The project land was previously open desert, and is owned by NREA, and will be leased to the sponsors for a 25-year period.  There will be no involuntary land acquisition, thus PS5 on Land Acquisition and Involuntary Resettlement is not applicable to this proposed investment.  The area comprises desert with minimal vegetation and surveys have not identified any features or species which would trigger PS6 for Biodiversity Conservation and Sustainable Management of Living Natural Resources.  There are no Indigenous Peoples in the project area, and therefore PS7 on Indigenous Peoples is not applicable.  The studies as part of the ESIA did not reveal cultural heritage, therefore PS8 on Cultural Heritage is not applicable.  However, the sponsors will develop a Chance Finds Procedure in case of the identification of cultural/archeological resources in the area in line with PS8.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the E&S impacts associated with the project are limited, generally site-specific and can be addressed through the implementation of good international industry practices.  As the project is part of a larger development there are potential cumulative impacts associated with the construction, and to a lesser degree the operational and decommissioning phases, which need to be managed in a coherent and coordinated manner.  In order to address these cumulative impacts, the sponsors have joined the Benban Developers Association (BDA) which will, with NREA and EETC, appoint the FMC which will undertake or direct the management of construction and several of the E&S cumulative issues.  This approach will assist in ensuring that ESHS risks are managed consistently by Benban PV developers, and that there is a well-managed and coordinated response to overarching cumulative issues such as occupational health and safety, transport / traffic management, security, community engagement and corporate social responsibility, and labor, worker welfare and accommodation, among others.

Environmental & Social Assessment

The international lenders and NREA initiated a Strategic Environmental and Social Assessment (SESA) for the entire Benban PV solar park with the objective of providing an overarching assessment of the environmental and social impacts of the Benban development.  The details of this assessment are included below (see Cumulative Impacts).  The SESA, dated December 2015, was approved by the government on 17 March 2016 and considered cumulative impacts with respect to the additional impacts expected beyond the development of a single power plant with individual developers responsible for defining and implementing site specific mitigations/recommendations as appropriate within their environmental management plans.  Due to the development of the SESA, the individual projects within the solar park have been categorized as requiring a Form B EIA by the Egyptian Environmental Affairs Agency (EEAA).  As a result, the SESA supported the EIA process for the project, resulted in a more consistent approach at the individual project level for the Form B EIA preparation, and reduced the need, and cost, for additional baselines.  It also removed the need for a project-specific consultation process. 

In order to address project-specific impact assessment requirements, the EIA for the project, dated March 2016, was prepared by a local consulting company (EcoConServ) in accordance with the Egyptian Environmental law no. 4 / 1994 amended by law no. 9 / 2009 and its executive regulations.  This EIA incorporated the findings and approval conditions of the SESA, and covered the construction, operation and decommissioning phases of the project.  This considered to largely meet the requirements of PS1 with any gaps to be met through the ESAP.

The sponsors have addressed the gap between the local EIA and Lender requirements through the development of an ESDD checklist/report, to specifically address the assessment of impacts per the PSs.  The Form B EIA for the project submitted to EEAA, and the Environmental approval for the project was received on 16 May 2016 as part of Round 1 from the Egyptian Environmental Affairs Authority (EEAA) in 2016 and reportedly remains applicable for Round 2. 

Following development of the EIA, the project’s Form B was submitted on 12 April 2016 as part of FiT Round 1 and was approved by the EEAA, this approval remains applicable for FiT Round 2.  The approval contains conditions which are largely similar to the SESA approval conditions, and includes an additional requirement for PV panels to have contrasting edge colors to reduce avian impacts.  The sponsors have stated that all requirements described in the EEAA’s decision will be considered within the design and management of the project.

The approval of the Form B, together with the SESA approval, constitute the Environmental Permit required for the project.  The sponsors have addressed the gap between the local EIA and various lender requirements through the development of the Environmental and Social Due Diligence (ESDD) checklist/report, to specifically address the assessment of impacts in alignment with the PSs. 

As part of IFCs involvement, the sponsors will ensure that ESHS risks and impacts identified in the EIA and in the permit requirements are appropriately addressed in the project’s ESHS MS.  As part of this, it the ESHS Management Plan (ESHS MPs) will be further developed into a clear plan of action for the identified risks/impacts with assigned responsibilities and deadlines.  This will also be implemented by the EPC Contractor and sub-contractors.

