature or those related to inundation of vegetative biomass (i.e. dissolved oxygen, total dissolved gases, and water clarity) or those associated with watershed runoff.
GEC’s current and planned hydroelectric power projects fall under the category of small hydroelectric projects, meaning that they have relatively small (hourly-daily) storage at the headworks to regulate flow through the power station. This type of project design tends to have less of a negative impact on the quality of surface waters such as changes in water temperature or those related to inundation of vegetative biomass (i.e. dissolved oxygen, total dissolved gases, and water clarity) or those associated with watershed runoff.
Infrastructure and Equipment Safety - A potentially significant hazard related to the construction of infrastructure projects in rural areas of Vietnam is the possible presence of unexploded ordnance (UXO) which resulted from the period of armed conflict in the 1960s and 1970s. Depending on the location of the proposed project, it is standard practice for construction companies and project developers to conduct pre-construction screening by reviewing maps of post-conflict areas as well as through UXO detection surveys using more detailed methods such as metal detectors and magnetometers. If UXO are encountered, specialized service providers must be contracted to remove and decommission explosive materials. Additional risk to health and safety of the community typically consist of traffic and pedestrian safety from the transport of construction materials, equipment, and workers to and from the construction sites and potential for structural damage to local housing located adjacent to transport routes. Other potential impacts include hazards associated with the transport and use of explosives for site excavation and tunneling activities. GEC requires construction contractors to evaluate potential impacts from transport activities and performs limited access route improvements to ensure the safety of access of transport equipment to the project sites. Contractors are also required to adhere to driver safety programs and for transport equipment operators to respect locally imposed speed limits.
Civil works are designed and constructed according to good international practice to address potential risks associated with natural hazards such as floods and seismic activities. Dams and other structural elements, some of which exceed 15 meters in height, are designed by qualified and experienced professionals with proven experience in projects of a similar complexity. The designs are reviewed by government regulators and are also subject to periodic independent safety inspections during construction and operation. GEC maintain copies of dam safety reports documenting engineering and construction supervision results. Other possible risks to communities near the project include drowning hazards due to the new reservoirs or to downstream users of the river or a passerby due to discharge of water in the tailrace during normal or emergency events. This is typically handled by warning signs along the shore of the reservoir as well as access control (fencing) to prevent access into some high risk areas.
Going forward, in the context of development of the E&S management program and EHS audit of existing facilities, GEC will review and augment health and safety measures designed to protect community members including those aspects related to access restrictions to high risk infrastructure and those related to emergency response planning as previously noted in this report.
Civil works are designed and constructed according to good international practice to address potential risks associated with natural hazards such as floods and seismic activities. Dams and other structural elements, some of which exceed 15 meters in height, are designed by qualified and experienced professionals with proven experience in projects of a similar complexity. The designs are reviewed by government regulators and are also subject to periodic independent safety inspections during construction and operation. GEC maintain copies of dam safety reports documenting engineering and construction supervision results. Other possible risks to communities near the project include drowning hazards due to the new reservoirs or to downstream users of the river or a passerby due to discharge of water in the tailrace during normal or emergency events. This is typically handled by warning signs along the shore of the reservoir as well as access control (fencing) to prevent access into some high risk areas.
Going forward, in the context of development of the E&S management program and EHS audit of existing facilities, GEC will review and augment health and safety measures designed to protect community members including those aspects related to access restrictions to high risk infrastructure and those related to emergency response planning as previously noted in this report.
Vietnamese environmental regulations include requirements for the assessment of potential impacts to biodiversity and implementation of preventive and corrective actions. However, in the majority of cases, ESIAs can rely on secondary sources and are not required to collect primary baseline information nor required to identify the presence or potential presence of species under conservation status. Required conservation measures are typically limited to replacement of lost vegetation with little consideration of ecological values. Similarly, evaluation of potential impacts to aquatic habitats due to implementation of HPPs requires little in the form of identification of the presence of species of significance nor the identification of ecosystem services. Ecological or sanitary flow requirements in HPPs are established on a case by case basis by regulators but are mainly based on hydrological methods without consideration of local ecological or social requirements.
