While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS 5 - Land Acquisition and Involuntary Resettlement
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources

This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures and good international industry practices (GIIP).

Key E&S issue and risks associated with the project include: i) adequacy of the sponsor's management and monitoring systems to assess and manage E&S risks and impacts from project construction and operations, covering direct workers, contractors and sub-contractors; ii) consistent management of labor and working conditions and occupational health and safety (OHS) policies and practices for employees and contractors, as well as the solar supply chain; iii) pollution prevention and management of waste; iv) community health and safety (including harassment and gender-based violence and harassment (GBVH)) due to labor influx, construction traffic and presence of security forces; v) potential residual vulnerabilities resulting from land acquisition (led by third parties) and economic displacement limited to the land affected by associated facilities, since the land for the site was acquired before IFC involvement; vi) biodiversity impacts associated with a small parcel of Natural Habitat, and; vii) the sponsor's stakeholder engagement activities and grievance mechanism.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

PS1-Assessment and Management of Environmental and Social Risks and Impacts

Axian Energy have developed a Corporate Environmental and Social Management System (ESMS), including an HSES Policy, definition of roles and responsibilities at corporate and asset levels, due diligence and risk management procedures, and a set of management plans, procedures (community health and safety, biodiversity, land acquisition, contractors, stakeholder engagement, grievances etc.) and tools. Monitoring and reporting processes are also well defined. The ESMS provides an adequate overarching framework to manage multiple assets. An ESMS for each SPV is currently under development by the sponsors and will be finalized and implemented prior to project early works (ESAP #1).

In September 2021, GY, the previous project sponsor, commissioned international consultancies to develop ESIAs aligned with the Performance Standards, including high-level Stakeholder Engagement Plans (SEP), for each project site (including associated facilities). The four ESIAs, issued in September 2022, were submitted to the Agence Beninoise pour l’Environnement (ABE) under the national permitting process and Certificates of Environmental and Social Conformity were granted in July 2024.

The EPC contractor’s Group-level management system applies the principles of the ISO 14001 Environmental management systems and 45001 Occupational H&S standards, amongst others, and has achieved certification to these standards for its African subsidiaries. The EPC contractor has experience developing solar projects financed by international finance institutions in Africa. The sponsors will ensure that the EPC contractor implements the ESMPs developed alongside the ESIAs and develops and implements construction environmental and social management and monitoring plans (CESMMP) for each project site. The CESMMPs will define responsibilities of all relevant parties and persons and will include thematic E&S management plans (see ESAP #2). They will include biodiversity measures (as specified below in the PS6 section). The sponsors shall ensure that the O&M contractor updates the relevant ESMMPs for the operation phase.

Adequate E&S clauses, covering labor standards, work conditions, OHS and environmental protection, are integrated in the EPC contract template and will be included in the final EPC contract (ESAP #3). Similar clauses will be included in the O&M contract.

As per Axian Energy’s Corporate ESMS, the Impact and Sustainability Manager holds overall responsibility for corporate strategy and the development and implementation of the subsidiary’s ESMS, while the subsidiary’s in-country HSES Manager is the management representative for the ESMS, and has defined roles, responsibilities and authority for ensuring that Axian Energy’s ESMS requirements are established, implemented, updated and maintained; and that E&S performance is reported to top management for review. The project will establish and maintain an organizational structure that defines roles and responsibilities to implement the ESMS and will hire suitably qualified professionals, including an EHS Supervisor and a Community Liaison Officer for each site (ESAP #4). The sponsors shall also require that the EPC contractor develops an organizational structure demonstrating adequate environment, health, safety and security (EHSS) capacity and a dedicated EHSS manager for each site (as per provisions in the draft EPC contract).

Axian Energy has a high-level Emergency Preparedness and Response Procedure (EPRP) and associated procedures (e.g. hydrocarbon spill intervention procedure) that provides a framework and outlines the requirements for the development of project-specific EPRPs. A project level Emergency Intervention procedure has been developed, but a comprehensive EPRP has not yet been developed for the project. The project shall require that the EPC contractor develops site-specific EPRPs prior to commencing construction works, including measures related to spill response, and will require they are properly implemented and disseminated to relevant parties (including workers and local fire department), as appropriate (ESAP #5). These will be updated as necessary for the operation phase.

