IFC’s review considered the following Performance Standards not to be applicable: PS5 (Land Acquisition and Involuntary Resettlement).  The company acquires (or had acquired) land on a willing buyer / willing seller basis. This process relating to the service station and power plant sites will be verified per PS1.  PS6 (Biodiversity, Conservation and Sustainable Natural Resource Management) as there are no identified sensitive natural habitats or natural resources at direct risk of SODIGAZ’s routine and proposed activities. PS7 (Indigenous Peoples) as there are no Indigenous Peoples present in the regions in which SODIGAZ’s activities occur; and PS8 (Cultural Heritage) because there are no identified artifacts and resources that would constitute to tangible or intangible cultural heritage resources in the project affected areas in which SODIGAZ’s activities occur                                                 

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 areas of E&S focus for this project include: (a) E&S screening and the appropriate undertaking impact assessments for proposed developments, (b) organizational capacity and management systems; (c) fair, safe and healthy working conditions for employees and workers; (d) hazard assessments and fire safety and emergency response planning; (e) pollution prevention (emissions, waste management, wastewater and hazardous chemicals management); (f) security management; and (g) stakeholder engagement and grievance mechanisms.                                                

  Policy and Management Systems: SODIGAZ has developed a corporate code of ethics providing an overarching set of expectations and policy positions expected by the company from its employees and stakeholders. The code of ethics addresses; i) health, safety, security, society and environment; ii) human rights; iii) protection of the environment; iv) security; v) data confidentiality; vi) anti-bribery and corruption; vii) community engagement; and viii) human resources (HR) related elements discussed further in PS2 below. A specific occupational, health and safety (OHS) policy has also been developed, signed by the Chief Executive Officer in January 2020. The policy has been disclosed to the workforce and published on the company website.

SODIGAZ has established elements of an environmental and social management system (ESMS) with documented policies and procedures, which include; i) occupational risk assessment procedures; ii) incident/ accident reporting; iii) site security requirements; iv) quality requirements for trucks relating to security and safety; v) specifications for the transportation of gas cylinders; vi) sales point safety and inspection requirements and measures; and vii) health and safety committee roles and responsibilities. As part of IFC’s financing, the company will augment its existing policies and ESMS applicable to all operations and to all contractors undertaking the development and operations of the SODIGAZ business in a manner consistent with PS requirements per ESAP #1a and #1b. Complimenting the corporate ESMS, SODIGAZ shall develop an ‘Owner’s E&S Standards’ which shall define SODIGAZ’s E&S contractor requirements consistent with corporate ESMS requirements. The document shall include KPIs and auditable criteria. The ‘Operator’s E&S Standards’ shall be included in all contractor contracts per ESAP #1c. As part of, and as defined by the corporate ESMS, SODIGAZ shall develop and maintain a corporate risk register per ESAP #1d and #3i.

Identification of risks and impacts: Applicable host nation legal framework requires adequate permits and authorizations for activities and operations relating to petrol stations and LPG cylinder depots. Supporting these applications, environmental and social impact assessments (ESIAs) or environmental assessments are required to be completed consistent with host nation regulatory requirements.

SODIGAZ holds operating licenses for the two depots located in Nabitinga and Ballolé and authorizations for the eleven existing gas stations. The company has prepared a draft ESIA for the Pamnoguin PV power plant. ESIAs have been completed or are under process for the service stations. As part of IFC’s financing, the company will complete project ESIAs in a manner consistent with PS1 requirements, per ESAP #2a and 2b for all new developments and complete ESIA which are ongoing and obtain the necessary regulatory approvals. SODIGAZ will also prepare E&S management and E&S construction plans to address the risks and impacts identified by the project ESIAs per ESAP#3m and #3n. SODIGAZ shall develop and maintain a corporate permitting register to ensure all SODIGAZ assets are developed and operated in a manner consistent with host nation regulatory requirements and corporate ESMS requirements per ESAP #1e.

