This is a Category B project as per the IFC's Policy on Environment and Social Sustainability (2012).  The proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures.

Key E&S risks and impacts during the installation of solar equipment (construction) include, occupational health and safety (OHS) incidents, traffic management across communities along long haul routes from Durban to Selebi Phikwe, hazardous waste management, PV cells supply chain and community health and safety risks such as gender-based violence.          

Environmental and Social Management Systems: Scatec has a corporate ESMS that includes principles for business conduct, the procedures for identifying and managing environmental and social risks and impacts and the organizational requirements for operating the ESMS in accordance with IFC's Performance Standards and WBG EHS Guidelines. In addition, Scatec is ISO certified for its corporate ESMS (ISO 9001, ISO 14001 and ISO 45001).

As per the corporate ESMS, Scatec will develop a project specific ESMS to mitigate risks and impacts identified in the ESIA and in Scatec's internal risk assessment process. In addition, the project will develop and maintain a project legal register/permitting plan capturing all the required and potentially required permit/license requirements. The project ESMS will inherit corporate requirements and detail project specific actions needed for meeting the reference framework requirements, namely Scatec requirements, the IFC Performance Standards, WBG EHS Guidelines and national legislative requirements as per ESAP #1a.

Policy: Scatec has corporate policy statements demonstrating its commitment to E&S management, which include amongst others: i) sustainability policy, ii) code of conduct (CoC), iii) health, safety, security and environment (HSSE) policy, iv) human rights policy, v) human resources policy, vi) diversity and inclusion policy, and vii) a global labour policy for site personnel. Scatec will develop project level E&S policies reflecting the project's corporate policy commitments (ESAP #1a).

Identification of Risks and Impacts: The project ESIA was updated in 2023 to meet IFC Performance Standards requirements, specifically to include a transport impact assessment, a socio-economic baseline, further stakeholder engagement, specialist ecological studies, cumulative impacts, waste impact assessment, hydrogeological studies, contractor management framework plans and further archaeological investigation. Scatec will develop an environmental and social management program (ESMPr) for the project's construction and operation (ESAP #1b) phases in accordance with IFC Performance Standard requirements.

Management Programs: The corporate ESMS states that a set of E&S management plans required for the project must be identified as outcome of a risk assessment and an ESIA carried out for the project should be developed as part of the project ESMS. Scatec will integrate the Environmental and Social Management Plans using its programmatic approach (ESMPr) as part of the project ESMS (ESAP #1a) for construction and operations. In addition, the assessments include specific conditions for the development of implementation plans, and these include an alien invasive species management plan, traffic management plan, revegetation and habitat rehabilitation plan, stormwater and wastewater management plan, erosion management plan, pre-construction site clearance procedure and chance finds procedure (ESAP #1b).

Scatec’s ESMS (ESAP #1a) requires the development of a robust contractor management plan highlighting their obligations during construction. The ESMPr (ESAP #1b) reiterates that all references to the EPC contractor will include all sub-contractors responsible for any tasks in respect of the development.  All environmental and social management actions allocated to the EPC contractor in the ESMPr will apply equally to all sub-contractors responsible for any specific task. This will involve the inclusion of ESMPr and other specific HSSE requirements in tender documents and legal contracts, undertaking regular monitoring and reporting of contractor performance (see Monitoring & Review section below), and trainings to improve E&S performance for low capacitor subcontractors.

Monitoring and Review: The Scatec corporate ESMS requires regular monitoring of project activities and E&S management plans. The inspections are to be carried out by assigned and trained employees and cover the broad area of influence of all construction related activities. The corporate ESMS also requires internal auditing of projects by the Scatec corporate HSSE team and HR team and external auditing by third parties. These requirements will be reflected at the project level ESMS (ESAP #1a).

Organizational Capacity and Competency: Scatec has developed a project management organogram that flows from SPV to EPC levels during construction for, providing adequate E&S resources. At the project anagement (SPV) level, these include i) Environmental and Social Manager, ii) Environmental and Social (E&S) agent, iii) health, security, and safety advisor, and iv) Community Liaison Officer (CLO). At the site level, the EPC resources include i) health, security, and safety manager, ii) HR administrator. The E&S agent and CLO positions from the SPV are equally site based. The EPC will appoint HSSE Officers (ESAP #1c) during construction. Scatec will appoint a permanent HSE officer and a CLO for operations (ESAP #1c).

Emergency Preparedness and Response: The Scatec corporate ESMS requires emergency response plans are developed for each of its projects and should include a review of potential incidents that may impact the environment and/or the surrounding communities in link to a project's development, construction and/or operations. Emergency response plans will be developed per ESAP #1b. 