Cumulative Impacts: 

As mentioned above, the SESA for the Benban PV solar park was prepared for NREA with funding from the European Bank for Reconstruction and Development (EBRD) in July 2015, in consultation with IFC.  The SESA concluded that the ESHS risks from individual solar developments at the Benban PV solar park could be adequately managed through standard application of good practices, but the cumulative impacts from several developments (39 plots) advancing in the same area at the same time could pose potential significant challenges and risks related primarily to traffic and transportation, occupational health and safety, accommodation, labor management, waste management, security and the management of stakeholder expectations from nearby local communities.  The SESA also concluded that in order to address these “common issues” for all developers, a coordinated aligned approach was needed.  It further noted opportunities for positive impacts related to engagement with the local communities and community investment efforts if carried out strategically and in a coordinated manner.

Following close engagement by IFC and other Lenders with the various developers, the Benban Developers Association (BDA) was formed (and currently encompasses the participation of most of the developers) to enhance their collective efforts of tackling the key E&S risks for the Benban PV solar park in a coordinated manner.  The BDA was initially formed in 2016 in connection of Round 1 of the FiT, and then reactivated in 2017 in connection with Round 2.  This has led to the decision by the BDA, in coordination with the EETC and NREA, to appoint a FMC for the entire site and for this FMC to develop the various E&S management plans and strategies recommended in the SESA and provide construction services in line with IFC Performance Standards, EBRD Performance Requirements, and EIB Environmental and Social Standards.  This includes, but is not limited to the development of a Labor and Workers Relations Strategy, A Workers Accommodation Strategy, A Security Management Plan, a Traffic Risk Assessment and Management Plan, an Environmental, Health and Safety Plan and a Community Investment Strategy.  The FMC will also provide “mandatory” services to all developers, whether or not they are part of the BDA, during construction related to site EHS management, traffic management, community stakeholder engagement and grievance management and waste management.  On labor management, the FMC will also be expected to be establishing offices in Benban and Fares to channel all local labor subcontracting for the various projects.  The sponsor, through the EPC JV, is required to comply with all items outlined in the SESA as “common issues” and to coordinate with the FMC on these various action items as per ESAP action item #1.

Environmental and Social Assessment and Management System

The sponsors will develop an Environmental, Social, and Health and Safety (ESHS) Management System (ESMS MS) prior to project construction, which will largely consist of an E&S Policy and Health & Safety (H&S) Policy, an E&S Management Plan (ESMP) with monitoring actions, an overarching system for reporting and tracking non-compliances, and an organizational framework.  The ESHS MS will include an Emergency Preparedness and Response Plan.  The sponsors have developed an ESHS MS specific to the project which needs to be updated accordingly.  The plan sets out the ESHS management expectations and requirements of the sponsors and the EPC Contractor.  It provides a suitable framework that sets out objectives and defines requirements in relation to roles and responsibilities, legal and other requirements, training, reporting, monitoring, incident investigation, and emergency preparedness and response.  It also provides a framework for the development of project-specific ESHS management plans. 

The plan is high level from which more detailed plans and procedures need to be developed by either the sponsors or EPC Contractor.  The EPC has developed a project specific ESHS MS that covers the key elements expected within an ESHS MS, however needs to be revised and updated to address identified gaps such as 1) including responsibilities for interface with the FMC and implementation of FMC management plans as well as linkages to all applicable project and FMC ESHS MPs, 2)  including a project ESHS organogram for sponsors and EPC, 3) to include project ESHS objectives, action plan and measurable performance indicators, and 4) sponsors’ monitoring and reporting (e.g. type/frequency of inspections/audits/reports).  The sponsors’ ESHS MS will address the relevant conditions set out in the letter of approval attached to the SESA.  The required improvements to the project-specific ESMS are captured in ESAP item #2.  All project-specific documents will be developed in Arabic and/or English.

The sponsors in the SPV, as well as the EPC ib Vogt have corporate management systems which will be in compliance with ISO 14001, 9001 and OHSAS 18001.  As the EPC and O&M Contractor are the same company (ib Vogt) there should be a seamless transition of the project from an EPC to the O&M Contractor which should minimize ESHS risks in the operational phase.

The EPC Contract is a key tool for ensuring compliance with the ESHS requirements of the sponsors.  The contract was reviewed and will be updated to include specific requirements to comply with IFC PSs by the EPC Contractor and where applicable subcontractors and main suppliers, as well as a provision of resources for ESHS management and monitoring compliance of its subcontractors as captured in ESAP item #3.