As per ESAP action # 9, where potential impacts to biodiversity are identified, the ESIA will identify any IUCN Red-listed critically-endangered or endangered species, concentrations of nationally listed threatened species, endemic or restricted-range species, and/or migratory or congregatory species. The ESIA will describe whether the site is located in modified, natural or critical habitat and provide additional information necessary to evaluate the presence and potential impacts to biodiversity resources of conservation and/or community importance in compliance with IFC’s PS6 requirements. Subsequently, project design and environmental management plans (EMPs) will include detailed biodiversity protection programs which apply the mitigation hierarchy described in PS6. GEC will develop a procedure to guide ecological flow determinations where projects will result in sustained alteration of river flows. This procedure will consider the ecological and social needs of the affected river reach in addition to purely hydrological factors.
The 6MW Thuong Lo project located in Thua Thien Hue Province, recently commissioned in 2015, was redesigned by GEC in 2013 shortly following its acquisition in order to minimize potential environmental impacts. As originally designed, the Thoung Lo project would have directly affected approximately 60 hectare (ha) of the Bach Ma National Park an area known for the potential presence of a critically endangered forest antelope and tiger. The project re-design resulted in a reduction in the footprint of the reservoir from 197 ha to 46 ha, affecting 10 ha of the Bach Ma National Park. Given Thuong Lo’s overlap to this key biodiversity area, GEC will commission a complementary biodiversity assessment by a qualified expert consisting of a desktop review of existing sources and interviews with key experts on the relevant species and sites, followed by a more detailed evaluation of potential impacts to biodiversity depending on the findings of
the desktop review and interviews.
As per ESAP action # 9, where potential impacts to biodiversity are identified, the ESIA will identify any IUCN Red-listed critically-endangered or endangered species, concentrations of nationally listed threatened species, endemic or restricted-range species, and/or migratory or congregatory species. The ESIA will describe whether the site is located in modified, natural or critical habitat and provide additional information necessary to evaluate the presence and potential impacts to biodiversity resources of conservation and/or community importance in compliance with IFC’s PS6 requirements. Subsequently, project design and environmental management plans (EMPs) will include detailed biodiversity protection programs which apply the mitigation hierarchy described in PS6. GEC will develop a procedure to guide ecological flow determinations where projects will result in sustained alteration of river flows. This procedure will consider the ecological and social needs of the affected river reach in addition to purely hydrological factors.
The 6MW Thuong Lo project located in Thua Thien Hue Province, recently commissioned in 2015, was redesigned by GEC in 2013 shortly following its acquisition in order to minimize potential environmental impacts. As originally designed, the Thoung Lo project would have directly affected approximately 60 hectare (ha) of the Bach Ma National Park an area known for the potential presence of a critically endangered forest antelope and tiger. The project re-design resulted in a reduction in the footprint of the reservoir from 197 ha to 46 ha, affecting 10 ha of the Bach Ma National Park. Given Thuong Lo’s overlap to this key biodiversity area, GEC will commission a complementary biodiversity assessment by a qualified expert consisting of a desktop review of existing sources and interviews with key experts on the relevant species and sites, followed by a more detailed evaluation of potential impacts to biodiversity depending on the findings of
the desktop review and interviews.
Most of GEC’s HPPs are situated in areas inhabited by one or more of Vietnam’s ethnic minorities. The Government of Vietnam recognizes 54 ethnic groups within its population; 53 are recognized as “ethnic minority” groups with an estimated 13 to 14 million people, accounting for around 14% of the country’s total population of 90 million. The remaining ethnic group, the Kinh, constitute the majority of Vietnam’s population and represent the country’s social and political “mainstream”. Ethnic minority groups live scattered throughout the country but are largely concentrated in the Northern Mountains and Central Highlands – areas of the country with significant hydropower development potential. While many of these groups possess socio-cultural characteristics typical of “indigenous peoples” as defined by the international community, the Vietnamese government does not accord them any special rights or privileges. While the government has not ratified ILO Convention 169, it has voted in favor of the UN Declaration of Rights of Indigenous Peoples. All ethnic minorities have Vietnamese citizenship, and Vietnam’s constitution recognizes that all people have equal rights. A ministry-level agency, the State Committee on Ethnic Minority and Mountainous Area Affairs, is responsible for promoting the welfare of ethnic minorities.
