The following PS are not relevant for this transaction: PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources – the project under consideration for IFC financing is in an urban setting and there are no negative impacts on significant biodiversity values; PS 7: Indigenous Peoples – there are no Indigenous Peoples in the area or affected by the project; and PS 8: Cultural Heritage – the project is not located in areas of known cultural heritage significance.

This is a Category A project according to IFC’s Policy on E&S Sustainability because the newly identified QBCs will have potential significant adverse environmental or social risks and/or impacts that are diverse, irreversible, or unprecedented.

Key E&S issues associated with this proposed investment include: LAMATA’s ESHS management system (ESMS) and capacity; procurement and contractor management systems; social risks and impacts due to physical and economic displacement of residences and businesses; engagement with affected communities and businesses; and alignment with internationally recognized good practices for the sector in which the projects are undertaken.

LAMATA has a robust ESMS, largely aligned with IFC Performance Standards (PS), designed to ensure that its operations comply with all applicable local regulations and WB E&S Safeguard Policies (where relevant). Under this proposed investment, LAMATA will adopt IFC PS as part of applicable requirements for the two QBC packages and consider issues identified in PS1 through PS8 when assessing E&S risks and impacts and implementing specific mitigation, monitoring, and management steps to provide enhanced oversight of its E&S performance.

As part of its ESMS, LAMATA has an E&S Screening Procedure that identifies potential E&S impacts and determines the E&S categorization, applicable local and WB Safeguard Policies, existing E&S liabilities, and location sensitivities (e.g., sensitive environment such as natural habitat and cultural heritage).

Project-specific E&S issues are managed through E&S Management Plans (ESMP) developed per LAMATA's E&S Management Framework (ESMF), which outlines the principles and procedures to be followed to ensure that implementation of projects under the LSTMPP 1 (such as the projects being considered for IFC financing) meets existing Environmental Impact Assessment (EIA) laws in Nigeria and relevant WB E&S Safeguard Policies. Additionally, LAMATA has a Social/Environmental Management Guide for Civil Works and an Environmental/Social Specifications and Checklist for Contractors to guide road authorities, consulting engineers, and contractors on the integration of E&S actions associated with road improvement into the planning, design, and implementation of road rehabilitation and maintenance works.

Detailed project designs for the new QBC packages have been prepared. Correspondingly, as per the ESMF, two ESIAs, including project-specific E&S Management Plans (ESMP) and RAPs, were completed in June 2024 and are aligned with national requirements, WB Safeguard Policies, IFC’s Performance Standards, and the WBG EHS Guidelines. As noted in the ESIAs, LAMATA will require project contractors to conduct E&S assessments for any quarries to be used for sourcing construction materials before project construction starts (ESAP item #1).

LAMATA has an E&S Safeguards Unit led by an experienced Safeguards Manager who reports to the Director of Corporate and Investment Planning (DCIP). The Unit ensures programmatic integration of ESHS functions for all its operations and those of its contractors. It has dedicated staff resources, including a Social Specialist and an EHS Officer. In addition, there is a Head of Administration and Human Resources (HR) responsible for overseeing matters related to labor, working conditions, and occupational health and safety (OHS).

LAMATA’s E&S Supervisors are responsible for the day-to-day supervision of the implementation of project-level programs and plans.  LAMATA provides professional training to key personnel to ensure they have relevant skills and adequate training to perform their work.  In accordance with the project-specific work plans, project or site managers are responsible for providing EHS training to employees, including contractor personnel.

LAMATA monitors EHS performance for each project according to the procedures established in their existing ESMS and project specific ESMPs. In addition to standard procedures, project-specific monitoring procedures are developed to comply with provisions contained in the ESIA. If monitoring results indicate non-conformance with standards or deviations from established benchmarks, appropriate corrective or preventive actions are initiated. A similar approach is adopted for unplanned events such as accidents where the events are investigated and corrective or preventive actions initiated to prevent recurrence. The Infrastructure Department, together with the EHS Officer, is responsible for monitoring the EHS performance of the projects, on a weekly basis, while supervision consultants monitor contractor performance daily and confirm job certification before payment.

