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
Environmental and Social Policies and Management Systems. Mbouna follows a Quality Policy that directs its production methods, covering industrial processes, equipment standards, and staff development across all areas of the production line.
Current procedures address waste management, pest control and internal inspection at the milling plant. Daily inspections are conducted at each workstation to ensure hygiene, safety and product quality. The waste management procedure applies to physical, organic and chemical waste generated by the flour mill. In line with ESAP#1, Mbouna will expand its Quality Policy into a broader Environmental and Social Management System (ESMS), incorporating commitments on environmental management, occupational health and safety (OHS), stakeholder engagement and traffic management. Once updated and approved, the Company will operationalize these commitments across its activities.
Identification of E&S Risks and Impacts. Mbouna prepared an ESIA in 2023 for the expansion of its milling facility from 220 tons/day to 500 tons/day, which was approved by the environmental authorities in accordance with national regulations. Whilst the solar PV farm was described as part of the overall Project, the ESIA does not assess risks and impacts of either the solar plant or the transmission line. In line with ESAP# 2, Mbouna will prepare a standalone ESIA for the solar PV farm and the OHTL and will obtain the required licenses before the start of construction. The ESIA will include an environmental and social management program (ESMP) for construction and operational phases, consistent with IFC PS requirements.
The OHTL’s RoW, with an approximate width of 0.5 meters, is located entirely along Mbouna’s existing footprint with the land acquired on a willing-buyer, willing-seller basis in 2002. Once constructed, the OHTL will be handed over to the Company for operation and maintenance. In line with the enhanced ESMS, Mbouna will establish procedures to manage RoW safety, prevent encroachment, and mitigate community health and safety risks associated with the operational OHTL.
E&S management program. Mbouna conducted a risk assessment in 2023 covering nine operational units, including production, warehousing, administration and, and onsite clinic, etc. Key risks identified included falls from heights, electrical hazards, and internal traffic. The ESIA for mill extension provides a framework ESMP for construction and operations, outlining mitigation measures for air emissions, water use, effluent management, solid waste, and noise, as well as associated roles responsibilities, and legal obligations. In line with ESAP#1, Mbouna will expand its ESMS to integrate E&S parameters for the solar farm and transmission line.
Monitoring and Review. There is currently no systematic E&S monitoring plan in place. In line with ESAP#1, Mbouna will establish and implement a monitoring program covering both the milling plant and the Project. The EPC contractor will provide monthly E&S performance reports during construction, and quarterly reports during operations for the solar farm and OHTL. Mbouna will regularly monitor EPC compliance during construction and oversee the implementation of all Project-related E&S management plans.
Organizational Capacity / Competency. Mbouna's Quality department is led by a QHSE officer and supported by two Safety Officers reporting to the Operations Director. This unit oversees quality control across the milling plant – from wheat reception to product dispatch – and ensures implementation of internal procedures.
In line with IFC investment requirements, Mbouna will appoint a full-time Environmental & Social (E&S) Manager to oversee ESMP implementation and rollout the ESMS (ESAP#3). Given the scope of the project, Mbouna will also assign an Occupational Health and Safety (OHS) Officer for the construction phase of the PV plant and OHTL (ESAP#4).
E&S Training: Mbouna has a training plan covering hygiene, health and safety. In line with their ESMS (ref. ESAP #1), the plan will be updated to incorporate all E&S training needs for both the milling plant and solar farm, reflecting anticipated risks. Training will include work safety, risk assessment, defensive driving, first aid, working at heights and electrical safety.
Emergency Preparedness and Response. Fire hydrants and extinguishers are installed throughout the plant. In line with ESAP#1, Mbouna will develop and implement an Emergency Response Plan consistent with IFC Performance Standard 1. The plan will identify potential emergency scenarios across the milling plant and solar farm, assess associated environmental and safety risks, and define roles and actions. It will include measures to prevent and mitigate accidents, fires, electrical shocks, dust explosions, spillage, pollution, climate-related hazards, and contamination of finished products. All workers will receive response training – including drills and classroom sessions including those involved in construction. The Company will also disclose emergency protocols to nearby communities in an accessible format and ensure alignment between Mbouna’s procedures and those of the EPC contractor.
