No indigenous people or cultural heritage will be impacted in the course of this project; therefore, there are no risks and impacts related to PS7 (Indigenous Peoples) and PS8 (Cultural Heritage). A chance find procedure is available and is being implemented by Setrag.

Consistent with the first investment and based on the review of the risks and impacts during its implementation, this proposed second investment has also been categorized B as it is directed to the completion of the capital expenditure program of refurbishment of existing assets and infrastructure within an existing (brownfield) footprint. The IFC use of proceeds for this second investment will be directed at activities which are intended to make the company and its assets cleaner and safer for staff, communities and the receiving environment. Rails replacement will contribute to lowering risks of derailment and improve operational safety; safety walls and overpasses will improve community safety. Given the nature of this proposed second investment, key environmental and social issues are consistent with the ones reviewed during appraisal of the first investment and include occupational health and safety during refurbishment works, pollution control, provision of potable water to workers, hazardous and non-hazardous waste management, resettlement of informal settlers, community and pedestrian safety, emergency preparedness and response, and stakeholder engagement. The proposed investment entails further refurbishment of existing infrastructure within an existing corridor. No significant adverse impacts on biodiversity were anticipated as a result of the first review carried out by IFC and none have been reported throughout the implementation of the agreed Biodiversity Action Plan (BAP) during the first phase of the project, as discussed under Performance Standard 6 below.

 Environmental and Social Assessment and Management System

Setrag is a subsidiary of the Eramet Group which has a Sustainable Development Policy, an Environmental Policy, and an Ethics Charter. As required under the ESAP agreed for the initial investment, Setrag developed its own Environmental and Social Sustainability Policy in line with IFC’s Performance Standard 1. Most elements of an adequate Environmental and Social Management System (ESMS) are now available. There are procedures and teams responsible to ensure that: i) Setrag is in compliance with all applicable laws and regulations; ii) all environmental licenses are obtained for the different activities; and iii) the Environmental and Social Management Plans (ESMP), the Resettlement Action Plan, and the Biodiversity Action Plan are implemented. There are management programs and procedures covering aspects such as: environmental and occupational health and safety (OHS) procedures for contractors involved in refurbishment activities, train safety, vehicle safety, hazardous and non-hazardous waste management, spill management, chance find procedure, emergency preparedness and response plan, anti-poaching patrolling, pedestrian awareness raising, stakeholder engagement including a grievance mechanism. The stakeholder engagement plan (SEP) was developed in line with requirements of this Performance Standard. So far and given the scope of the project, its implementation has been focused on engagement activities needed for the implementation of the resettlement program, as discussed under Performance Standard 5 below. Going forward, the SEP will also focus on pedestrian safety and awareness related to railway crossing and other activities that take place in the vicinity of the railway corridor. This will include awareness raising on emergency response in cases of accidents.

Identification of Risks and Impacts

A number of environmental and social audits and action plans have been undertaken for the railway refurbishment projects. Setrag conductedan Environmental and Social Audit (2015), an Environmental and Social Management Plan (2015), a Resettlement Framework (2015) and a Resettlement Action Plan (2017), and a Biodiversity Action Plan (2015). All reports are in line with requirements of this Performance Standard. In accordance with the Environment Law (dated August 26, 1993) and consistent with IFC’s Performance Standards, Setrag also developed the following environmental studies: Environmental and Social Impact Assessment (ESIA) of sand extraction in the Ogooue River (2017), abridged ESIA of the sleepers plant in Booué (2016), abridged ESIA of the refurbishment project Kango-Franceville (2017), and abridged ESIA for workers accommodations in Lastourville, Moanda, and Ndole (2013). 

As indicated above, the project footprint does not exceed the existing railway corridor and rehabilitation works will be confined within the 30-meter wide safety corridor. Sources of risks and potential impacts associated with this project include use of machinery and transportation, presence of workers (one team of up to 100 workers), storage and disposal of hazardous materials including used sleepers, refurbishment of infrastructures, and presence of unstable track bed zones/slopes along the corridor, and the presence of informal settlers and informal economic activities within the safety corridor. Main E&S risks and issues are as follows: soil erosion and slope instability, air and water pollution, noise, waste production and contaminated sleepers, occupational health and safety risks, influx of workers, community health and safety risks, and resettlement of informal settlers.