Management Programs

The EIA and EMP contains separate outlines for the sponsors’ ESHS MPs for the construction, operational and decommissioning phases of the project which are largely based on the sponsors’ corporate documents which have been partially adapted to the project setting.  Management actions described in the ESHS MPs include air quality, noise, soil, water resources, chance finds, and health and safety amongst other topics.  The ESHS MPs include details on monitoring actions, and the frequency of monitoring, along with the performance indicators and the responsible entity EPC contractor / O&M provider (i.e. ib Vogt).  The project through its EPCwill need to make its ESHS MP project-specific and align relevant ESHS aspects with, or adopt, the ESHS MP developed by the FMC for the management of the cumulative ESHS impacts for the Benban PV solar park, as detailed in ESAP item #1.  

The sponsors will ensure that workers understand the requirements, measures, and protocols stipulated within the ESMP.  It will also ensure that all E&S personnel are competent to carry out their duties, or, where necessary, arrange for suitable training to be undertaken to achieve this level of competency before the construction starts.

The sponsors have already developed a chance finds procedure as required by the SESA approval, however this procedure needs to be updated to include compliance with IFC’s PS8, as well as provide evidence that procedure is included in training program of the EPC.  This procedure will be included as part of the project’s ESHS MS and the sponsors will need to monitor the EPC Contractor’s compliance as detailed in ESAP items #2.

Organizational Capacity and Competency

The E&S management team will consist of at least one on-site Environmental, Health and Safety (EHS) Officer for the construction and at least one EHS Officer during operation based off-site.  The sponsors will assign an EHS focal point within their company to supervise the project.  In addition, the EPC will appoint an EHS focal person on site.  Additional EHS support staff will be procured prior to the start of the construction phase to ensure that there are sufficient qualified staff on site to manage the risks, and ensure that environmental and, health and safety management practices are carried out adequately.  The EPC’s (ib Vogt) EHS focal person will liaise closely with the FMC to coordinate all “common issues” needed between the project site and the overall solar park.  The sponsors’ EHS focal person will be responsible for the implementation of the ESHS MP, including monitoring actions (ESAP item #4).  

Emergency Preparedness and Response

The sponsors will ensure that a project-specific Emergency Preparedness and Response Plan (EPRP) is developed, and that the EPRP is aligned with the EPRP for the Benban PV solar park.  The EPRP plan will follow the National Fire Protection Association (NFPA) 101 standard or an equivalent internationally recognized standard, and will be developed for construction and operation phases of the project.  The EPC will provide adequate training to staff to ensure that all workers on-site are familiar with the EPRP.

Monitoring and Review

EHS monitoring requirements will be included in the ESHS MP for the construction and the operations phases of the project as mentioned in the sub-section above on ‘Management Programs’ in this document.

The project will employ up to 200 workers during construction, and 20 workers during operations, with additional workers for panel cleaning during cleaning events, as well as 3 security personnel with two 12 hour shifts each.  The sponsors, in coordination with the FMC, will encourage contractors to hire workers from the local communities.  The recruitment of workers will comply with FMC’s recruitment procedures which will seek to place jobs locally, before recruiting from further afield in Egypt.  Workers employed by the project during construction will be transported from the local communities and Aswan, or accommodated in FMC managed or approved worker accommodation at the Benban PV solar park. All aspects related to workers’ accommodation will be managed by the FMC or conform to the FMC’s workers’ accommodation standards and PS requirements.  The sponsors will develop a comprehensive workers’ accommodation plan for the project following the IFC workers’ accommodation guidelines that complies and is coordinated strictly with the FMC and the FMC’s worker accommodation plan as identified in ESAP Item #5.

Human Resources Policies and Procedures

As identified in ESAP Item #6 the sponsors will ensure that the EPC develops a Human Resources (HR) policy and procedures in line with IFC’s PS2 and with Egyptian labor law and that these are applied to their workers and sub-contractors.  As sub-contractors will likely be responsible for hiring workers, it is important that they implement their HR policy and procedures in line with those of the EPC.  The HR policy and procedures will be aligned with those of the FMC and stipulate that the terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation and holiday, are established according to national labor regulations, and will be included in employee contracts.  Additional workers’ benefits for full-time operations staff will include health insurance and medical assistance, among others.  Working conditions (including health, safety and security), employee termination, prohibition to employ minors, disciplinary actions, workers’ rights and obligations, employer’s rights and obligations will also be referenced.