Supply Chain: Scatec's Code of Conduct encompasses responsible sourcing provisions, mandating that suppliers ensure the absence of forced labor in their supply chains. Contractually Scatec includes specific language around Business Conduct Principles, Forced Labor and Traceability Compliance in both main agreements, supply contracts and sub-contractor obligations. Scatec's business partners will comply with the Code of Conduct which also extend to the project. The Code of Conduct specifically prohibits sourcing from certain PV material-producing regions.

Scatec also conducts Integrity Due Diligence (IDDs) assessments on all Suppliers pre-contract, with Scatec’s compliance team also screening the Subcontractors in the BOM proposed for the production of the PV Modules used in a specific project. This is a multi level approach, progressing from internal due diligence and industry best practice tool to externally contracted enhanced due diligence. Scatec has various policies and statements relating to Human Rights and Transparent Supply Chains which can be accessed at https://scatec.com/sustainability/esg-resources/.

In line with corporate standards and PS2 requirements, the project ESMS incorporates a corporate due diligence procedure for the procurement of critical materials and services, including solar PV panels. This approach will focus on assessing potential labor issues in the supply chain, particularly related to force labor (ESAP #1d).    

A total peak construction workforce is anticipated to be 170 personnel with a total operations workforce for the project estimated to be 6-8 people.

Human Resources Policies and Procedures: Scatec developed corporate policies which define the company's approach to HR in line with PS2 requirements. Scatec's Code of Conduct (CoC) references applicable policies where relevant (i.e. sustainability policy, HSSE policy etc.) and includes statements, among others, on i) opposing all forms of slavery, forced labor, trafficking, illicit forms of child labor and violations of human rights in Scatec operations; ii) opposing differential treatment based on colour, nationality, ethnicity, gender, age, sexual orientation, disability, religion or belief and zero tolerance policy on sexual harassment; iii) commitments to zero harm for employees, iv) supply chain including the requirement for undertaking an internal due diligence on suppliers; and v) whistle blowing including a statement indicating that any potential violation of the law, Scatec's procedures or the CoC can be reported as a violation. As part of the project, Scatec will develop and implement human resources policies and procedures for construction and operations in accordance with IFC PS2 requirements as per ESAP #2.

Freedom of Association.  Scatec’s global HR Policy states that the company acknowledges freedom of association and collective bargaining as a labour right of all employees. Employees have the right to join labour unions or form workers’ organizations.                                      

Grievance Mechanism: Scatec has a whistle blowing policy in which all employees and stakeholders can report any potential violation of law or Sactec's procedures or CoC. Scatec's global labor policy for site personnel states that a grievance mechanism must be defined in worker contracts. The Selebi Phikwe Solar project ESMS includes a grievance management procedure. The procedure shall be updated to include objectives, definitions, levels of grievances, timelines for resolving the grievances, roles and responsibilities, grievance form, and provision for third party dispute in the event the grievance cannot be resolved (ESAP #2).

Occupational Health and Safety (‘OHS’):  The corporate HSSE procedure states that Scatec projects must have documented systems for the management of occupational health, safety, security, and environment. As per corporate requirements, the project level ESMS will meet relevant regulatory requirements, Performance Standards and WBG EHS Guidelines where applicable and will include specific contractor requirements including risk assessment requirements for Scatec and its contractors per ESAP #1a and #1b.

Greenhouse gases (‘GHG’): The greenhouse gas (GHG) emissions associated with the Selebi Phikwe Solar PV project are minimal and short term. The limited direct GHG emissions to be produced will primarily stem from fuel combustion from construction equipment and transportation of equipment, materials, and employees to the site during the construction phase. Indirect GHG emissions is mostly associated with the manufacturing and transport of the materials.

Air Quality: The principal source of air emissions during the construction phase relates to dust emissions because of vegetation clearance, earthmoving and the transportation of materials, construction equipment, transformers, cables as well as solar panels. Management of these aspects will be through dust suppression mitigants included in the project ESMPs, as described in PS1.

Noise: During the installation phase, noise may be generated because of the operation of equipment, vehicles and machinery, the transportation of construction materials and staff to and from site, the establishment of site construction areas, as well as general construction activities. Management of these aspects for the closest receptors at Mapakata will be through the project ESMPs, as described in PS1.

Water consumption: The installation of PV equipment requires minimal water usage, primarily for sanitary purposes and dust suppression. Water will be used for cleaning of solar panels once a year during operations. Management of water use including looking at water efficiency will be through a Water Management Plan as part of the project ESMPr, as described in PS1. Automated dry-cleaning using mounted robots is also planned for the panels.

