Based on IFC’s review, PS7: Indigenous People is not relevant as there are no indigenous peoples in the project area. PS8: Cultural Heritage is also not relevant as the project is not located in an area of known historical or cultural significance and does not impact any known cultural heritage                                                  

This is a Category B project according to IFC’s Policy on E&S Sustainability as the impacts associated with the project are limited and site specific. No physical or economic displacement associated with any land acquisition required for the future concession area is expected. Risks and impacts associated with airport operations and with any construction activities can be addressed through the implementation of good international industry practices (GIIP).

Key E&S issues reviewed at appraisal included the E&S management system (ESMS), labor and working conditions, resource use and efficiency, waste management, legacy sub-surface contamination, health and safety of surrounding communities, including noise impacts from ground and aircraft operations, and airport operation safety, emergency response, life and fire safety, land acquisition, and biodiversity management.

ASA currently has in place a certified Quality Management System based on ISO 9001:2015, an Occupational Health and Safety (OHS) Management System based on ISO 45001:2018 and is developing an ESMS based on ISO 14001 at its international airports. As part of the process to integrate the airports into VINCI systems, CVA will develop an ESMS aligned with VINCI policies and procedures, IFC’s Performance Standards (IFC PSs) and the requirements of the CA. (ESAP # 1). The core elements of the ESMS are set out below.

Policy: VINCI has a well-established E&S policy framework publicly available on their website - https://www.vinci.com/vinci.nsf/en/item/sustainability.htm. This includes an environmental policy called AIRPACT, which sets out a set of time-bound targets and defines E&S performance improvements for all airports operated by VINCI. CVA will establish an overarching E&S policy defining the objectives and principles in line with the VINCI E&S policy framework including AIRPACT and consistent with the requirements of the IFC PSs. (ESAP # 2).

Identification of Risks and Impacts:  As the investment plan consists of two phases, each with multiple works’ components, to be implemented at seven airports over several years, CVA will develop and implement an E&S Screening and Assessment Procedure and undertake E&S assessments in accordance with Cabo Verdean regulatory and IFC PS requirements. (ESAP # 3). Depending on the works, this may comprise a limited or focused environmental and social assessment, or straightforward application of environmental siting, pollution standards, design criteria, or construction standards.

Management Programs: For the planned construction works, the Concessionaire shall require the EPC Contractor/s to develop and implement a Construction Environmental Plan/s (CEMP) and associated sub-plans, guided by the risk and impact assessments undertaken and aligned to the IFC PSs and relevant WBG EHS Guidelines. (ESAP # 4). For the operations phase, CVA will develop specific management plans and procedures for a range of E&S topics (as per VINCI policy requirements and as outlined in this ESRS); these will be operationalized via site level plans and procedures.

Organizational Capacity: ASA currently has an EHS coordinator based out of BVC and safety officials at all the international airports. This team covers all seven airports in the ASA portfolio. Going forward, based on an assessment of the existing organizational capacity against project’s E&S commitments, CVA will update the E&S organizational structure as needed. At a minimum, this will include the recruitment of a qualified E&S manager. (ESAP # 5).

Emergency Preparedness and Response: Each airport and aerodrome has an internal Emergency Preparedness and Response Plan (EPRP) and is equipped with firefighting and rescue services to respond to such airside accidents. Going forward, CVA will review and update all the EPRPs to align with the VINCI requirements, provisions of relevant IFC PSs and relevant WBG EHS Guidelines. As part of this review, the CVA will liaise with local emergency service to assess their capacity and resources. (ESAP # 6).

Monitoring and Review: CVA will develop an operations E&S monitoring plan to demonstrate compliance with VINCI commitments, IFC PSs, relevant WBG EHS Guidelines, as well as national environmental standards. (ESAP # 7).                                                  

At the time of appraisal ASA had a total number of 492 direct employees (29% women) across all seven airports, of which 91% were permanent. In addition, up to another 100 staff were employed by third party contractors for security, cleaning, maintenance, etc. ASA has a dedicated Human Resources (HR) department led by a HR manager. As per the CA, all ASA employees assigned to carry out activities at the airports, excluding air navigation who will remain at ASA, will be transferred to CVA.