The project is located in a country where the risk of Gender-Based Violence (GBV) is substantial due to the legal context, gender norms and beliefs, and actual capacity to respond and manage GBV issues. As part of this investment, a gender and GBV assessment will be undertaken. Among others, this will include a review of the Human Resources policy to include a policy on addressing sexual harassment. The client will review and, if necessary, revise procedures for implementing these policies to ensure and measure effectiveness and consistent usage and include recommendations for training, etc. The assessment will also include the risks and impacts to host communities of the project, such as for example the influx of contractors/migrants, and improvement measures for women safety along the railway corridor and in stations and supporting infrastructures.  Based on the findings, Setrag will develop and implement an action plan (e.g. influx management;  railway stations improvement measures such as safe waiting areas, adequate lighting in parking lots, separate toilets, CCTV; sufficient lightening around family houses; and improvement to existing stakeholder engagement plan and community grievance mechanism) that is designed to manage such risks and impacts effectively. The plan will include gender-specific mitigation measures to ensure risks are mitigated and will be included in the ESMS (ESAP #1).

Gabon is very rich in terms of biodiversity. The railway runs through natural habitat for about 80% of its length and passes through the Lope National Park (for 62 km), a World Heritage Site, the Bas Ogooué Ramsar Site (for 56 km), and the Rapides de Mboungou Badouma Ramsar Site (for 30 km). Based on the reviews carried out as part of the first investment, it was confirmed that Lope National Park, and the two Ramsar sites qualify as critical habitats based on criteria 1 (Critically Endangered and/or Endangered species) and 2 (Endemic and/or restricted-range species). Refer to the section on Performance Standard 6 below for more details.

Organizational Capacity and Competency

As part of the actions agreed under the ESAP for the first investment, the team responsible for E&S management was strenghtened and is now composed of eight staff in the E&S department, 17 staff in the OHS and fire safety department, five staff in the Railway Safety department, and seven staff in the Resettlement Bureau (including two senior social specialists, one data base officer, and three field agents) supported by an international resettlement expert. Since 2016 there is also a full-time international E&S coordinator responsible to ensure implementation of the IFC’s ESAP.  Under ESAP #2, another senior social specialist will be hired to strengthen the team for the implementation of both stakeholder engagement plan and Resettlement Action Plan, and existing staff will receive adequate training.

Given that the departments above were recently created, their roles and responsibilities and the coordination and communication among departments and with senior management are being defined as part of the initial implementation of the revised organization chart. Setrag’s organizational chart will include an E&S coordinating structure to ensure efficient communications and reporting lines between all E&S related departments, other departments and management. Clear roles and responsibilities will also be defined (ESAP #3).

The HR department offers a range of training programs. For example, in 2018, about 350 workers were trained in first aid, OHS, driving safety, and fire safety. Every year, about 100 workers are trained in fire-fighting and prevention. Thematic occupational health & safety training is provided to all workers every year (e.g., hazardous materials handling, work at height), and use of personal protection equipment. Specific annual training is provided to Safety Chiefs responsible for the safe movement of trains at the stations and to Regulators who are responsible for the safe operations of trains along the entire corridor. The train drivers and their assistants are also trained each year. They are also subject to continuous training and supervision.

Emergency Preparedness and Response

Setrag relies on an Emergency Preparedness and Response Plan (‘’Plan Fer’’), and Crisis Management guidelines in case of emergency scenarios such as natural disasters, fire, explosions, oil and hazardous materials spills, train accidents, terrorism or vandalism. These plans include the identification of areas where accidents and emergency situations may occur, response procedures, provision of equipment and resources, and designation of responsibilities and communication. The emergency plan for fire emergencies is fully in line with IFC’s requirements. For other scenarios, the plans do not include provisions on periodic training to ensure effective response, and community notification. As outlined in ESAP #4, the plans will be updated to include, among others, specific training and practice (i.e., simulations and drills) to ensure effective response, and community notification, and provisions for workers accommodations, in line with good international industry practice as described in the WBG General EHS Guidelines and the recommendations made by the International Union of Railways.