PS2-Labor and working conditions

The project will hire approximately 240 temporary workers at construction peak and approximately 36 permanent positions in operations, distributed between the four sites. According to the Concession Agreement, at least 80% of workers during construction shall be Beninese. Most of the workers will be hired by EPC contractors. The draft EPC contract stipulates that the contractor will engage workers from the villages surrounding the project to the extent possible. Given that all plants are located close to towns, it is planned that non-local workers (expected to be about 20-30% of the workforce) will be accommodated in the towns. Workers’ accommodation will be monitored according to the Accommodation Management Plan to ensure safe and healthy conditions.

Axian Group has provided its corporate HR and HSES policies that overall appear to be aligned with best industry practices. The HR policies specifically mention commitment to a healthy and safe workplace, freedom of association and organization for workers, prohibition of the use of child and forced labor, non-discrimination and equal opportunities, prohibition of sexual harassment and retaliation. Axian Energy has an OHS Management Plan applicable to all its collaborators, including sub-contractors, that provides a framework for the development of project-specific OHS Plans. Axian Energy also has a Third Party Management Policy, a Contractor Management Plan and Contractor HSES Requirements that define key labor, OHS, and environmental requirements.

ESAP #1 and 2 require that the sponsors and the EPC contractor develop and implement an ESMS and ESMPs, respectively, including project-specific Employment Management Plans comprising a Local Hiring Plan, Worker Accommodation Plans and a Workers’ Grievance Mechanism, as well as an OHS Plan and a Contractor Management Plan. Axian Energy shall extend its own grievance mechanism to contracted workers as needed (ESAP #9). The Human Resources Policy shall be accompanied by appropriate procedures and monitoring measures to verify the application of its commitments and the implementation of a code of conduct to respect local communities and prevent GBVH and violence against children (ESAP #8).

At the corporate level, Axian Group has a Supplier Code of Conduct (2021) mentioning the key requirements it expects from its suppliers (including human rights, labor rights, health and safety as well as environmental requirements). Axian Energy also has solar supply chain guidelines that outline requirements for risk and compliance assessments. Solar modules will be sourced by the EPC contractor; specific clauses are included in the template EPC contract that address forced labor. The EPC contractor has an Ethical Charter for a Responsible Supply Chain that prohibits forced labor and has a dedicated team that conducts on-site audits of suppliers and contractors to verify application of the Charter. Axian Energy will establish a supply chain management system to identify, manage and remediate supply chain risks associated with the solar supply chain as per PS2, and establish a team of supply chain specialists to perform assessment and management of suppliers and the EPC contractor (ESAP#10).

General health and safety requirements are included in the draft EPC contract, as are references to the Contractor’s Health and Safety (H&S) Management Plan and H&S training plan, to be drafted by the EPC contractor in cooperation with the sponsors. The EPC contractor’s African subsidiaries have QHSE officers and offer certified H&S training to employees.

PS3-Resource Efficiency and Pollution Prevention

Greenhouse gas emissions from the project during construction are expected to be minimal and predominantly associated with the use of fuels such as for generators, transport, on-site equipment, and machinery. The project is expected to generate approximately 35.6 gigawatt hours (GWh) of electricity per year, resulting in a predicted 90% reduction in greenhouse gas emissions compared to fossil fuel sources.

The main water requirement during construction is likely to be water for dust suppression, with some minor domestic use. For the operation phase, water will primarily be required for panel cleaning. In order to minimize the volumes of water used, dry cleaning of panels via brushes will be implemented. Water needs are estimated at a maximum monthly consumption of 200 m3 per site (four cleanings per month). At this stage of the project, several options are possible to cover the water needs: supply by truck, connection to the nearest SONEB (national water utility) network, or installation of on-site boreholes.