LAMATA will review and update its Social/Environmental Management Guide for Civil Works and its Environmental/Social Specifications and Checklist for Contractors to incorporate OHS and labor standard provisions as applicable to the IFC-financed QBCs (ESAP item #2) and will develop a Contractor E&S Management Procedure (CESMP) (ESAP item #3) in line with IFC PS2 requirements. The CESMP will include at a minimum: (i) E&S considerations in the bid evaluation process; (ii) introduce E&S binding clauses in the contracts made with the contractors that will cover relevant policies, guidelines and checklists, IFC PS requirements, as well as any Nigerian OHS and labor regulations and the implementation of the construction related ESMP items; (iii) define regular inspection and audit mechanisms to ensure compliance of the contractor with the contractual E&S requirements; and (iv) require that the contractor either has in place its own workers’ grievance redress mechanism (WGRM) or facilitate their access to LAMATA’s WGRM.

Following the completion of construction activities, it is expected that informal transport operators will no longer be permitted to operate on the QBCs (only designated buses will be authorized to use the corridors). LAMATA is currently conducting a study (Bus Industry Transition for Informal Operators) involving a census of informal operators and negotiations on the best option for their integration into the new transport system (e.g., formal employment as operators, drivers, technical agents, etc., alternative livelihood support, or compensation for their economic displacement). The study will be concluded in November 2025. Pending the outcomes of the study, LAMATA will implement the agreed-upon measures to manage the impacts of the project on informal transport operators (ESAP item #4).

Currently LAMATA employs 160 people directly and has a dedicated Administration and HR Unit, led by an HR Director. In addition, LAMATA currently employ over 290 contractors who employ over 4,460 workers carrying out civil works, drainage and routine maintenance of the road network. LAMATA’s Employee Handbook makes provisions for recruitment, induction, non-discrimination, and equal opportunity, harassment-related redress process, performance management, redundancy policy and process, and general terms and conditions of employment that apply to all employees with personal contracts with LAMATA (i.e., permanent staff, contract staff, consultants, etc.). The Handbook is available to all employees at the time of induction.  While the Handbook references national labor laws, it does not identify or acknowledge workers’ rights. LAMATA will update its existing Employee Handbook to include a commitment to respect the rights of workers, including but not limited to freedom of association and the right to collective bargaining (ESAP item #5).

The minimum employment age at LAMATA is 18 years. This is confirmed by collecting age-proof documentation at the time of recruitment. In addition, by law, LAMATA does not employ any form of forced or bonded labor.

It is expected the construction phase for each QBC will require recruitment of approximately 200 workers, who will be engaged through contractors to LAMATA. As part of the ESMP implementation, LAMATA will develop and implement a Workforce Management Plan in accordance with PS2 requirements (ESAP item #6). The Plan will align with LAMATA’s existing HR policies and cover third-party workers (i.e., contractor personnel) directly linked to the IFC-financed QBCs, to ensure any risks to labor or working conditions are adequately addressed. Among others, the Workforce Management Plan will address terms of employment and working conditions, project workforce requirements, recruitment procedures, management of employment contracts, gender-based violence and harassment, workers’ accommodations, and transport.

LAMATA will develop and implement a workforce grievance redress mechanism (WGRM) for all project workers (including contractor personnel) to ensure there is a clear procedure to receive, register, and address grievances in accordance with PS2 requirements (ESAP item #7). The WGRM will be communicated to workers as part of project induction and on an ongoing basis. The mechanism will allow for anonymous complaints to be raised and addressed without the risk of reprisals and will ensure that concerns can be raised other than to immediate supervisors.

The Administrative and HR Unit and the Traffic Management and Safety Unit at LAMATA provide OHS oversight of all projects, facilities, and operations. Training of workers is done on a routine basis in compliance with local workplace regulations. The HR Department is responsible for ensuring that all employees are adequately trained to perform their work safely. All employees undergo a training program at induction regarding worker OHS relevant to their job activity.

The primary focus of OHS requirements for the IFC-financed QBCs will be during the construction phase; OHS risks will be limited during the operations phase. LAMATA will procure the services of third-party construction contractors to undertake the civil works under this project. As part of the ESMP implementation, LAMATA will develop and implement a project-specific Health and Safety Management Plan for workers (ESAP item #8).