Monitoring and Review

Throughout the initial investment, Setrag has continued to report on key performance indicators to monitor energy and water consumption, air emissions (e.g. SOx, NOx, CO2, metals), hazardous and non-hazardous waste, etc. Relevant information continues to be compiled in a data base (Eragreen) and annual reports to be prepared for senior management. Lost Time Incidence Frequency Rate (LTIFR) and accident free days continue to be compiled in a specific data base (Eralink) and reported monthly. Customers and community complaints are also managed and documented. Progress on resettlement is being monitored (see under PS 5 below), and reports are drafted on a regular basis.  A specific data base on resettlement complaints was developed during the first phase of the project. This data base includes a complaint form, a numeric register georeferenced to the location of complainants, and a monitoring system to follow up on the responses. This system is being implemented to include all types of complaints. As part of the reporting requirements under the initial investment, since 2016 the company has consistently reported annually its performance to IFC.

 Human Resources Policies and Procedures

Setrag’s organizational structure has 3 levels: managers (c. 18,12%), technicians (c. 48,33%) and workers (c. 33,55%). In october 2019, Setrag had a total of 1,225 employees (among which 192 are women – 15,67%), with 222 management positions. Most of the employees have open ended contracts. Setrag hires third-party contractors providing services such as health, water management, electricity production and distribution in railway stations and worker accommodations, railway repair and maintenance.

Human Resources are managed according to an HR Internal Regulation (‘’Règlement intérieur’’ in line with the Gabonese Labor Law no 3/94, of 21 November 1994), as discussed under the ESRS disclosed for the first investment.  This Internal Regulation has documented procedures for hiring, selection, disciplinary practices and termination, and terms of employment (wages, benefits, working hours, overtime, rest days, breaks, and leave). Working conditions and terms of employment are specified in the written contracts signed by employees, provided and communicated to employees during induction. As agreed under the ESAP for the first investment, Setrag included in its HR Policy provisions with regards to non-discrimination and equal opportunity, child and forced labor, a worker grievance mechanism, supervision of workers engaged by third parties, and supply chain. While the updated policy provisions are consistent with Performance Standard 2, IFC’s monitoring found that dissemination of the grievance mechanism within the organization and awareness of workers are areas of improvement, as well as the treatment of anonymous complaints and complaints around sexual harassment. Setrag will review its induction training package and will inform the workers of the grievance mechanism at the time of recruitment and make it easily accessible to them. The grievance mechanism will also be updated to allow for anonymous complaints to be raised and addressed. Moreover, Setrag will develop a sexual harassment policy and a code of conduct to be signed by management, staff and by contractors and compliance will be required by the workforce. Finally, Setrag will develop an internal audit program for all sub-contractors to ensure alignment with contractual requirements and labor laws (ESAP #5).

Working conditions and terms of employment

Setrag complies with all national legislation limits related to working days per week, rest days and leave. The minimum salary (266,000 CFA) paid by Setrag is about 75% higher than the minimum wage in Gabon. In addition, each employee is eligible to the ‘’Caisse nationale de sécurité sociale’’ (i.e. CNSS- social security cover) in case of illnesses, work accidents, and retirement. Setrag provides also a supplementary private health and life insurance. Normal working hours begin at 07:30 and last until 15:30 and do not exceed 48 hours a week and 12 hours overtime a week. 

Workers accommodation is provided at a few railway stations.  There is a total of 1,014 houses along the railway corridor owned by Setrag. The number of houses varies from 66 in Lastourville to more than 300 in Booué. Most houses date from the 1970s and are in need of refurbishment. In the course of the first phase of this project, about 150 houses were refurbished and built in line with guidance from the IFC and the European Bank for Reconstruction and Development (EBRD) Guidance Note on Worker Accommodation Process and Standards, except for fire safety requirements where fire extinguishers are available in a few accommodations only. In the course of this project, a fire safety audit will be conducted in workers accommodations by a fire safety professional in line with national requirements, or an internationally recognized fire safety standard. A corrective action plan will be developed and implemented (ESAP #6).