As also indicated in ESAP Item #6, the sponsors will ensure that their own overarching HR policy is in line with PS2 and ensure that the HR policy and procedures developed by the EPC are in alignment.  Human Resources KPIs will also be developed for reporting from any sub-contractors to the EPC and on to the sponsors.  The HR procedures will incorporate any relevant HR procedures which are developed by the FMC and cover the whole site.  

Workers’ Organization

In line with PS2, the sponsors’ HR policy will not impede workers from freedom of association and collective bargaining.  Workers will be able to organize among themselves and will not be discriminated against for doing so, as will be specified and updated accordingly in the HR policy and procedures.

Non-discrimination and Equal Opportunity

The sponsors are committed to avoid all forms of discrimination against its employees, based on the age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs of its counterparties.  The requirements of non-discrimination and equal opportunities will be extended to all contractors and subcontractors as part of contractual obligations.  The sponsors’ HR policy will exclude the use of any form of forced or compulsory labor, in accordance with national law and IFC PS2.  

As indicated in ESAP Item #6, training for workers will be covered in the EPC’s HR procedures.  Induction training on the HR policy and procedures and basic safety awareness training will be provided to all newly hired workers.  Other types of technical skills training will be identified for staff on an as-need basis. 

Worker Grievance Mechanism

The sponsors will develop and make available a worker grievance mechanism (ESAP Action #7) which is aligned with PS2, and will inform the workers of the grievance mechanism, through its EPC, and describe how to make use of it during the induction training.  The grievance mechanism will also be accessible to other contractors and subcontractors performing work in core business processes of the project.

Occupational Health and Safety

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

As identified in ESAP Action Item #8 the sponsors will ensure that the EPC develops, as part of its ESHS Management System, a project-specific OHS procedure for the construction and operations phase.  The procedure will be designed to be specific to the PV solar sector (in terms of industry specific hazards) and the project site.  The OHS procedures will also include project-specific Emergency Preparedness and Response Procedures (EPRP) which will include fire risk assessment and control systems, fire alarm systems and drills, emergency preparedness and planning, as part of OHS procedures for both the construction and operation phases.  The EPRP will be aligned with and describe the reporting requirements and roles and responsibilities in relation to the FMC’S EPRP. 

The sponsors will also ensure that the EPC assesses and tracks its OHS performance during both construction and operations.  OHS performance evaluations will be carried out for employees considering lagging (or trailing / downstream) indicators and leading (or upstream) indicators EPC’s EHS Officer will record and track any OHS incidents through an incident tracker and will report on OHS performance during both construction and operation phase.

Workers Engaged by Third Parties

The sponsors will take reasonable efforts to ascertain that the third parties who engage these workers are reputable and legitimate enterprises and have an appropriate ESHS MS that will allow them to operate in a manner consistent with the requirements of IFC’s Performance Standards.  The sponsors will establish policies and procedures for managing and monitoring the performance of such third party employees in relation to IFC’s PS’s as well as incorporate these requirements in contractual agreements with such third party employees, as identified in ESAP #9.

Supply Chain Management

The sponsors anticipate that the PV panels for the project are to be obtained from foreign countries.  The sponsors will conduct a supply chain assessment of the nominated primary PV supplier to identify key E&S risks/impacts and ensure the supplier complies with the principles of IFC’s PSs to appropriately manage these risks.  Particular consideration in the assessment should be given to confirming the adequacy of the manufacturing facility’s management of hazardous material storage, waste storage/disposal, compliance with working conditions and occupational and community health and safety requirements to demonstrate that the project’s suppliers are complying with IFC’s Performance Standards and EHS Guidelines.  The sponsors and EPC will include a clause in main supplier contracts regarding applicable PS2 requirements on child or forced labor and OHS. 