The project ESIAs indicate that Water Management Plans need to be developed for each project site. The ESMPs developed as part of the ESIAs include water management measures. As per ESAP #11, the sponsor will i) assess community water availability impacts as part of the hydrological study to be conducted for each site, and ii) develop and implement site-specific Water Management Plans, based on ESIA baseline findings, for the construction and operation phases which will cover water sourcing, measures for efficient water use/water minimization as part of the cleaning needs for panels and for general use, stormwater drainage, as well as monitoring procedures.
During construction, a minor amount of pollution to air, water and soil, and increased noise levels is anticipated; these impacts can be mitigated through standard pollution prevention and control measures that will be outlined in the respective ESMMPs (see ESAP #2). During the operation phase, no environmental pollution impacts are anticipated except for wastewater, primarily derived from panel cleaning, and domestic waste generation. Sanitary wastewater will be collected in septic tanks and transported by a licensed contractor to the nearest municipal treatment plant. The sponsors will implement pollution prevention measures in accordance with national law, IFC’s PSs, and project ESIA and ESMP provisions.

The overall volumes of both solid and hazardous waste generated by the project are expected to be low. The project will produce both non-hazardous wastes, such as paper, wood, plastic, scrap metals and glass, and a limited quantity of potentially hazardous materials such as oils, paints, batteries, etc., as well as some electronic waste.
The ESIAs indicate that project-specific Waste Management Plans need to be developed for the construction and operation phases. As per ESAP #12, the sponsors and its EPC and O&M contractors will develop and implement site-specific Waste Management Plans for the project aligned with local legal requirements, IFC PS and WBG EHS General Guidelines. The Waste Management Plan (for solid, liquid and hazardous waste) will commit to application of the waste mitigation hierarchy and will outline processes for appropriate waste storage, segregation, tracking, transportation, and disposal / treatment. The Plan will also include specifics for management of broken, expired, or surplus PV panels and provide details on hazardous waste disposal solution(s) in line with good international industry practices. Provisions will be included to fully track waste from source to final destination and for selecting third parties hired for waste transport and disposal. An assessment of the suitability of each licensed disposal facility will be undertaken prior to use to verify project waste is disposed / treated in such a manner that it is safe for human health and the environment.

PS4-Community Health, Safety and Security

The ESIAs identify the following impacts related to community health and safety and propose mitigation measures: dust, noise and vibration, waste, diseases (STIs, HIV, respiratory diseases) associated with worker influx, increased sociocultural conflicts / criminality and accidents due to increased traffic or construction works. Worker's influx is expected to be limited and minimized by local hiring (expected at about 70% of total workforce) and accommodation of non-local workers in nearby towns (> 10,000 inhabitants); however, risks related to interactions between non-local workers and communities (conflicts, harassment and GBV) will be considered. The transport of construction equipment and material for the construction of the plants will generate a minor increase in traffic between Cotonou and the project sites (approx. 90 trucks over a 3-4 month period). This movement of large trucks on existing roads may increase the risk of accidents, as well as respiratory diseases due to dust and gas emissions. Access roads to be built for the project are short (200m and 400m for Parakou and Djougou, respectively; only minor access ramps at Bohicon and Natitingou) and do not pass through communities, thus associated impact will be limited. The sponsors shall ensure bypasses and access tracks will be built for the communities of Bohicon and Parakou prior to restricting access to sites (fencing) as per ESAP #13. During the operation phase, road traffic to/from the plants will be limited and will have little impact.

Community health and safety impacts will be addressed in the Traffic Management Plan and the Community Health and Safety Plan to be developed, which shall include measures against pollution, spread of communicable diseases, harassment and GBV, emergency response, awareness raising campaigns for workers and with local communities and a health and safety plan for workers (see ESAP #2). A Code of Conduct will be disseminated among the workforce and enforced. Employment of people from local communities will also be prioritized, where possible (see PS2 section above).