The management of the process of land acquisition, compensation payments and livelihood restoration by the government described under Section PS5 above takes into consideration the traditional leadership structure of those ethnic minority groups affected by capital development projects. Traditional leaders along with the government appointed heads of the Commune Peoples’ Committees are invited to participate in the District Resettlement and Compensation Committee. In this capacity, they represent their constituents’ interests in establishing compensation packages and livelihood restoration benefits. However, there is no direct evidence of the Informed Consultation and Participation with ethnic minority communities by the DRC that IFC would require in circumstances where indigenous peoples are adversely affected by a project. As per ESAP Action # 10, GEC and its project managers, with the support of the company’s E&S Management Unit, will fulfill the responsibilities for ensuring consultation and appropriate compensation entitlements that PS7 requires in circumstances where the government is responsible for managing indigenous peoples’ issues in all future projects.
The management of the process of land acquisition, compensation payments and livelihood restoration by the government described under Section PS5 above takes into consideration the traditional leadership structure of those ethnic minority groups affected by capital development projects. Traditional leaders along with the government appointed heads of the Commune Peoples’ Committees are invited to participate in the District Resettlement and Compensation Committee. In this capacity, they represent their constituents’ interests in establishing compensation packages and livelihood restoration benefits. However, there is no direct evidence of the Informed Consultation and Participation with ethnic minority communities by the DRC that IFC would require in circumstances where indigenous peoples are adversely affected by a project. As per ESAP Action # 10, GEC and its project managers, with the support of the company’s E&S Management Unit, will fulfill the responsibilities for ensuring consultation and appropriate compensation entitlements that PS7 requires in circumstances where the government is responsible for managing indigenous peoples’ issues in all future projects.
Stakeholder Engagement
GEC has been recently established and company has yet to develop corporate policies or practices pertaining to information disclosure, public consultation or grievance redress. The company grants autonomy to its individual project managers in their liaison with local government bodies, in particular the concerned People’s Committee of each project’s area of influence (i.e., mainly the location of the project civil works and transmission lines) to convey project information or address public grievances. Typically, the District- and Commune-level Peoples’ Committees are the principal means of communication of project information to the inhabitants of a project area as well as the principal means of conveying community feedback to a project proponent. The GEC Project Manager and his staff typically interact directly with local government personnel and community leaders but there is no formal arrangement such as dedicated Project Management Unit staff to facilitate liaison between the PMU and project-affected communities.
GEC maintains formal procedures to resolve disputes and complaints for addressing issues raised by regulatory agencies or political authorities. However, these procedures do not extend to less formal grievances raised by communities located in the areas of influence of GEC projects. Nonetheless, GEC project managers and staff live and work within the communities affected by their projects and interact regularly with local government.
As per ESAP action # 6, GEC, with the support of the company proposed new E&S Management Unit, will develop and implement a corporate stakeholder engagement procedure commensurate with the scope of the company’s projects and consistent with IFC’s stakeholder engagement hierarchy, incorporating a community grievance management mechanism. GEC will also establish a formal community liaison function within each project’s PMU to facilitate community engagement, record and address community grievances related to project activities, land acquisition and compensation, and to monitor the ability of project affected households to restore their livelihoods post-displacement.
GEC maintains formal procedures to resolve disputes and complaints for addressing issues raised by regulatory agencies or political authorities. However, these procedures do not extend to less formal grievances raised by communities located in the areas of influence of GEC projects. Nonetheless, GEC project managers and staff live and work within the communities affected by their projects and interact regularly with local government.
As per ESAP action # 6, GEC, with the support of the company proposed new E&S Management Unit, will develop and implement a corporate stakeholder engagement procedure commensurate with the scope of the company’s projects and consistent with IFC’s stakeholder engagement hierarchy, incorporating a community grievance management mechanism. GEC will also establish a formal community liaison function within each project’s PMU to facilitate community engagement, record and address community grievances related to project activities, land acquisition and compensation, and to monitor the ability of project affected households to restore their livelihoods post-displacement.