Resource Efficiency & Water

Resource consumption on a PV project is expected to be minimal, with the main resource of note during construction being water use for dust suppression, concrete production, and domestic usage.  During operations the main water use will be water for cleaning the PV modules after sandstorms and when necessary (dry cleaning is the primary method of cleaning), and for domestic use.  Water will be supplied either through Benban PV solar park’s groundwater wells via a shared facility managed by the FMC, or through water trucks.  During construction, the estimated water consumption will be approximately 600 m3/month, whilst during operation the estimated average water consumption will be 710 m3/month.  The frequency of water truck movements during construction is estimated to be 10 water trucks/day.  The actual volume of water used will depend on the balance between dry and wet cleaning, and the number of wet cleaning events (influenced by the number of sandstorms etc.).  It is expected that wet cleaning will be done twice a month.  Maintenance of photovoltaic systems is expected to be minimal and would be mainly related to activities during the periodic cleaning.  Water use will be a key performance indicator (KPI) and reported as part of the sponsors’ E&S performance (ESAP #10).   

Solid Waste Management

Wastes generated during construction mainly consist of municipal and construction wastes that will be collected by a FMC approved contractor to be disposed of in designated landfill sites.  The overall volumes of both solid and hazardous waste generated by the project during construction will be minimal.  It is anticipated that solid waste will comprise paper, wood, plastic, scrap metals, and glass, and hazardous will comprises waste oil from machinery lubricants.  In addition, there may be some medical waste, and contaminated soils and absorbent materials.  These waste streams will be segregated as per the EPC’s procedures in the ESHS MP and volumes recorded.  Hazardous materials will be stored in a dedicated area; a register will be maintained and Material Safety Data Sheets displayed in Arabic and English.  The EPC’s waste management procedures will be aligned with those of the FMC and waste disposal will be through licensed third party waste contractors approved or contracted by the FMC, with the disposal being to suitably designated municipal or hazardous waste landfills.

During operation, waste generated will be largely limited to domestic waste, and waste generated from maintenance.  At the end of the PPA, when the plant is decommissioned, PV panels will be recycled.  Waste disposal during operation will be managed through licensed third party waste contractors approved or contracted by the FMC.

Energy Efficiency &GHG Emissions

Greenhouse gas emissions from the project during the construction are expected to be predominantly associated with the use of fuels such as in generators and transport, although the quantities of emissions have not been calculated, these are expected to be low and significantly less than 25,000 tonnes CO2e.

The mean GHG emissions of manufacturing silicon modules (Lifecycle GHG emissions) is about 85 tCO2eq/GWh.  The project is expected to generate approximately 142.94 gigawatt hours (GWh) of electricity per year.  Egypt’s current carbon dioxide emission performance (from fuel combustion) is 0.465 kg carbon dioxide per kilowatt hour (CO2/kWh) (according to International Energy Statistics, 2013) compared to 0.040 kg CO2eq/kWh associated with the PV lifecycle GHG.  Using this factor, the project is estimated to avoid the equivalent of 60,750 tons of CO2eq/year.

Pollution Prevention

A diesel generator will be used during construction, and as a backup power supply during operation.  The sponsors will require the EPC to implement pollution prevention measures in accordance with their management procedures contained in the ESHS MP to minimize the risk of any pollution and as needed remedy any incidents in an effective and timely manner. 

The Sponsors and EPC will develop environmental management plans and/or procedures (as part of the construction and operational elements of the ESHS MS) relevant to the Benban site to manage pollution related aspects of the project in line with the requirements of relevant sections of the applicable WBG EHS Guidelines.  Aspects should cover, among others dust, management of waste, hazardous materials, spills, occupational noise, etc., as captured in ESAP item #11.

Wastewater Treatment

Other than minor amounts of sanitary wastewater, the project will generate little wastewater, with all run-off and rainwater being allowed to evaporate and/or infiltrate the ground.  The project will use septic tanks during construction and operations which will be maintained and emptied by FMC’s approved third party wastewater contractors authorized by the governorate for wastewater disposal.  It is anticipated that the wastewater would be discharged at the nearest wastewater treatment plant in Ballana (which has a daily treatment capacity of about 3,200 m3/day and serves the communities of Daraw and Kom Ombo) located about 20 km from Benban.  Any management of wastewater will need to comply with the requirements of relevant sections of the applicable WBG EHS Guidelines.

Community Health and Safety

As part of the ESHS MP, the sponsors will be required to develop a Community Health and Safety Plan as well as a plan for Training and Awareness which will be aligned to the FMC plans.  The FMC plans will need to address the influx of construction workers coming into the Benban area for the project development, and their potential impact on the community at large including the risk of infectious diseases, proper buffer zones and all requirements listed in PS4.  To ensure security and protect the community from its project the sponsors aim to construct a perimeter fence height of approximately 2 meters above grade with climb-over protection.