The sites will be fenced, with video surveillance cameras positioned around the perimeter, and a private security sub-contractor will be engaged to provide security services on-site. Axian Group has a corporate Security Framework that refers to alignment with the IFC’s “Good Practice Handbook on Use of Security Forces” and requirements to train security personnel on human rights and analyze and report on grievances from local communities. The project shall prepare and implement a Security Management Plan in collaboration with the EPC and O&M contractors and regularly update it. The Security Management Plan will cover the hiring, equipping, and training needs of security personnel, including: i) vetting of security guards; ii) description of responsibilities of security guards such as controlling access and verification of people entering the site; iii) rules of engagement/use of force; iv) interactions with the project workforce and with the surrounding community (including rules against harassment, gender-based violence and consideration of local sensitivities); vi) duties in case of an emergency at the site; vii) training needs; and viii) regular reporting to project management in case of incidents or grievances received from the surrounding community (ESAP #14). The Plan shall be aligned with IFC’s Good Practice Handbook.

PS5-Land Acquisition and Involuntary Resettlement

The project sites were made available through the economic displacement of 364 PAPs in the four localities. MCA-Benin II was responsible for the expropriation procedures and the release of right-of-way starting from 2015. An international consulting firm developed and implemented a specific RAP aligned to PS5 requirements for each locality in 2017, including compensation and livelihood restoration measures. Livelihood restoration measures and the RAP process were discussed during stakeholder engagement activities in 2018/2019 including through the organization of dedicated focus group meetings with women and the establishment of Local Mediation Committees. A dedicated grievance mechanism was put in place including a channel dedicated to gender issues.

The previous project sponsor, GY, was not involved in the planning and implementation of the displacement, but commissioned a field-based gap analysis for each of the four RAPs against PS5 and lenders’ comments. The gap analyses did not highlight any major gap and confirmed that the RAPs were of good quality.
Based on the report from the IESC site visit in 2022, compensation for the four sites was completed by the end of 2020 (prior to IFC’s involvement in the project), and livelihood restoration and capacity building activities were conducted between 2020 to early 2022, complaints were addressed (+1400) and relations between communities and MCA/consultants are reportedly very good. A post-resettlement report was produced by the consultant in June 2022. Almost 100% of PAPs reported in surveys that they were satisfied with the RAP process (including compensation amounts).

Additional land acquisition was carried out in 2023 (after the IFC mandate) for the access roads and transmission lines in Bohicon and Parakou as well as the transmission lines for the sites in Djougou and Natitingou (land for the Djougou access road was acquired during the earlier acquisition process). During the IESC site visit in December 2024, PAPs reported that all relevant compensations had been paid. No livelihood restoration plan has been implemented for these additional acquisitions. The sponsors are required to obtain an official confirmation from the Government of the completion of the compensation payments and grievance closure (ESAP #15).
As per the Concession Agreement, the Government is responsible for any residual impacts and gaps in the RAP process (including addressing any outstanding grievances) since the end of MCA-Benin II in June 2023. The sponsors have committed to cover potential residual vulnerabilities related to the land acquisition for the associated and ancillary facilities if and as identified by external monitoring/supervision or PAPs grievances in order to align the outcomes with the IFC PS5 requirements (ESAP #15).

PS6-Biodiversity Conservation and Sustainable Management of Living Natural Resources

None of the four project sites nor associated facilities overlap any known protected or internationally recognized areas. The project ESIAs include PS6-aligned biodiversity assessments of each site (including associated facilities). Three sites are modified habitat in peri-urban or rural areas and do not trigger PS6. The fourth site, Bohicon, covers a 50 ha area and overlaps the Guinean forest-savanna ecoregion. It comprises modified habitat with a parcel of less than 5 ha of residual natural habitat, adjacent to a temporary pond. The Bohicon site is located on cultivated and fallow agricultural fields and cashew and palm plantations in a peri-urban area. Expected project impacts include habitat transformation. As part of ESAP#2, the project will update, and implement, its ESMP to include measures for avoidance (e.g., conserving and fencing/cordoning off the area of natural habitat, using wildlife-friendly fencing where relevant, installing signs), minimization, and rehabilitation (e.g., removal of any invasive species; maintenance of natural vegetation under the panels and any other areas under client control) to facilitate No Net Loss where feasible. No significant residual impacts are expected.

