Environmental and Social Management System

CP has an integrated management system certified under international standards ISO 14.001 (environmental management), ISO 9.001 (quality management) and OHSAS 18.001 (health and occupational safety management), applied to its thermal and hydroelectric activities throughout Argentina. The project will be managed within the framework of this integrated management system. The organizational and functional structure of the integrated system is aligned with IFC PS 1. 

ESHS Policy

CP has a Code of Business Conduct, a Mission and Vision Statement, a Corporate Governance Code, an Integrated Policy (Environment, Quality, Safety, Hygiene and Occupational Health) and a Human Resources (HR) policy. The Integrated Policy provides a general statement on the principles guiding all activities managed by the company. In general terms, the principles and objectives of these documents are consistent with the IFC PS 1. Notwithstanding this, CP will establish a project-specific E&S policy that, in addition to being in line with the Integrated Policy of Central Puerto SA, will include a grievance mechanism for receiving and resolving labor and third party complaints, in addition to a grievance mechanism for interested and affected project stakeholders as required in PS 1. (ESAP Condition 1)

Identification of risks and impacts

E&S risks and Impacts for the construction phase of the project include those associated with the transportation of equipment and workers from the port of Bahia Blanca to the project site; traffic impacts; those associated with typical civil construction works (soil compaction, erosion, potential soil and groundwater contamination from hydrocarbon spills, vehicle emissions and dust generation). The most relevant health and safety risks will be those associated with work at heights, lifting loads, working in confined spaces, and risk of falling objects. Areas for the extraction of materials for civil works are not located in the Achiras area; sand will be extracted in Río Cuarto and stone from Berrotarán (80 km away) will be transported by truck to the site of the project.   Typical E&S risks and impacts during the operations phase include risks to bird and bats arising from turbine operation and safety risks for workers, especially falls from height and electrical risks. Noise and shadow flicker effects are not expected to be relevant due to the absence of households or sensitive habitats near the project site.

Project risks and impacts were partially identified in the ESIA. CP will ensure that risks and impacts identified during lenders due diligence, and discussed in this report, as well as all ESHS risks identified during construction phase are appropriately communicated to contractors. CP will prepare an ESHS risk matrix identification. (ESAP Condition 2)

Although the original EIA of the project was approved by the Secretariat of Environment and Climate Change of the Province of Córdoba, an Addendum to the study will be submitted. The reason for the Addendum is due to the following changes made to the project: each generator will deliver a power of 3.2 MW instead of 3 MW as planned; the number of generators shall be 15 and not 16; the total potential delivered by the park will then be 48 MW; the 33 KV line between generators will be aerial and not buried and the high voltage transmission line will be a double-circuit line, not a single circuit line as originally envisaged. At the moment of preparing this report CP had not yet submitted to the environmental authority all the documentation required in the environmental license. CP will submit this documentation to IFC prior to the commencement of construction works.

Organizational capacity and competency

During construction, CP will supervise all contractors (including environmental and occupational health and safety performance) by designating a team of experienced professionals. The sponsor has assigned an environmental manager and an occupational health and safety manager to work alongside Ventus, the project's technical supervising firm, during construction. The project construction contractors will be required to develop their own environmental and health and safety management plans and have their own E&S managers; these contractor management plans shall be consistent with CP's Environmental and Social Management Plan. CP will establish an Environmental and Health and Safety Committee, led by Ventus, to ensure alignment in the implementation of the Environmental and Social Management Plan. The main contractors include construction company Milicic, and turbine supplier Acciona. (ESAP Condition 3)

Training program

CP will prepare and implement a training program, aimed at raising contractors and subcontractors´ awareness on environmental, social, health and safety aspects of the Project, including emergency situations and issues related to communities´ relationships and archaeological findings management. (ESAP Condition 4)

Monitoring and review

As part of the ESHS Management Plan CP will develop and implement a Monitoring and Supervision Plan, prepared both for construction and operation phases, and aimed at: i) monitoring and measuring effectiveness of the ESHS management; ii) monitoring environmental and working conditions; iii) monitoring health programs; iv) monitoring legal compliance and v) monitoring and supervising contractors and subcontractors ´activities during the construction phase. The Monitoring and Supervision Plan will involve the active participation of project contractors and subcontractors. (ESAP Condition 5)

Although impacts on bird and bats are considered not relevant for this project, a related baseline and monitoring program shall be carried out by CP and included in the ESHS Monitoring and Supervision Plan. Details of these activities are discussed in the PS6 section in this report.