Human Resources Policies and Procedures and Working Conditions and Terms of Employment: ASA has a HR Policy, which has provisions on recruitment, renumeration and benefits, training, career development, and working conditions and terms of employment as regulated by the Cabo Verde Labor Code. ASA also has a Code of Ethics that has provisions on equal opportunity and non-discrimination. The Policy and Code do not extend to workers employed by third parties and, whilst there are no explicit references to child and forced labor or freedom of association and collective bargaining, these requirements are made indirectly through reference to the Labor Code. Employees of ASA are free to join workers’ organizations, with three unions currently established at the workplace. ASA does not have a formal grievance redressal mechanism for its employees. Employees direct any grievances either to their supervisor or to the HR department.

VINCI has a Guide to Human Rights which together with associated procedures sets out the principles, commitments and guidelines in relation to labor, applicable across all operations and subsidiaries and for all employees, sub-contractors and business partners. Going forward, CVA will develop HR policies and procedures, in line with national laws, VINCI policies and procedures, and IFC PS2 requirements. These HR policies and procedures will be applicable to all workers including those employed by third parties, made readily accessible and clearly communicated at onboarding and through the provision of additional sensitization and training. (ESAP # 8). 

Occupational Health and Safety (OHS): ASA currently manages OHS aspects in line with Cabo Verdean legal requirements and in line with ISO 45001. VINCI has set a target of zero accidents. To achieve this, CVA will review and update the OHS Management System to align with Vinci policies and procedures and IFC PS 2 requirements. The update will include: i) an OHS Policy; ii) a procedure for health and safety risk assessments in relation to activities and tasks; iii) a risk register; iv) hazard controls and preventive protocols to manage health and safety risks; v) a work-related injury recording procedure, using the internal monitoring tool (BaSAFE) used by VINCI at corporate level; and vi) an OHS training programme for to all airport workers. (ESAP # 9).

Workers Engaged by Third Parties: VINCI has standard templates for contractor EHS, Quality and Labor requirements, which will form part of the EPC contract together with the Guide to Human Rights. CVA will put in place a contractor monitoring procedure to monitor the performance of contractors with national laws, project E&S requirements and PS2 provisions. (ESAP # 10).                                                  

Resource Use and Efficiency: Currently all the airports are supplied with electricity from the grid, with the use of backup generators. Water comes from public or municipal sources and is stored in above or underground tanks. As per of the CA, the Concessionaire has committed to several energy and water resource use and efficiency measures. Going forward, CVA will audit the water storage conditions and quality at all water storage facilities and based on the findings, develop and implement upgrade measures as required, in line with local regulations and relevant WBG EHS Guidelines (ESAP # 11).

GHG emissions: Based on data provided by ASA for 2019, direct and indirect (Scope 1 and Scope 2) GHG emissions associated with airport operations were estimated to be 4,160 tons of CO2 eq. The AIRPACT Policy commits to achieving Level 1 (Mapping) Carbon Accreditation under the Airports Council International (ACI) Carbon Accreditation scheme for all airport in VINCI’s portfolio within three years, followed by becoming carbon neutral by 2030, and net zero by the end of the concession period or by 2050 whichever comes earlier.

Pollution Prevention – Air Emissions: All the airports are in areas with no significant sources of air pollution. The main current air emission sources at the airports and aerodromes are emissions from aircraft operations during landing and take-off, ground support vehicles and diesel generators. Limited air emissions and associated impacts are expected from the construction phase of the project. If waste incinerators are installed at the international airports, these will also be a source of air pollution (see section on waste). Ambient air quality monitoring is not currently undertaken.