Setrag provides drinking water to their workforce in all operational areas. Near urban centers, water is provided by the national utility company (Société d’énergie et d’eau du Gabon – SEEG). As required under the ESAP for the first investment, water treatments were upgraded in Booué, Lopé, Ndjolé and Lifouta. During the second investment, new water treatments are planned for the following locations: Mouyabi, Moanda, Mbel, Ivindo and Lastourville. As required under the ESAP for the first investment, the company has implemented a water monitoring plan and water monitoring is conducted monthly in all locations where SETRAG supplies water through its own installations, although microbiological testing is not done systematically.  In areas where water is not treated to WHO standards, Setrag provides bottled water. To complete the ongoing actions, Setrag will upgrade the water monitoring program, including microbiology testing, for all the locations, and in cases where water is not potable, will implement a corrective action plan (ESAP #7).

Workers’ Organization

Setrag’s workforce is represented by ten unions with a total of 42 representatives representing most direct workers. According to union representatives, main issues which continue to be raised by staff are availability of potable water and lodging. As such, Setrag is focusing on improving accommodations and supply of potable water. Union representatives are selected every three years and Setrag enters into collective bargaining with all the unions. The current collective bargaining agreement was signed in June 2017 and is valid for an undetermined period of time.

Occupational Health and Safety

Setrag has an OHS management system which addresses key aspects, including work hazards, work with heavy machinery and accidents statistics which are recorded on a monthly basis and compiled in an annual report to management. In the course of the first project, a specific OHS department was created with adequate resources and staff. The team developed a robust OHS management system commensurate with the scale of Setrag’s activities. Before the first phase of this project, Lost Time Injury Frequency Rate (LTIFR) was at 8 accidents per million hours (international benchmark rate for the railway sector is 6.5). In 2018, the LTIFR was at 3.7. Setrag has a medical center in Owendo staffed with three medical doctors and two nurses, and equipped with a pharmacy and a laboratory. Many of the railway stations have a nurse on site (eight nurses in total). As required under the ESAP for the first investment, an independent review of the OHS management system was conducted against this Performance Standards and good international industry practice. A corrective action plan was agreed and is under implementation with the objective that actions are completed by end of 2020.

 Resource Efficiency

Setrag’s rolling material includes 36 locomotives, 723 cargo wagons, and 41 passenger wagons. It includes also about 150 road vehicles (on rental and owned by SETRAG). Annual electricity consumption is 4,069,000 kWh, and water usage is around 270,000 L. Total annual gas oil consumption from locomotives, vehicles and generators is 11,457,000 L. 78,000 L of gasoline is used for vehicles. GHG emissions amount to circa 36,000 CO2 t equivalent per annum. The following actions have been implemented to reduce energy consumption: acquisition of 6 new locomotives, development of a transport plan, and the use of solar panels for lighting in railway stations.

Wastes

As discussed in the ESRS for the first investment, disclosed in 2015, waste management was a major issue at most Setrag sites. Families living near railway stations, including Setrag’s workers, used to burn their waste in open air behind their backyards, and none of the railway stations (except those in urban areas) had a designated area to properly dispose wastes. Under the ESAP for the first investment, a waste management plan was developed for the Booué area, and discussions have been held with the different municipalities to address the issue in a collaborative manner. In Owendo (Libreville), Gabon Propre Service collects solid waste once every two days and has a plan to build a recycling center. Used oil is collected by CimGabon and used at their cement factory. The company also has a contract with IEG, which has an incinerator in Port- Gentil where they dispose of contaminated soils. Medical wastes are sent to the incinerator at the main hospital in Libreville. Waste management improvements are still underway. The relevant action under the first investment’s ESAP, requiring a waste management system to be developed and implemented in all of Setrag’s sites, is to be completed and it has been kept open and moved to the ESAP #8 for this second investment. When complete, the system will include the following: review of waste sources, pollution prevention opportunities, and necessary treatment, storage, and disposal infrastructure; characterization of waste by type, quantities, and potential recycling/reuse/disposal options, establishment of priorities based on a risk analysis that takes into account the potential EHS risks during the waste cycle and the availability of infrastructure to manage the waste in an environmentally sound manner; opportunities for source reduction; procedures and operational controls for onsite storage; options / procedures / operational controls for treatment and final disposal.

Consistent with the agreed ESAP for the first investment, for all refurbished and newly constructed workers accommodations Setrag is building adequate sanitary facilities with septic tanks.  In general, sanitary effluents are managed by the national utility company (SEEG).