Additional GEC’s corporate and specific project-level E&S documents can be accessed at the following:
Mr. Le An Khang
CEO,
Gialai Electricity JSC
Address: 114 Truong Chinh, Pleiku, Gia Lai Province, Vietnam
Telephone: +84593823604
Email: mailto:khangla@geccom.vn
Mr. Le An Khang
CEO,
Gialai Electricity JSC
Address: 114 Truong Chinh, Pleiku, Gia Lai Province, Vietnam
Telephone: +84593823604
Email: mailto:khangla@geccom.vn
Broad Community Support
Broad Community Support is not applicable for this project
Environmental & Social Action Plan
| GEC(37567) Supervision Disclosure Snapshot – Version 2 | ||||
|---|---|---|---|---|
| Description | Anticipated Completion Date | Status | Comments | Completion Date |
| Policy: Develop and implement a corporate Environmental, Health Safety and Social (EHSS) policy defining GEC objectives and principles for achieving sound EHSS performance. The Policy will specify compliance with applicable Vietnamese and IFC Performance Standard requirements and indicate who will ensure conformance with the policy and be responsible for its implementation. | 31-May-2016 | Completed | Completed | 5/31/2016 |
| E&S Assessment and Management Program and Procedures: Develop and implement a formal EHSS Management Program with plans and procedures covering the following aspects according to Vietnamese and IFC E&S requirements: • Develop and implement a written project screening procedure to avoid acquisition of HPPs or other renewable energy projects in environmentally and socially sensitive areas, i.e. conservation areas and areas where significant involuntary resettlement would be required. | 31-May-2016 | Completed | Completed | 5/31/2016 |
| • Revise terms of reference (ToR) for ESIAs to ensure consistency with IFC requirements and include adequate baseline studies including such aspects as: identification of key community stakeholder groups and culturally distinct groups; material culture or natural elements of cultural significance; and, fauna and flora to identify the presence or absence of listed species and evaluation of potential presence of sensitive habitat (also refer to the actions under PS 6, below). | 31-May-2016 | Completed | Completed | 5/31/2016 |
| • Conduct EHS audit of existing facilities and develop time-bound corrective measures for key findings (examples of potentially required corrective actions include hearing protection and fall protection measures) | 31-Dec-2016 | Completed | Completed | 12/30/2017 |
| • Develop and implement construction and operational phase EHSS management plans covering such aspects as: solid and liquid waste (hazardous and non-hazardous including spoils); dust; noise; erosion; riparian vegetation; fauna and flora rescue; archeological resources; occupational health and safety; labor management; workforce mobilization and demobilization; community safety; emergency preparedness and response; and contractor management (including contract language). | 31-Dec-2016 | Completed | Completed | 12/31/2018 |
| Implement management plans and procedures across GEC operations | 31-Mar-2017 | Completed | Completed | 12/31/2018 |
| Organizational Capacity: Establish a corporate level Environmental and Social (E&S) Management Unit to manage the assessment and impact mitigation of the GEC’s projects in accordance with national requirements and IFC’s Performance Standards. The newly created unit will be responsible for oversight of development and implementation of the E&S Management Program. | 31-Dec-2016 | Completed | Completed | 11/30/2017 |
| Training: Once the program is in place, the unit will develop and implement a corporate level training program covering E&S aspects of construction and operations, with a focus on OHS management, emergency planning, environmental monitoring, and stakeholder engagement. | 31-Mar-2017 | Completed | Completed | 12/31/2017 |
| Monitoring and Reporting: Develop and implement an E&S monitoring program to help track key E&S indicators and performance measures, including but not limited to: regulatory compliance status of all of its operations, internal OHS audit results, OHS incidents with employees and contractors, waste management (types, quantities and forms of disposal), compensation programs for project affected persons, etc. GEC will also prepare E&S performance reports to communicate to Company management key aspects of ESMP implementation. Management reports shall be prepared at a minimum on a quarterly basis or more frequently as determined by the Company Management. | 31-Dec-2016 | Completed | Completed | 6/30/2019 |