Pollution Prevention – Operational Noise: Aircraft landing and taking off are the main source of operational noise pollution. Each airport has a decree that establishes protection zones regulating land use. In relation to noise, the decrees refer to national standards (limit values) for ambient noise levels for mixed or sensitive land use zones. There are some settlements/ structures close to the perimeters of the international airports that may be exposed to noise impact from operations. As per the CA obligations, CVA will undertake noise contour modelling for each airport in line with GIIP. (ESAP # 12). Furthermore, in coordination with key stakeholders (such as the municipalities, Civil Aviation Authority, etc.), CVA will develop Noise Management Plans in line with national regulations and the WBG EHS Guidelines for Airports and, using as a guidance framework, the ICAO policy on airport noise management. The Noise Management Plan will clearly define roles and responsibilities and coordination mechanisms between CVA and other stakeholders and establish a protocol for periodical updates of the noise modelling. (ESAP # 13).

Pollution Prevention – Wastewater: All airports have septic tanks, the integrity and functioning of which is currently not known. SID, BVC and RAI have wastewater treatment plants (WWTP) with varying degrees of operability. In all cases treated wastewater is ultimately discharged to the soil without a permit or adequate monitoring. CVA shall undertake an audit of the structural integrity and functioning of all septic tanks and based on the findings undertake upgrade works as required, in line with relevant WBG EHS Guidelines. (ESAP # 14). As per the CA, under Phase 1-B, CVA will install new WWTPs at SID, BVC and VXE, upgrade the existing WWTP at RAI and install new septic tank systems at the remaining airports. The WWTPs and septic tanks will be designed and operated in line with national laws and relevant WBG EHS Guidelines. (ESAP # 15).  Industrial or surface water runoff from the paved areas at all airports (except RAI and BVC) are discharged into the environment without treatment. At RAI, surface water runoff is partially sent to the WWTP for treatment, whereas at BVC, the apron is equipped with an oil-water separator. CVA will also review and upgrade as required, the surface water drainage systems at all airports (including oil water separators at the aprons of international airports) in line with relevant WBG EHS Guidelines. (ESAP # 16).

Solid and Hazardous Waste Management: Whilst most airports and aerodromes have temporary waste storage facilities with closed waste containers, there is limited waste sorting, segregation and re-use, and waste is ultimately sent to external dump sites (some of which are uncontrolled). Waste registries are not maintained and currently there is no monitoring of quantities waste generated. Furthermore, at present none of the airports or aerodromes have developed a Waste Management Plan as required by Cabo Verdean legislation. CVA is planning to install waste treatment facilities at all airports (including compact waste incinerators at the four international airports) under Phase 1-B. Going forward and in line with IFC PS 3 requirements and relevant WBG EHS Guidelines, CVA will develop a Waste Management Plan (ESAP # 17).

CVA will also undertake: Asbestos Containing Material (ACM) surveys at all the airports in order to assess presence, quantities, conditions and associated risk; an inventory of all existing HVAC equipment containing coolant gases; an inventory of all existing equipment containing Polychlorinated Biphenyls; and based on the findings, develop a time-bound plan to manage the safe removal or replacement and treatment and/ or disposal of such hazardous waste in line with relevant WBG EHS Guidelines. (ESAP # 18).

Hazardous Material Management: Hazardous materials stored, handled and used at the airports are mainly fuel and lubricants. All the international airports have aircraft fuel storage facilities of various sizes. Aircraft fuel is either brought in by truck or via a pipeline (SID and RAI). Furthermore, all airports also have diesel storage tanks for the generators. The ESDD report notes that most diesel storage facilities have secondary containment with purge valves, none of which are covered. Furthermore, the storage and handling of such hazardous materials need to be improved and material registers and data sheets and spill kits need to be provided at all storage facilities. A Hazardous Materials Management Plan (HMMP) has not yet been developed. Going forward, CVA will develop and implement a HMMP and a Spill Response Plan in line with IFC PS 3 requirements and relevant WBG EHS Guidelines. (ESAP # 19). Furthermore, CVA will conduct structural integrity audits and inspections of all hazardous material handling and storage infrastructure, undertake upgrades as required to in line with relevant WBG EHS Guidelines and develop and implement a maintenance and inspection protocol. (ESAP # 20).  