Performance Standard2. Labor and working conditions
At the time of the appraisal, Mbouna employed 266 staff, including five (5) contracted workers holding permanent contracts (Contrat a duree indeterminee – CDI). The workforce comprises of 241 men and 25 women. Mbouna occasionally engages labour for truck loading activities through a service provider.
For the construction of the solar farm, an EPC has been contracted. The EPC is expected to hire approximately 60 workers on fixed term contracts. For the operational and maintenance phase of the solar farm and OHTL, Mbouna intends to hire 15 permanent employees and 12 contracted workers.
Human Resources Policies and Procedures. Mbouna has recently adopted an internal labor regulation aligned with Malian labor laws, covering terms of employment, worker responsibilities, process of hiring, discipline and dismissals. The Company has developed policy and procedures to prohibit and address sexual harassment. Mbouna will consolidate all labour-related policies in an HR manual that will address non-discrimination, equal opportunity, freedom of association, prohibition of child and forced labor, Gender Based Violence and overtime management, internal grievance mechanism and an OHS policy and management plan. The HR department will conduct regular sensitization sessions for all current employees, including temporary workers, at the time of hiring (ESAP#5).
Working Conditions and Terms of Employment. Standard working hours are 09:00-17:00 from Monday to Friday. Shift workers operate on a rotating two or three-shifts system depending on operational needs. Salaries are above the statutory minimum wage. All workers receive a contract specifying wages, overtime, leave entitlement, allowances and notice period.
Recruitment is conducted in line with principles of equal opportunity, transparency, and merit. The HR Department, led by a manager and supported by four assistants, oversees all recruitment and HR functions.
Workers’ Organizations. Mbouna respects the right of workers to join or form union or workers associations of their choosing. Currently, there is no union in place. As part of their HR manual (Ref. ESAP#5), Mbouna will develop freedom of association policy to allow and uphold workers’ freedom of association and the collective rights of bargaining, consistent with PS2.
Grievance Mechanism. Mbouna has established a dedicated grievance mechanism for all employees including third party workers to address issues related to discrimination, harassment, and misconduct. This mechanism ensures that any employee who experiences or witnesses inappropriate behavior in the workplace has a formal channel to express their concerns. All complaints submitted through this system are subject to a resolution timeframe of 30 days, ensuring that issues are addressed in a timely and efficient manner.
To further strengthen this process, anonymous reporting channels will be implemented specifically for complaints related to Gender-Based Violence and Harassment (GBVH), providing a safe space for individuals to report sensitive matters without fear of retaliation. In addition, the Company will enhance worker training on the grievance procedures to ensure that all employees are aware of their rights and understand how to access and utilize the grievance mechanism (ESAP#6).
Mbouna will also develop a clear protocol outlining the steps for investigating and resolving GBVH-related cases. This protocol will define roles and responsibilities, maintain confidentiality, and ensure that all reported incidents are handled with sensitivity and professionalism. These enhancements to the grievance mechanism will apply not only to the existing milling plant but also to the future solar farm, and will cover all categories of workers, including contracted personnel, in line with (ESAP#6).
Protecting the Workforce. Neither child labour nor forced labour is utilized by Mbouna in adherence to the provisions of the Mali Labor Code. Mbouna only employs people over 18 years. As part of their HR manual (ESAP#5), Mbouna will develop a child and force labor policy consistent with PS2.
Workers Engaged by Third Parties. As part of this investment, Mbouna will develop and implement a third-party monitoring procedure to systematically verify that working conditions and terms of employment for construction and other contracted workers comply with national labor laws and IFC PS2 requirements. Any non-conformities identified will be addressed through a time-bound corrective action plan (ESAP#7).
Occupational Health and Safety. The primary Occupational Health and Safety (OHS) risks associated with the Project are linked to both the construction and installation phases—undertaken by the appointed EPC contractor—as well as the subsequent operational phase, which will be managed by Mbouna. As part of the ESMS (ESAP#1) Mbouna will develop an OHS Management System for its processing plants aligned with IFC PS2 and WBG EHS General Guidelines requirements as well as requirements for Electric Power Transmission and Distribution.