Land for the existing service stations, the five new stations to be developed and for the solar power plant (4a ha) has all been acquired on a willing buyer / willing seller basis. The solar plant site had a customary owner which was acknowledged, with evidence, by the village elders’ committee.  The owner willingly agreed to trade the 4 ha of land in return for 23 parcels of land at a minimum of 300 m2 as owned by the housing project developer; this is bare open land and located near the housing project site. The plots will be levelled and ready to build on upon handover by the housing developers. Information on the plots for the five new stations was not available at the time of the IFC appraisal. As per ESAP #3c, SODIGAZ will; i) develop a procedure for willing-buyer willing seller land transactions incorporating the principles outlines in PS5; and ii) undertake a verification of the land acquisition process for the sites of the five new stations and the solar power plant against this procedure. Any gaps identified will be remedied in agreement with the IFC.

Management Programs: SODIGAZ has developed a number of management programs, primarily relating to OHS risk controls. As part of its corporate ESMS, the company shall augment existing corporate management programs related to; i) new asset development asset acquisition; ii) community health and safety; iii) environmental monitoring; iv) hazardous materials management; v) hazardous and non-hazardous waste management; vi) emergency preparedness and response; vii) spills and stormwater management procedures; viii) monitoring and inspection requirements for underground storage tanks (USTs) and septic tanks per ESAP #3a to #3k.

Organizational capacity and competency: SODIGAZ has established an organizational structure for environment, health and safety (EHS) management. SODIGAZ has appointed a full-time security and safety supervisor as well as a full-time EHS manager. The EHS resources falls under the supervision of the head of staff administration. To support the EHS manager, and as defined by the corporate ESMS, SODIGAZ shall augment its EHS capacity by retaining additional EHS officers, per ESAP #4a.

The EHS organization reports to the EHS committee which in turn, reports to the SODIGAZ board. As part of the corporate ESMS, specific reporting requirements shall be articulated (including the corporate risk register) for routine reporting to SODIGAZ senior management, its health & safety committee and its board, per ESAP #5.

Operational EHS oversight is provided by EHS representatives nominated for each service station. The EHS representatives are responsible for safety and environmental management with a specific focus toward truck loading and waste management. For construction and development sites an EHS representative is in place responsible for environmental and safety management. Prior to construction SODIGAZ will ensure its engineering, procurement and construction (EPC) contractor hires an EHS resource and a community liaison resource for the solar project and for the service stations defining clear roles and responsibilities that correspond to the construction management plan and/ or the Owner’s E&S Standards per ESAP# 4b.

Emergency Preparedness and Response: For its service stations SODIGAZ has developed an on-site emergency procedure to respond to potential fire incidents. As part of the ESMS, the company will establish an emergency preparedness and response system, in collaboration with appropriate and relevant third parties, ensuring the project is prepared to respond to incidents and emergency situations associated with the project in a manner appropriate to prevent and mitigate any harm to people and/or the environment. The emergency preparedness and response system will include the identification of areas where accidents and emergency situations may occur, communities and individuals that may be impacted, response procedures (including scenarios and associated mock drills), provision of equipment and resources, designation of responsibilities, and communication per ESAP#3h.

Monitoring and review: SODIGAZ have developed monitoring tools including checklists and templates for equipment verification, truck verification and reseller verification. As part of IFC’s financing, the company will establish documented procedures to monitor and measure the effectiveness of its current fleet management to ensure consistency with host nation regulatory and PS requirements per ESAP # 4 and ESAP#5. As specified under ESAP #3k, the company will further develop a monitoring procedure and inspection program for underground storage tanks (USTs) for all service stations to ensure alignment with the host nation requirements and good international industry practice (GIIP).

Gender Based Violence: The contextual risk for gender-based violence (‘GBV’) for the project has been assessed as high. An influx of project workers and jobseekers into the area where developments are occurring with access to disposable income may increase GBV risks, particularly during construction. These issues will be addressed via the management plans to be compiled for the construction projects (ESAP 3n).                                                 

   The SODIGAZ human resources (HR) function is overseen by an appointed manager, the head of human capital, located at the SODIGAZ main offices and is the most senior staff in the HR team. As of October 2021, the total SODIGAZ workforce comprised of 381 workers, of which 118 (30%) were temporary workers. SODIGAZ will retain an additional 34 workers for the operations of two of the four service stations to be developed. Construction workforce numbers for the service stations are yet to be determined. For the construction of the solar power plant, 30 temporary workers will be hired, while 5 jobs will be created for its operation, covering security and site maintenance.