Emergency preparedness and response

CP will require the construction company prepares an Emergency Preparedness and Response Plan. This plan will include, in addition to measures aimed at protecting the life of workers and project facilities, considerations aimed at protecting the health and safety of neighboring communities and visitors to the project site. Protocols to be implemented by the project managers in case of an emergency and the necessary arrangements with the emergency services will be defined. The most relevant typical emergency conditions are: plant fires due to electrical failure or lightning strike, destruction of rotors by hurricanes or fires in the surrounding area (e.g. via burning of grasslands). CP will also require the operator to prepare an Emergency Preparedness and Response plan for the operation phase. (ESAP Condition 6)

The construction phase of the project is expected to require a maximum of 110 workers, whilst about 6 permanent jobs will be created during the operations phase.

Human resources policy and procedures

CP will establish a Human Resources (HR) policy and procedures based on the principles of the human resources policies and procedures of the CP Integrated Management System and IFC PS 2. Contractors will be required to align with those principles. CP will also ensure that documented information is provided to workers, includes details of any collective bargaining agreements, hours allocated to work, wages, overtime, compensation, training and benefits provided to workers. (ESAP Condition 7)

Working conditions and terms of employment

CP will avoid discrimination and ensure equality of opportunity during the processes of employing its own and contracted workers, especially considering the aspects of gender equality of applicants to fill jobs. The use of local labor should be prioritized, thus allowing the local economy to benefit. 

Grievance mechanism

The project will establish a workers' grievance mechanism that covers all workers and contractors and is accessible and transparent, providing timely feedback to claimants without risk of retribution and allowing anonymous complaints to be raised. (ESAP Condition 8)

Occupational Health and Safety

During the construction phase, CP will ensure that the project and all contractors adopt the same OHS practices and procedures at the project level. At the request of the financing entities, the bidding documents included the specific requirements for contractor companies, aimed at demonstrating compliance with legal norms and the IFC Performance Standards.

Under a contractual requirement, CP and contractors shall have a manager and a team dedicated to supervising, training and enforcing their workers with appropriate occupational and health and safety practices and procedures. CP will require the EPC contractor develops and implements a Health and Safety Plan for the construction phase, which will aligned with the ESHS Management Plan prepared by CP.

Contractors´OHS Plans will include: i) a chart of key personnel describing their roles and responsibilities; (ii) a list of training courses to be given to workers indicating their frequency and training verification mechanisms; (iii) a procedure for managing personal accidents and incidents; (iv) contingency and emergency preparedness and response measures, particularly during high risk activities such as working from heights during the installation of turbines and electrical components

Law 24557 governing work related risks require all projects to have an on-site medical facility and basic medical equipment and medication. The project is expected to hire a permanent ambulance service during construction works, to provide basic emergency services and transportation to a medical facility in case of requiring urgent care. All workers will receive training on emergency preparedness and response.

Workers engaged by third parties

The client has hired Ventus as ‘Owners Engineer’ to bring experience in the sector to the project. Ventus will have a dedicated team with permanent presence at the project site, and will be responsible for supervising contractor’s responsibilities and managing the interface with them.

Health and safety aspects and risks will be managed by Ventus in coordination with each contractor's health and safety manager. All workers will be required to comply with a code of conduct that prohibits behaviors and / or activities that could endanger the lives of workers, members of the local community and / or produce environmental impacts. CP will prepare a Code of Conduct for workers, to be fulfilled by all contractors during the construction and operation phases. (ESAP Condition 9)

To ensure a harmonious relationship with landowners neighboring the project site, CP will prepare and implement a Code of Conduct (per ESAP Condition 9) that will be mandatory for all contractors and their subcontractors. All workers will be required to comply with the Code of Conduct, by which specific behaviors and activities that could put in danger the lives of the individuals themselves, other workers, flora/fauna and members of the local community will be prohibited.

Infrastructure and equipment design and safety

During construction phase, the main project impact for the public will be linked to interruptions in local traffic during transportation of turbines, heavy machinery, workers and other materials along state highways. This may lead to traffic delays and increase the risk of road accidents. CP will implement (or require the EPC contractor to implement) a Transport Management Plan to identify the safest transportation routes, implement any road improvements needed to transport electromechanical elements, install road traffic safety signs, and prepare and apply traffic safety rules to all project drivers. (ESAP Condition 10)

Turbines are expected to be transported to the project site late in the evening to avoid blocking traffic on state highways during the day and during peak traffic hours. CP shall be responsible for maintaining direct contact and active coordination with the public services during any construction work that may result in the interruption of such services.

The traffic management plan shall include specific emergency preparedness and response measures to be implemented with the assistance of local authorities in the event of such events. In case of an accident, CP will take all measures to ensure that the impacts to the public are mitigated and managed. CP will present the contractor's traffic management plan to lenders for review prior to the start of construction.

Security personnel

As the project site is remote and there are no communities nearby, security personnel related risks are expected to be very low. CP will make use of a limited number of unarmed private security personnel to control site access and prevent theft during the construction phase. These personnel will be trained in CP’s Code of Conduct to ensure that interactions with workers and any neighboring landowners are cordial and professional.