As per (ESAP#8), the Company will ensure, through legally binding contractual obligations, that the EPC contractor is responsible for developing a comprehensive OHS procedures specific to the project activities. The contractor must appoint a dedicated OHS focal point tasked with overseeing health and safety compliance on site. Furthermore, the EPC contractor is required to fully comply with Mbouna’s Environmental, Health, and Safety (EHS) requirements. This includes strict adherence to established safe working procedures, the proper and consistent use of personal protective equipment (PPE), and the mandatory reporting of all safety incidents and near-misses.
OHS performance during the construction phase will be tracked and evaluated on a regular basis using a defined set of key performance indicators (KPIs). The monitoring process will be overseen by the in-country Environmental and Social (E&S) manager, who will ensure that all safety protocols are being effectively implemented and maintained throughout the construction activities.
Once the project transitions to the operational phase, overall OHS responsibilities will be transferred to Mbouna, who will then manage and uphold all health and safety standards for ongoing operations under their ESMS (ESAP#1).
Supply Chain.
To manage E&S risks in procurement and supply chain, the EPC implements a mandatory Supplier Code of Conduct prohibiting forced labor and child labor, human trafficking, and requiring compliance with occupational health and safety, environmental protection, and business ethics standards. These requirements are embedded in supplier contracts and publicly disclosed.
The EPC also uses third party independent mapping services to trace suppliers up to the polysilicon, wafer, and cell stages. The shortlisted supplier also conducts annual ESG risk assessments with third-party factory audits. This approach strengthens supply chain transparency and oversight.
PS3: Resource Efficiency and Pollution Prevention
Greenhouse gases: The greenhouse gas (GHG) emissions associated with the Solar PV project are minimal and short term. The direct (Scope 1) GHG emissions will arise mainly from fuel use associated with combustion from construction equipment and transportation of material and personnel. During operations, diesel consumption will be minimal. Indirect emissions are largely associated with the manufacturing and transport of the PV components. Once operational, the Project will contribute to significant avoided CO2-eq emissions by displacing fossil fuel-based electricity generation.
Air emissions. During the construction phase of the project, air emissions will primarily consist of dust generated by several activities, including vegetation clearance, earthworks, and the transportation of materials and equipment to and from the site
In contrast, once the project moves into the operational phase, no significant air emissions are anticipated. To address and control dust emissions throughout construction, the Company will develop and implement a comprehensive Dust Management Plan. This plan will include targeted dust suppression measures designed to minimize airborne particulates. All measures will be integrated as part of the project's Environmental and Social Management Plan (ESMP), in accordance with the requirements outlined in the Environmental and Social Management System (ESMS) referenced in (ESAP#1).
Noise. During the installation phase of the project, noise will be generated as a result of various construction activities. These sources of noise include the operation of construction equipment, movement of vehicles around the site, and general site activities such as the transportation of materials and the establishment of designated work areas.
The potential impact of this noise on nearby sensitive receptors, such as residential areas or community facilities, will be addressed through measures established in the project’s Environmental and Social Management System (ESMS) in accordance with Performance Standard 1 (PS1). The ESMS will outline specific protocols and controls to mitigate noise-related disturbances, ensuring that construction activities are managed responsibly and in compliance with relevant standards and commitments (ESAP #1).
Water consumption. Water will be sourced directly from the national distribution network. During the construction phase of the project, water usage will be primarily restricted to two main purposes: meeting the sanitary needs of the workforce and implementing dust suppression measures on site. These activities are essential to maintain hygiene standards and control dust emissions generated by construction activities, such as earthworks and transportation of materials.
Once the project transitions into its operational phase, water requirements will decrease significantly. Water will be needed only occasionally for operational maintenance, specifically for cleaning the solar panels, which is anticipated to occur approximately once per year. This limited and periodic use of water ensures minimal operational water demand.
To ensure responsible and efficient water use throughout both the construction and operational phases, all water-related activities will be governed by a comprehensive Water Management Plan. This Plan will be developed and implemented in alignment with the project’s ESMS, as referenced in ESAP#1. The Water Management Plan will outline procedures for water sourcing, usage, and conservation, supporting the project's commitment to sustainable resource management.