Site-specific pollution prevention and mitigation measures and resource conservation and efficiency considerations associated with the selected QBCs are included in the corresponding ESIA and ESMP, which are aligned with IFC PS3 provisions and relevant WBG EHS Guidelines, and cover measures associated with potential air and noise emissions, solid and liquid waste generation, hazardous materials (e.g., minor fuel spills), and weed management. Additional management plans for pollution prevention will be prepared as required by the project ESIAs/ESMPs including, but not limited to, the development and implementation of a Waste Management Plan and a Spill Response Plan (ESAP item #9).

As per the CESMP (see ESAP #3), LAMATA will contractually require and ensure that its contractors adhere to LAMATA’s E&S standards. LAMATA will work with the Lagos State Environmental Protection Agency to implement an appropriate monthly monitoring and reporting program, including monitoring of ambient air quality and noise levels at pre-construction and during construction and operations, particularly at sensitive receptors, and as described in the project ESMPs. Monitoring of noise levels and nearby surface and ground water will also be implemented during construction and operation of the IFC-financed QBCs, as described in the project ESMPs.

The Traffic Management and Safety Unit at LAMATA ensures public safety in its projects through the development and implementation of specific plans and measures per provisions described in LAMATA’s ESMF. For the IFC-financed QBCs, LAMATA will ensure appropriate procedures to minimize community health and safety risks during construction and operations are implemented according to good international practices, including but not limited to safe corridors and crossings for pedestrians, appropriate speed limits, speed control devices near crossings, appropriate signage, access controls, roadside laybys, real-time warning systems, and other accident prevention measures. The QBCs will follow LAMATA’s Social/ Environmental Management Guide for Civil Works provisions for community health and safety risk management.

As per the recommendations of the ESIAs for the IFC-financed QBCs, LAMATA will develop and implement a Traffic Management Plan to minimize traffic congestion and accidents during the construction phase, which will be applicable to all contractors (ESAP item #10).

Private security personnel will be engaged for the construction and operation phases of the project. To address related risks, LAMATA will develop and implement a Security Management Protocol per IFC PS4 requirements (ESAP item #11). The Protocol will outline the accreditation and training requirements for security personnel associated with the project and will include a policy on the use of force. LAMATA will be responsible for monitoring compliance with this Protocol by all security personnel, including with any public security forces, as needed.

LAMATA has a Stakeholder Management Strategy and a Stakeholder Engagement Plan (SEP) aligned with WB requirements to guide community engagement activities. LAMATA's Media and Communication Unit takes the lead in identifying and managing stakeholder engagement on all projects, initiatives, and interventions. Stakeholder engagement covers the project lifecycle with the overall objective of enhancing stakeholder ownership and participation. LAMATA has programs on television, radio, and social media (Instagram, Facebook, and website).

Per Nigerian requirements, ESIAs are submitted to the Federal Ministry of Environment, Abuja and disclosed publicly at relevant Local Government Area Headquarters, State Environmental Protection Agency, State and Federal Ministry of Environment Offices for a period of 21 working days. During this period, public comments are invited through advertisements in at least three national newspapers and announcements on radio and television in local languages of the project area.

As per the requirements above and the IFC PS, consultation with project stakeholders and PAP started in 2021 and continued throughout the development of the ESIAs and RAPs for the QBC 1 and QBC 2 packages. Scoping workshops on E&S issues to be studied in the ESIAs and RAPs were held in January 2022 with government agencies, community development associations, community members, and security agencies attending. Meetings with community leaders and consultation with PAP followed. Feedback collected through stakeholder consultation included the request that LAMATA continue to engage the community and PAP on the progress of works, which LAMATA has committed to do. A stakeholder engagement program has been developed as part of the RAPs, which will focus on consultation with affected households and other relevant stakeholders.

Implementation of the RAPs will include an update of the survey data to ensure all affected persons and assets have been identified.

LAMATA will review and update its existing SEP to ensure it reflects the project context and guide ongoing engagement (ESAP item #14). The updated SEP will include an external grievance mechanism to receive, resolve and track any issues raised by external stakeholders related to the project as per PS1 requirements.

Contact Person: Managing Director-Engr. Mrs Abimbola Akinajo

Company Name: LAMATA

Address: KM 15 Ikorodu Road, Ketu-Ojota Cloverleaf Interchange, Lagos Nigeria.

Email: aakinajo@lamata-ng.com

Tel: 012702778, +2349099526282