Stakeholder engagement activities to date have been performed by MCA consultants as part of the ESIA process and RAP: about 15 meetings with communities and local authorities were held during the ESIA development and about 20 additional meetings during the RAP preparation in each locality, including focus groups with women, youth and, where present, local NGOs.

While the ESIAs were submitted to ABE in 2023, no official public hearings to present the ESIAs and receive feedback were conducted (nor required by national legislation). The due diligence visits highlighted the insufficient information provided about the nature of the project, its sponsor and its potential impacts. Additional stakeholder engagement shall occur before the start of early works (ESAP #6).

Community requests regarding local intangible cultural heritage were addressed in consultation with the relevant communities in April 2025.

Axian Energy developed a framework Stakeholder Engagement Procedure at corporate level that sets adequate principles and standard procedures. A high-level SEP has been developed for each site within the ESIAs that should be updated as needed before construction (ESAP #6). The SEP will also detail how the project will maintain ongoing reporting to affected communities.

Axian Energy has a corporate external grievance procedure that sets adequate principles and standard procedures. According to ESAP #7 the sponsors shall adopt, implement and maintain a project-specific external grievance mechanism. The mechanism shall be disseminated to external and internal stakeholders, such as the EPC contractor and subcontractors. The mechanism will have a dedicated channel for gender-related complaints and allow for anonymous complaints. The sponsors will provide adequate resources to implement the mechanism (as per ESAP #3) and include complaint logs and results in the annual monitoring report (AMR).

Axian Group publishes a yearly corporate impact report that outlines CSR principles and actions and presents the next year's roadmap. The IESC visit and past consultations have revealed high expectations in terms of local benefits amongst local stakeholders. The client will develop and implement a Community Development Plan (CDP), as required by the Concession Agreement with the Government.

Contact Person: Roukayath SOROGUI
Company Name: Sika Capital
Address: Ilot 646-A, Quartier Gbégamey Centre / 04 BP 0763 Cotonou, Bénin
Email: benin.ipp50@axian-group.com ; sikaipp50@egnonconsulting.com
Phone: +229 01 69 42 54 54