Human Resources Policies and Procedures: SODIGAZ has developed elements of an HR management system which provides requirements for the induction of new recruits, an annual training plan, performance appraisal guidelines and supporting material for employee appraisals. As part of IFC’s financing, SODIGAZ will augment its existing HR management system to ensure alignment with the requirements of PS2, per ESAP #6a. An HR handbook will be developed consistent with the requirements of PS2 to define the company’s approach to HR for direct, contracted and third-party workers throughout the project life cycle per ESAP #6a. The handbook shall be provided to workers at the point of engagement and appropriately communicated to all employees (direct, third party and contracted). Third party contractors will be required to ensure consistency with the augmented HR management system, with performance and audit requirements to be articulated in the ‘Owner’s E&S Standards’, which shall be included as part of SODIGAZ standard procurement contracts, per ESAP #1c. The HR management system shall augment existing training requirements to ensure consistency with the provisions of PS2, per ESAP #4c.

Working Conditions and Management of Worker Relationships: SODIGAZ employs both direct and third-party labour. As part of IFC’s financing, the company will revise employee contracts in a manner consistent with the revised management system, employee manual and HR policies, per ESAP #6a. The revised HR management system will also include provisions for migrant workers to ensure consistency with PS2 requirements. SODIGAZ encourages freedom of association and labor representation across the workforce and regularly engages with and cooperates with recognized trade unions in Burkina Faso. SODIGAZ shall formalize existing practices by developing; i) employee representative election requirements; and ii) company and representative engagement requirements, per ESAP #6c. 

Non-Discrimination and Equal Opportunity, Forced Labor and Worker Grievance Mechanisms (GM): As noted in PS1, the SODIGAZ code of ethics makes specific HR related commitments which include anti-harrassment, diversity, equal access to employment and equal opportunity. The company is committed to zero tolerance of any actions or conduct which is humiliating, intimidating or hostile. The code of conduct makes clear definition of, and a zero tolerance of, sexual harassment in the workplace and psychological harassment.

SODIGAZ’s code of conduct makes commitments to ensuring a fair and equal workplace free from all forms of discrimination in hiring, remuneration, access to training, and promotion, based on gender, age, ethnicity, religion, disability, union membership or political affiliation.

As part of IFC’s financing, SODIGAZ shall develop and implement a sexual harassment policy and associated disciplinary procedures (ESAP 6b). In addition, a worker grievance mechanism consistent with the provisions of PS2  will also be developed and implemented and apply to all company workers and equally contractors where such do not have access to a grievance mechanism. The worker grievance mechanism (GM) will include procedures to address gender-based violence complaints. Employee contracts will include reference to the grievance mechanism.  It will also be communicated to workers and extended to third party workers / contractors through inductions, training and additional sensitization activities per ESAP #6c.

IFC’s contextual risk screening indicates a risk of underage labor in the region. As part of IFC’s financing, SODIGAZ shall develop a policy prohibiting employment of child and forced labor, per ESAP#6a.

Occupational Health and Safety (OHS): SODIGAZ is committed to ensuring the protection of health and safety for both employees and contractors are thus aligned with the provisions of PS2. SODIGAZ has also developed an OHS improvement plan which identifies a range of improvements, including working at heights, risks identification cylinders safe handling, defensive driving, manual handling, fire safety. Additional supporting procedures have also been developed.

As part of the project’s ESMS development specific OHS elements will be defined and implemented, per ESAP #3a including; i) OHS training, including emergency preparedness and response, for SODIGAZ staff to ensure contractors and primary supply chain service providers, including their workers operate in a manner consistent with SODIGAZ’s ESMS requirements; ii) a monitoring and reporting program consisting of the collection of key OHS statistics including near misses, root cause and trend analysis, verification of implementation of corrective actions, and other relevant components covering SODIGAZ staff and contractors; iii) the update and implementation of a worker safety program, iv) an audit program for SODIGAZ construction and operational sites, to extend to SODIGAZ contractors responsible for construction and maintenance of SODIGAZ assets; and vi) formalized COVID-19 safety protocols, tailored to their operations, in compliance with relevant requirements by host nation health authorities.