Historical Pollution: VINCI commissioned a Phase II Environmental Site Assessment (ESA) in 2020 for the areas of potential contamination identified at the SID, RAI and VXE. Going forward, CVA will update this study, and prepare and implement a time-bound site remediation plan for these area in accordance with Cabo Verdean legal requirements and relevant WBG EHS Guidelines. (ESAP # 21).                                                  

Life and Fire Safety: A Life and Fire Safety (L&FS) audit of the airports has not yet been carried out. As a matter of priority, CVA will engage a specialized consultant, acceptable to IFC, to undertake a L&FS audit of the existing passenger terminals and other priority areas against Cabo Verdean regulations and relevant WBG EHS guidelines, with focus on L&FS systems that are critical from a Life Safety perspective (including fire detection and alarm, accessibility of exits & evacuation signalization; among others). Based on the audit findings, CVA, will develop and implement corrective Life and Fire Safety measures according to an agreed time-bound plan. (ESAP # 22).

Road Safety: Most of the operational traffic is related to buses taking tourists to and from the airport. The primary risk to community safety identified for the project construction works is associated with road traffic associated with the transport for construction materials, equipment and workers to and from the sites. These risks will be managed by EPC contractor under the CEMP as required under the ESAP # 1.

Security Personnel: Security at the airports is managed by a mix of directly employed security staff or by a security contractor. All security staff are unarmed.

Operational Noise: Aspects related to noise, which could have community health and safety risks and impacts, are covered under PS3 above.                                                  

All the islands fall within the Cabo Verde dry forests ecoregion. MMO is located less than 1 km to the Salinas de Porto Ingles Ramsar site; whilst the concession area of BVC overlaps the Lagoa do Rabil International Bird Area (IBA) by 1.7 ha. This IBA was designated after the construction of BVC. Based on a biodiversity screening undertaken for BVC and MMO in 2023, the Areas of Influence (AoI) for both airports are largely Modified Habitat. Both airports are within a broader area that qualifies as Critical Habitat due to presence of threatened and/or restricted range species. The development works at both airports will be in areas classified as modified habitats. No significant residual impacts are expected. Furthermore, no development works are planned on the 1.7 ha of the concession area at BVC that overlaps the IBA. Going forward, in consultation with the relevant national and international organizations, CVA will develop a Biodiversity Action Plan (BAP), including Biodiversity Monitoring and Evaluation Plan (BMEP) for both BVC and MMO in line with PS6 requirements and in consistency with the airports’ Wildlife Management Plans. (ESAP # 25).

Local regulations in Cabo Verde establish easements around the airports with restrictions on activities that could attract avifauna and increase collision risks and require an airport operator to develop and implement Wildlife Management Plans for all airports. To date only the international airports, have such plans in place. Going forward, in conjunction with the Civil Aviation Authority and municipalities, develop, and/ or update Wildlife Management Plans for all airports in line with national regulatory and relevant PS6 requirements. (ESAP # 26).

The works components for both phases and any future developments planned during the life of the concession will be screened for biodiversity and assessed in line with the procedure to be developed under ESAP #1.

Increased airport traffic has potential to increase risk of accidental introductions of invasive species to the islands. The project will assess risks of such introductions and establish suitable bio-control measures to reduce such risks, including sensitization of travellers to such risks. (ESAP # 27)                                                  

ASA currently does not have a formal process to identify, assess and engage with stakeholders such as communities affected by or living in the vicinity of the airports. Furthermore, whilst a customer comments/feedback mechanism is in place, it is not enabled to manage community grievances.  Going forward, CVA will develop and implement for all airports a Stakeholder Engagement Plan (SEP) and a Community Grievance Mechanism (CGM) in alignment with PS1 requirements and appoint a staff member to serve as a Community Liaison Officer (CLO) at each airport. (ESAP # 28).                                                  

Vinci Concessions

12-14 rue Louis Blériot

Rueil-Malmaison, 92500, France