Waste Management: Typically, wastes generated from the installation of solar equipment include i) packaging material, such as the cardboard, plastic and wooden packaging and off-cuts, ii) hazardous waste from empty tins, oils, soil containing oil and diesel (in the event of spills), and chemicals; iii) building rubble, discarded bricks, wood and concrete, iv) domestic waste generated by personnel from chemical toilets, and v) vegetation waste generated from the clearing of vegetation. The ESIA identifies waste piles across the project footprint and highlights the non-compliance nature of the Selebi Phikwe landfill. It further identifies a list of waste management providers across Botswana capable of handling non-hazardous waste recycling as well as used oil. Non-hazardous waste shall be managed locally through re-use, recycling, and incineration. Scatec shall complete site pre-clearance to remove all the historic waste and a due diligence assessment of each third-party waste facility selected for project use shall be undertaken prior to it being used for project (ESAP #3a) in accordance with the ESIA.  A Waste Management Plan aligned with IFC requirements will be developed as part of ESAP #1b.

Botswana does not have a hazardous waste landfill. The potentially toxic materials contained in PV cells are considered as hazardous materials. Any hazardous waste (such as contaminated soil from spillages, used oil, filters, battery, chemicals, PV cells etc) will be temporarily stockpiled in designated areas on site (i.e., placed in leak-proof storage skips), and thereafter removed from site by a suitable service provider for safe disposal at a registered hazardous waste disposal facility in South Africa (ESAP #3b). The ESMS will define waste requirements to ensure PV cells and associated components are either recycled via an appropriately scaled PV cells recycling program to be coordinated with the PV cells supplier or disposed.

Pesticide Use Management: The use of pesticides during the operation of solar park is common, resulting in a moderate risk of pesticide-related issues for the project. As part of the ESMS development, Scatec will define project design requirements to ensure that conduits are pest resistant. In addition, the ESMPr will define screening requirements that discourages use of chemical pesticides, with the focus on prevention through proper housekeeping, effective waste management practices and manual clearing of vegetation during maintenance.                               

Community health and safety: The project may potentially impact community health and safety during the construction phase mainly due to i) nuisance from noise and dust, ii) increase in construction road traffic accidents, iii) increased GBV and sexually transmitted infections (STIs) due to worker/community interactions. Mitigation measures to reduce these risks are included in the environmental and social impact assessment (see PS1) which will be further developed and implemented through the ESMPr (ESAP #1b).

Traffic management: Workers’ accommodation will be offsite, requiring daily transportation to site. Included as part of the project’s traffic impact assessment which forms part of the ESIA (ESAP #1b), a transportation risk assessment will be undertaken, and monitoring requirements will be developed for the movement of workers during the construction period. Risk controls will be developed per the findings of the Traffic Impact Assessment TIA (ESAP #1a) along with monitoring requirements per ESAP #1a.

Security Personnel:  Security measures for the project will include i) electrified fencing, and ii) third party security contractors primarily used for access control (unarmed). The project will undertake a project level security risk assessment to include both construction and operations phases of the project. The outcomes of the security risk assessment will determine the content of the project level security management plan for both construction and operations and will include training requirements for security personnel per ESAP #4b.                                     

Gender Based Violence: The contextual risk for Gender Based Violence (‘GBV’) around the project area is considered moderate to high and has been exacerbated due to the closure of the nearby BCL mine leading to loss of jobs and further poverty.  The project will develop a GBV action plan as per ESAP #4a based on the GBV assessment conducted as part of the ESIA. The plan will inform the EPC development of relevant project procedures (including the labor and community grievance mechanisms), plans and the workers code of conduct.                               

The Selebi Phikwe 50MWac project has undertaken a public participation process, consistent with Botswana DEA requirements during the EIS approved by the DEA in 2020. As part of the ESIA update process in line with IFC PS requirements, further engagement activities were held in April and May 2023 to gather further feedback from communities to inform the ESIA and the development of the ESMPr and relevant social management plans. 

The project developed a stakeholder engagement plan (SEP) to inform about project timelines, anticipated construction impacts, recruitment policies, the project grievance mechanism are communicated to affected communities in a timely manner. A community grievance mechanism (CGM) was developed in line with IFC PS requirements during the ESIA update process and will be expanded and operationalized to manage, track and record potential grievances throughout the life of the project (ESAP #1e).                                                  

 post.za@scatec.com

3 Dock Rd, Cape Town City Centre, Cape Town, South Africa

+27 (0) 21 202 1230

www.scatec.com