| Emergency Preparedness and Response: GEC will enhance EPR plans and procedures to include response to occupational accidents such as exposure to fires, electrical shock, falling in the water, and natural hazards (first aid, rescue and evacuation, particularly in remote areas); notification and coordination with downstream communities and local authorities in the event of emergency water releases or threats to the dam safety (including alarms and formal call procedures); use of EPR response equipment; comprehensive emergency contacts; and training (including maintenance of a registry). | 17-Dec-2016 | Completed | Completed | 12/31/2018 |
| Deploy EPR program across operational sites | 31-Mar-2017 | Completed | Completed | 12/31/2018 |
| Community Engagement: Develop and implement a corporate stakeholder engagement procedure commensurate with the scope of the GEC’s projects and consistent with IFC’s community engagement hierarchy, incorporating a community grievance management mechanism. | 17-Dec-2016 | Completed | Completed | 12/31/2018 |
| Establish a formal community liaison function within each project’s PMU to facilitate community engagement, record and address community grievances related to project activities, land acquisition and compensation, and to monitor the ability of PAHs to restore their livelihoods post-displacement. | 31-Mar-2017 | Completed | Completed | 12/31/2018 |
| Occupational Health and Safety: Develop and implement OHS management plans and procedures covering all relevant aspects if its business activities, including but not limited to: review and update of construction and O&M contractor requirements (with specific standards to be included in service contract language); operational phase standards and procedures covering such aspects as: electrical safety; Personal Protective Equipment (PPE); fall prevention; hearing conservation; drowning prevention and rescue; work in confined spaces; use of lifting equipment; etc; training; internal auditing; accident and incident investigations and root-cause analysis; emergency planning; and monitoring and reporting. | 17-Dec-2016 | Completed | Completed | 12/31/2018 |
| Implement OHS management plans and procedures across GEC operations | 31-Mar-2017 | Completed | Completed | 12/31/2018 |
| Land Acquisition & Involuntary Resettlement Procedures: GEC will develop and implement a due diligence procedure for review of government managed resettlement in its projects. The procedure will identify any shortcomings of the government managed process vis-à-vis desired PS 5 outcomes and identify any supplemental measures that GEC needs to implement to mitigate these gaps. | 30-Jun-2016 | Completed | Completed | 12/31/2018 |
| Implement PS5 Compliance Precedure as applicable | 31-Dec-2017 | Completed | Completed | 12/31/2018 |
| Protection and Conservation of Biodiversity : • Ensure that, where potential impacts to biodiversity are identified, the ESIA identifies any IUCN Red-listed critically-endangered or endangered species, concentrations of nationally listed threatened species, endemic or restricted-range species, and/or migratory or congregatory species. The ESIA will also describe whether the project site is located in modified, natural or critical habitat (as per PS 6 definitions) and provide additional information necessary to evaluate the presence and potential impacts to biodiversity resources of conservation and/or community importance. Where necessary, environmental management plans (EMPs) will include biodiversity protection programs which apply the mitigation hierarchy described in PS6. | 31-May-2016 | Completed | Completed | 12/31/2018 |
| • Develop and implement a procedure to guide ecological flow determinations based on the results of a detailed ESIA, considering ecological and social needs of the affected river reach in addition to hydrological factors. | 31-May-2017 | Completed | Completed | 3/31/2017 |
| • Commission a complementary biodiversity assessment for the Thuong Lo project, to be undertaken by a qualified expert and consisting of a desktop review of existing sources and interviews with key experts on the relevant species and sites, followed by a more detailed evaluation of potential impacts to biodiversity depending on the findings of the desktop review and interviews. | 30-Jun-2016 | Completed | Completed | 3/31/2017 |
| Private Sector Responsibilities Where Government is Responsible for Managing Indigenous People’s issues: GEC will ensure consultation and appropriate compensation entitlements that PS7 requires in circumstances where the government is responsible for managing matters related to Ethnic Minorities in all future projects. | 30-Jun-2016 | Completed | Completed | 12/31/2018 |
| Implement PS7 Compliance prodecude as applicable | 31-Dec-2017 | Completed | Completed | 12/31/2018 |
Press-Release
Related SII
Similar Projects
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.