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	Each Project company shall develop and implement an Environmental and Social Management System (ESMS), building on the existing corporate ESMS and considering feedback provided by the IESC and lenders, and in line with IFC Performance Standards (PS). The ESMS will incorporate the following elements: (i) EHS and OHS policies;(ii) Hazard identification and management procedure and a detailed risk assessment;(iii) management plans and procedures, including a Contractor Management Plan describing how the Sponsors screen, monitor, supervise and audit its contractor(s), as well as the EHSS standards for compliance and the list of plans and procedures to be developed/applied by contractor(s) ;(iv) HSE training program for all workers;(v) emergency preparedness and response;(vi) stakeholder engagement;(vii) monitoring and review procedures, to include regular inspections and audits, EHSS parameter tracking, evaluation of management program effectiveness, and monitoring and reporting on general E&S performance.EHS policies will be posted at all sites and communicated to staff, contractors and service providers during worker induction sessions.The Sponsors shall develop and implement a Code of Conduct to ensure management and workers respect local communities, prevent gender-based violence and harassment (GBVH) and violence against children on-site and in communities, and protect the environment. The Code will describe disciplinary measures to be applied if breaches occur.	09/30/2027
2	The Sponsor shall ensure that the EPC contractor implements the existing ESMPs (associated with the ESIAs) and develops and implements construction environmental and social management and monitoring plans (ESMMPs) for each Project site. The ESMMPs will define responsibilities of all relevant parties and persons, including the EPC contractor. The overall ESMMP shall cover but shall not be limited to the following plans, as per IFC PS:- Community Health and Safety Plan, including prevention of STDs and GBVH- Employment Management Plan, to include a Local Hiring Plan (including plans to recruit and retain local women) and Local Procurement Plan, - Workers’ Accommodation Plan - Workers’ Transportation Plan- Training plan- Occupational health and safety (OHS) plan (including heat stress management)- Traffic management plan- Hazardous materials management procedure- Dust, noise and air quality management procedure- Chance find procedure- Incidents and non-conformance management procedure- Reporting procedures and documents to track E&S issues related to the Project and relevant parties E&S performanceSponsor’s Biodiversity mitigation program: The loss of biodiversity (deforestation) related to the t-lines and access roads shall be addressed by the Sponsor through such a programme (applicable to Natitingou, Djougou and Parakou). For the Bohicon site ESMMP, biodiversity measures for avoidance, minimization, and rehabilitation of Natural Habitat to facilitate No Net Loss, where feasible, will be included. The Sponsor shall specifically fence/cordon off the small area of natural habitat in the southwest corner of the site.The Sponsor shall ensure that the O&M contractor updates the relevant ESMMPs for the operations phase (Community H&S, Employment, OHS, Incidents, Reporting, Biodiversity, Security, Stakeholder Management Plans).	09/30/2027
3	The Sponsor shall define key environmental, health, safety and social (EHSS) requirements in the EPC contract in line with the Project ESMMP. All EHS provisions in the existing template will be included in the final EPC Contract. The Sponsor will ensure regular reporting on EHS, including occupational health and safety statistics, by EPC contractors during the duration of the construction phase.The Sponsor shall also define key environmental, health, safety and social (EHSS) requirements in the O&M contract.	12/01/2026
4	Each Project company will establish and maintain an organizational structure that defines roles and responsibilities to implement the ESMS during construction and operation phases.At least, the Sponsor shall hire, onboard and maintain the following suitably qualified professionals for each site on a full-time basis:(i) Environmental, Health and Safety Supervisor (one across Natitingou and Djougou; one at each of Bohicon and Parakou);(ii) Community Liaison Officer.The Sponsor shall ensure key environmental, health, safety and social (EHSS) management roles are filled within the EPC contractor organization for each site. The Sponsor will ensure:(i) EPC contractor provides a dedicated EHSS manager;(ii) EPC contractor develops an organogram demonstrating adequate EHSS capacity including social.	10/31/2025
5	The Sponsor will ensure that the EPC contractor develops site-specific Emergency Response Procedures prior to commencing construction works, including measures related to spill response, and will ensure they are properly implemented and disseminated to relevant parties (including workers and local fire department), as appropriate. These will be updated as necessary for the operation phase.	06/30/2027
6	The Sponsor will conduct additional stakeholder engagement to present the ESIAs and collect comments at each Project site before the start of the construction works, as per IFC‘s Consultation process. The ESMMP will take into consideration stakeholders’ comments.The Sponsor will update as necessary and implement the ESIA Stakeholder Engagement Plan (SEP) for each site in compliance with the IFC PS and in line with “Stakeholder Engagement: A good practice Handbook for Companies doing Business in Emerging Markets”. The SEP will map specific stakeholders and vulnerable people, outline topics to be addressed/communicated, include a gender-sensitive engagement approach, and provide an engagement schedule. The Sponsor will hire additional resources such as specialized NGOs to conduct training and awareness-raising as needed.	09/30/2026