Traffic Management

As noted in the SESA, traffic management will be of considerable risk to the project during construction with an estimated 1,400 vehicles/day accessing the solar park (from the various developers) during peak construction.  Unless traffic is managed well this could pose a significant risk to the workers and personnel on site, and also to the community at large as the main access road to the solar park which will be considerably congested.  The traffic movements to the project will include approximately 20 vehicles/day including water trucks, materials and workforce transportation during the construction phase. Project traffic management will need to be coordinated with the FMC and aligned with the FMC’s traffic management plan to ensure that risks to workers and community members are mitigated.  As such the sponsors will develop a project-specific traffic management plan in alignment with the FMC’s overarching traffic management plan as identified in ESAP #12.

The internal roads on the solar park will consist of compacted site material and gravel capable of supporting the traffic loads during construction and operation.  The entrance to the project will be set on the south side of the sponsors’ plot.  A new 6 km road will be built by the NREA to connect to the Benban PV solar park with the existing asphalt road. 

Security

A licensed private security company will be hired by the sponsors to manage security of the project.  The security company will provide 3 unarmed security guards on site (3 guards on each 12 hour shift), and it is intended to hire these from the local community.  The sponsors will ensure that key elements of PS4 are implemented, and. to achieve this will develop a Security Risk Assessment and a Security Management Plan (SMP) as outlined in the ESAP item #13.  This plan will be aligned with FMC’s Security Risk Assessment and Security Management Plan for the whole Benban PV solar park.  The sponsors’ security company will work closely with the FMC’s security company.

In making such SMP arrangements, the sponsors will be guided by the principles of proportionality and good international practice in relation to hiring, rules of conduct, training, equipping, and monitoring of such workers, and by applicable law.  The SMP will be aligned with the Voluntary Principles on Security and Human Rights (http://www.voluntaryprinciples.org).  The sponsors will make reasonable inquiries to ensure that those providing security are not implicated in past abuses; will train them adequately in the use of force, and appropriate conduct toward workers and nearby communities; and require them to act within the applicable law.  The sponsors will not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat. 

Stakeholder Engagement:

Stakeholder engagement activities were carried out as part of the development of the SESA, hence, the form B EIA for the project did not require individual stakeholder engagement, consultation, public scoping, or disclosure activities.  

Moving forward, all stakeholder engagement will be managed through the FMC and build on the engagement undertaken as part of the SESA and the developed Master Disclosure and Engagement Plan.  Engagement as part of the SESA included meetings with local villagers, both individually and as a group.  The project is located on desert land which is owned by the Egyptian Government and project access is along newly constructed NREA roads from the local public highway.  There will no road or land impacts on the local villages, and there are no stakeholders directly affected by the project.  The FMC will develop a Stakeholder Engagement Plan (SEP) which covers the whole Benban PV solar park and therefore there is no requirement for the sponsors to develop a project specific SEP. 

Community engagement opportunities were identified as part of the ESIA process.  It is understandable that opportunities for community investment could not all be addressed by one investor/project and are more effectively addressed through collaborative efforts of the different developers.  A number of potential opportunities for community development exist and were initially identified including training (for local employment), health services (improving health units), and infrastructure (including schools and roads).  The community development outlined by the sponsors for Corporate Social Responsibility (CSR) should be in line with the strategic community investment efforts of the BDA through the FMC to ensure a coordinated effort on the part of the whole solar park.

The FMC will develop a Community Grievance Mechanism for the Benban PV solar park in alignment with PS1, and will be responsible for responding to any grievances which are raised in relation to the overall site or individual developers.  The sponsors will develop a subsidiary Community Grievance Mechanism which will include details of how it will be responsible for responding to any grievances identified by FMC as being caused by the activities of the project, or its EPC contractors as identified in ESAP item #14.  All responses to grievances will be processed by the FMC to ensure a consistent approach to stakeholder consultation from the whole site.  The Community Grievance Mechanism will be created prior to the start of construction to ensure that the sponsors can respond to any local stakeholder issues reported to FMC at any stage in the project cycle.

Name       Kamel Khalil

Title:        ESHS Manager

Address:  Interstate Paper Industries, 4^th Industrial Zone, Sadat City, P.O. Box: 165 Sadat City, Menoufia, Egypt

Email:      kamel.khalil@ipitissue.com

Phone:      01116116553