Waste Management. The installation phase of the solar facility will result in the generation of various types of waste. These include packaging waste such as cardboard, plastic, and wooden materials, as well as cuts from construction activities. Additionally, construction debris and vegetation waste will be produced due to site clearing and ongoing construction operations. As per its ESMS referenced in ESAP#1, the company will enhance its waste management plan to incorporate construction waste.
Hazardous waste. Contaminated materials such as soil, oil, filters, batteries, chemicals, and damaged PV cells will be stored temporarily in leak-proof areas and then safely removed by licensed providers. To address these waste streams, the Company will update its existing waste management procedure as an integral part of the Environmental and Social Management System (ESMS), as referenced in ESAP #1. This updated procedure will ensure effective segregation of waste, prioritize the maximization of reuse and recycling opportunities, and mandate the disposal of waste through licensed incinerator facilities.
The plan will also outline procedures for handling, transporting, and disposing of hazardous waste, including requirements for recycling PV cells and components.
PS4: Community Health, Safety and Security
Construction is expected to last approximately eighteen months.
A small number of isolated residential buildings and a selling point are situated approximately 500 meters from the Mbouna facilities. The location of these structures in close proximity to the project site highlights the importance of implementing effective measures to manage potential impacts, such as noise, dust, and increased traffic, during both the construction and operational phases of the project. The Environmental and Social Management System (ESMS) will address the needs of these nearby sensitive receptors through targeted protocols and controls to ensure that any disturbances are minimized, and community well-being is safeguarded.
Security personnel. Security for the Project will be ensured through a combination of physical and personnel-based measures. The site will be enclosed by perimeter walls and electrified fencing, which are designed to restrict unauthorized access and protect project assets. In addition, both unarmed and armed third-party security personnel will be deployed, with their primary responsibility focused on controlling access to the facility.
In accordance with (ESAP#1), the Project will develop a comprehensive Security Management Plan (SMP) that aligns with both IFC Performance Standard 4 (PS4) and the Voluntary Principles on Security and Human Rights. The SMP will clearly define the roles and responsibilities of all security personnel, establish contractor requirements, and outline mandatory training obligations. These protocols are intended to ensure that all security activities are conducted ethically, lawfully, and in a manner that respects the rights of workers and community members.
Community health and safety. No worker accommodation camps are anticipated for the project, as the majority of construction workers will be sourced locally. As a result, labor influx is not expected during the construction phase.
There is a risk of potential encroachment within the OHTL RoW, which could pose health and safety hazards to nearby households and workers. In response, and as part of the Environmental and Social Management System (ESMS) enhancements outlined in ESAP #1, Mbouna will develop and implement targeted measures to prevent RoW encroachment. These measures will include comprehensive community sensitization initiatives, clear demarcation of the corridor, and routine monitoring throughout both construction and operational phases to ensure ongoing protection of community health and safety.
Road Safety and Traffic. Mbouna currently does not have a formal traffic management plan in place to reduce interactions between project vehicles and nearby communities, particularly in sensitive areas. As part of the enhancements to its Environmental and Social Management System (ESMS), the Company will develop a comprehensive road safety and traffic management plan. This plan will be aligned with the requirements of IFC Performance Standard 4 (PS4) and will address the safe movement of vehicles associated with the project.
Prior to the construction phase and continuing into operations, Mbouna will require the EPC contractor to conduct a thorough traffic safety risk assessment. Based on the results of this assessment, the contractor must implement a driver safety program. All elements of the traffic management and driver safety programs will be subject to review and approval by the Company, in accordance with the requirements outlined in (ESAP #1).
In accordance with its traffic management plan and to enhance the safety of local residents, the project will launch an awareness campaign in areas near transport routes. This campaign will inform community members about the planned mitigation measures, which include the installation of traffic signage, enforcement of speed limits, and the provision of contact details for the community liaison officer. These efforts are intended to ensure that residents are aware of the steps being taken to manage traffic-related risks and know how to communicate any concerns