Hazardous Materials Management

When the railway concession started in 2005, Setrag identified a number of potentially contaminated sites within the concession areas, and there were no oil water separator and grease traps in any of the maintenance workshops for rolling material. As required under the ESAP for the first investment, Setrag started to rehabilitate some of the contaminated sites, and installed oil separators (in Owendo, Booué, and Franceville). It also mandated a consultant to develop an assessment and remedial action plan for 20 contaminated sites. Setrag developed hazardous materials transport and spill management procedures but still lacks a hazardous materials management plan in line with IFC’s requirements. As set forth in the ESAP #9, Setrag will develop and implement a hazardous materials management plan and will implement the remedial action plan mentioned above.

While all wooden sleepers are now being replaced by new concrete ones, creosote has been used as a wood preservative for the existing sleepers, and in 2016 Setrag has conducted a study to assess creosote content in old sleepers in order to analyze disposal options. As part of the project, approximately 10,000 tons of contaminated sleepers will be replaced (by concrete sleepers) and disposed. As part of the options recommended by the study, incineration field testing was conducted and an action plan was developed in 2018, including engagement with the Ministry of Environment, identification of crushing equipment, development of safe transport and storage procedures, and identification of storage sites. However, latest incineration testing showed that emissions values  exceeded guidelines values for furans and dioxins due to low heating capacity. Other alternatives are to be explored during this new investment. As set forth in ESAP # 10, Setrag will conduct a feasibility study to explore other options to dispose of used creosote contaminated sleepers. The implemented methodology will be in line with good international industry practice.

During the first phase of the project, manganese storage was observed along the railway in Booué. The external E&S consultant responsible for project monitoring confirmed that adequate containment was in place and risks of contamination were negligible.

 Community Health and Safety

In Gabon, train safety is regulated by Train Safety Regulations ('Règlement général de sécurité'). Freight and passenger train safety is mainly linked to management of train movement, train driving, railway and train maintenance, and overall safety management systems. 'Hot Box' detection devices to detect wheel overheating are installed in three different locations along the railway. As highlighted in the ESRS for the first investment, level crossings where railway lines cross roads represent high risk accident locations for railways, and an important component of the capital expenditure program is focused at mitigating that risk. The review prior to the first investment found that many crossings did not have proper signage and barriers. During the first investment 3.2 km of safety walls and three pedestrian overpasses were built, and railway safety awareness raising programs were carried out in the first 15 km where population density is higher; six level crossing have been equipped with safety barrier and a manned control post. During this investment, it is planned to build another 25 km of safety walls, refurbish 28 level crossings in line with good international industry practice, and build at least 5 other pedestrian overpasses.

During the first phase of the project and as required under the relevant ESAP action item, Setrag conducted an audit of rail operational safety procedures and their implementation. One of the audit’s recommendations was the creation of the Railway Safety Department, which was established by the company in 2017. As stated above in 2018 and 2019, Setrag implemented a communication and awareness raising action plan and hired 79 outreach officers to cover 48 schools along the first 38 km from Owendo to PK 38. Pedestrian safety communication materials were also produced and used, including comic strips, posters in railway stations, TV ads on train safety, etc. As spelled out in ESAP #11, the communication and community safety awareness plan will be updated on an annual basis and implemented and will include clear objectives, methodology, resources, monitoring and evaluation, and a budget.

Infrastructure and Equipment Design and Safety

At the Owendo site, there is a Fire Safety team of 7 people. For all their facilities, Setrag has about 20% of staff trained in Fire Safety with about 300 staff trained each year. As required under the ESAP for the first investment, in 2018 a Fire Safety audit was conducted in all buildings accessible to the public (e.g. railway stations), including passenger trains. A corrective action plan was developed in line with the French fire safety standard. It includes corrective actions such as the following equip railway stations with fire resistant floors, smoke evacuators, adequate emergency lighting, sufficient number of extinguishers and fire hydrants. Some passenger trains are to have their emergency exits refurbished. As set forth in ESAP # 12, the Fire Safety corrective action plan will be implemented in the course of this project.

Security Personnel

Following a decree in 1978, a trained unarmed police unit (66 staff) was instituted in Gabon with the same attributions and powers as judiciary police. These agents are regularly trained in fire safety, self-defense, ethics, anti-poaching patrolling, etc. Security guards are also hired to protect Setrag premises in Owendo (60 staff), and throughout the railway corridor (40 staff). Moreover, armed regular police force can be directly involved at any of the sites.