7	The Sponsor shall revise the draft Parakou Grievance Management Procedure and develop the procedures for the three other sites to:a) Include the whistleblowing mechanism for handling more sensitive grievances;b) Specify how the procedure will be communicated to stakeholders;c) Specify means and tools for implementation of the procedure for GBVH- related grievances. The Sponsor shall develop a referral mechanism for potential survivors of GBVH.The Grievance Mechanism (GM) shall be broadly disseminated to internal and external stakeholders, including the EPC and its subcontractors, ensuring that communities are aware of the change in contacts and scope.	09/30/2026
8	The Sponsor shall provide evidence that Human Resources (HR) policies, procedures and contractual commitments are implemented with respect to PS2 requirements for contracted workers including local hiring, migrant workers, notably as it relates to decent salary, OHS management, and access to a workers’ grievance mechanism. The Sponsor will ensure that the HR policy and procedures are accessible and clearly communicated to all workers, including daily workers (in French and local languages as necessary), to ensure that employees understand their rights under national labor and employment law.Appropriate monitoring, including regular, random labor and worker accommodation audits, should be conducted, to verify application of commitments.	06/30/2026
9	The Sponsor will design and implement a grievance mechanism accessible to all workers, regardless of their contract type, to ensure that a formal grievance process is followed. The mechanism shall include: i) procedures for documenting, managing, and monitoring the resolution of grievances; ii) involvement of appropriate levels of management (including designated staff and accountability); iii) clear and timely management of grievances; iv) allowing for anonymous complaints to be raised and without fear of retribution; v) appropriate expertise to manage GBVH related complaints; and vi) informing access to other judicial and regulatory mechanisms available under the Benin law for workers.	03/31/2026
10	The Sponsor will establish a supply chain management system to identify, manage and remediate supply chain risks associated with the solar supply chain as per PS2 and a team of supply chain specialists to perform assessment and management of suppliers and the EPC contractor.The management system will include:a) Responsible Sourcing Policy to only purchase from tier 1 suppliers that can provide traceable panels up to polysilicon level, b) a mapping and risk assessment of solar PV module suppliers before onboarding and during life of the business relationship, c) supply chain team structure, d) traceability up to polysilicon level, e) inclusion of appropriate clauses in procurement notices and contracts with EPC contractors or suppliers on labor risks and management thereof and f) enhanced representation on solar PV module suppliers or EPC regarding labor practices and audit rights up to polysilicon level suppliers.	10/31/2025
11	As part of the hydrological study to be conducted to confirm the quantity of groundwater and water flow necessary for each site, community water availability impacts will also be assessed.The Sponsor will ensure that the EPC contractor develops and implements site-specific Water Management Plans for construction and operation phases, covering: water sourcing; measures for efficient use/water minimization as part of the cleaning needs for panels and for general use; stormwater drainage; monitoring procedures.	09/30/2027
12	The Sponsor will ensure that the EPC contractor develops and implements site-specific Waste Management Plans for the Project aligned with local legal requirements, IFC PS and WBG EHS General Guidelines. The Waste Management Plans will commit to application of the waste mitigation hierarchy and will outline processes for appropriate waste storage, segregation, tracking, transportation, and disposal / treatment. The Plan will also include specifics for management of broken, expired, or surplus PV panels and provide details on hazardous waste disposal solution(s) in line with good international industry practices. Provisions will be included to fully track waste from source to final destination and for selecting third parties hired for waste transport and disposal. An assessment of the suitability of each licensed disposal facility will be undertaken prior to use to ensure Project waste is disposed / treated in such a manner that it is safe for human health and the environment.	09/30/2027
13	The Sponsor shall ensure the bypasses and access tracks will be built for the communities of Bohicon and Parakou prior to restricting access to sites (fencing).	01/31/2026
14	The Sponsor shall develop and implement a Security Management Plan (SMP) in collaboration with the EPC and O&M contractors and regularly update it.The Security Management Plan will cover the hiring, equipping, and training needs of security personnel, including: i) a security due diligence questionnaire for security provider selection checking guards’ training, vetting practices for guard selection, guard working conditions, etc.; ii) description of responsibilities of guards such as controlling access and verification of people entering the site; iii) rules of engagement/use of force; iv) interactions with the Project workforce ) and with the surrounding community (including rules against gender-based violence and harassment and consideration of local sensitivities); v) duties in case of an emergency at the site; vi) training needs; and vii) regular reporting to Project management in case of incidents or grievances received from the surrounding community. The Plan will be aligned with the IFC’s “Good practice handbook on use of security forces”.	06/30/2026
15	The Sponsor shall confirm that all associated and ancillary facility PAPs identified through the RAP addendum (covering the Bohicon and Parakou access roads and transmission lines as well as the Djougou and Natitingou transmission lines) have fully received their compensation payments.The Sponsor shall also address potential residual vulnerabilities resulting from land acquisition - as identified by Project ES monitoring and/or grievances - through a RAP/LRP corrective action plan (or equivalent document acceptable to lenders) including specific support measures for vulnerable PAPs, in case these are not addressed by the Government.	12/01/2026