As set forth in the ESAP #13, Setrag will conduct a security risk assessment and will develop and implement a security management plan. At a minimum, Setrag will review the contracts with the security providers and ensure that they include adequate provisions related to vetting of personnel, training, procedures in the event of any incident or alleged violation to ensure effective oversight and accountability for the security personnel. Setrag will develop a policy on the use of public and private security forces. It will also assess, document rules of engagement and security events, and propose management measures for risks arising from the project’s use of government security personnel deployed to provide security services.

At the time of the first investment, this performance standard was considered applicable because of the overlap of the existing project with critical habitat (as described under PS 1), rather than because of any incremental adverse impacts related to the proposed project. As discussed already, the project entails refurbishment of existing infrastructure within an existing impacted corridor, thus no new adverse impacts on biodiversity were anticipated with the implementation of basic management system procedures, no net loss of biodiversity was expected and the project was not expected to lead to measurable adverse impacts on those biodiversity values for which the critical habitat was designated, and/or on the ecological processes supporting those biodiversity values.

As discussed in the ESRS relevant to the first investment, Setrag drafted a Biodiversity Action Plan (BAP) as part of the project impact identification process in consultation with the Gabonese National Park Agency, the Ministry of Water and Forests responsible for anti-poaching patrolling, and WWF. This plan, disclosed with the relevant ESRS, incorporates management measures to minimize the impact of the railway on protected areas, in particular the Lope National Park. All mitigating measures of the BAP are being implemented. Moreover, since 2008, Setrag has in place an agreement with WWF and the Ministry of Waters and Forests to collaborate in anti-poaching patrols in the railway corridor; to undertake awareness raising of Setrag staff, train users, and local communities about wildlife species; and to carry out patrols of trains, workers’ camps, railway stations, and associated facilities. Bush meat (i.e. illegal venison) confiscated during those anti-poaching patrols is monitored and documented. In 2016 and 2018 the agreement was signed with the National Park Agency. In addition to the actions listed earlier, the collaboration focuses also on developing procedures in case of train collisions with wildlife, providing accommodations to National Park wardens to facilitate their work, and providing a train to develop nature tourism. Potential net gains of biodiversity values will be delivered through these joint efforts. In the course of this project, the action plan for collaborating with the National Park Agency will be updated and implemented. In parallel, it is planned to develop and implement agreements with other stakeholders to further control and mitigate illegal bush meat hunting and traffic of wildlife products (e.g. NGOs, other Gabonese authorities).

In line with Performance Standard 1 requirements, Setrag has developed a Stakeholder Engagement Plan (SEP) including the following elements: project description, legal framework, engagement principles, objectives and criteria, summary of previous engagement activities carried out during the environmental audit and resettlement processes, stakeholder identification, engagement program, timeline, documentation, resources and responsibilities, and description of grievance redress mechanisms. As stated above under PS 1, progress on resettlement is being monitored, and reports are drafted on a regular basis.  A specific data base on resettlement complaints was developed during the first phase of the project. This data base includes a complaint form, a numeric register georeferenced to the location of complainants, and a monitoring system to follow up on the responses. This system will be implemented to include all types of complaints, including those made around sexual harassment or gender based violence that might take place between members of the public using the railway, and employees of the railway including security guards. Safety awareness raising activities will be part of the SEP.

Latest consultations carried out in 2019 include the following: consultation with the new market committee to provide an update on the market start of construction; consultation with affected communities on track bed unstable zones to discuss the impacts and mitigating measures; consultation on impacts of the PK0-3 fencing on affected people and mitigating measures; and consultation with potentially affected people in Ntoum to discuss about the project, census, potential impacts and mitigating measures. Given the length of the corridor and the activities planned as part of the program, the company will increase the resources and their capacity to carry out all the stakeholder engagement activities required all along the railway corridor. Another senior social specialist will be hired to ensure its full implementation, and existing staff will receive adequate training.

Renato Torres
General Manager
P.O. Box 2198
Libreville, Gabon
Tel: 241-01-70-80-04
Fax: 241-01-70-01-06