Supply Chain: Forced labor is a growing concern in the development of solar panels. The company has developed a general procurement procedure and has selected reputable solar suppliers. Moving forward, SODIGAZ will ensure that all solar PV suppliers are signatories to the Solar Energy Industries Association’s Forced Labor Prevention Pledge and include specific contract language in the procurement of solar equipment, per ESAP #6e.                                                

  Resource efficiency: For the construction and operations of the solar project, the impact on water resources has been assessed by the ESIA as low, considering its localized extent and its temporary duration. Water usage associated with SODIGAZ’s key activities is primarily for sanitary purposes. SODIGAZ stations are connected to the public water network and are approved for approximate daily consumption of 1500m3. In areas not connected to the public water supply, the company arranges necessary water abstraction permits from the same authority.

The company’s sites are predominantly supplied by the public grid. However, being itself a solar solutions supplier, the company supplements its needs at service stations and other sites with solar installations. All service stations outside of the local grid coverage are fully solar powered. GHG emissions have been assessed to be less than 25,000 CO2e/y.

Pollution Prevention: The main water effluents generated at service stations and depots include sanitary wastewaters from sanitation and cleaning, sewage and storm water. The company relies on standard sanitary septic systems installed in accordance with local regulations to prevent hazard to public health. The SODIGAZ ESMS shall define monitoring, inspection cleaning and discharge requirements for septic tanks, per ESAP #3j.  The company will arrange adequate oil and water separation prior to discharging to municipal drainage, consistent with EHS guidelines and to ensure compliance with the legal limits, per ESAP ##3j at all the depots and services stations.

SODIGAZ operation of service stations primarily involves the sale of fuel and LPG cylinders which do not result in significant quantities of wastes and emissions. Petroleum products are stored in underground storage tanks (USTs) presenting a potential for soil and groundwater contamination in the event of leakage. SODIGAZ ensures USTs are installed per regulatory requirements. UST compliance is determined prior to commissioning by regulatory authority. The practice is consistent with Good International Industry Practice (GIIP) and WBG EHS guidelines. As part of the ESMS development, the company will undertake regular monitoring of USTs and undertake prompt action in the event of leak detection, per ESAP #3k.

Waste management: Waste generated at SODIGAZ site include domestic non-hazardous waste. The company is also expected to dispose of 170,000 obsolete gas cylinders. The requalification plant will have appropriate technologies to recondition reparable cylinders be end 2022. Cylinders that are beyond repair shall be disposed of and sent to scrap metal dealers, per ESAP #3f.

Hazardous waste, including used oils, used filters, soiled rags, used batteries and electronic waste from solar installations are currently generated principally from the garages and the service stations. The company will develop a waste management procedure consistent with GIIP and EHS guidelines to ensure proper disposal through accredited dealers, per ESAP #3f.                                                 

  The solar power plant construction site together with the planned service stations are in suburban and urban settings. Mitigation measures to reduce traffic incident risk will be addressed in the construction management plan, per ESAP #3m. The project will develop and implement a consolidated community health and safety plan which shall integrate mitigation measures from all ESMPs to manage community health and safety risk at the project level, per ESAP #3c.

Life and Fire Safety: SODIGAZ has established safety measures for service stations which are included in clauses with LPG resellers. To mitigate the risks associated with assets and equipment, and communities especially in case of fire or explosion, the company shall develop and implement life fire and safety and process safety improvement measures. These shall include; i) electrical safety at depots; ii) improvement of fire safety and electrical safety at petrol stations; and iii) vehicle maintenance and preventative maintenance, as per ESAP #3a.

The company organizes trucks for the delivery of gas cylinders and fuel through its subsidiary. Driver training materials have been developed to include driver behavior, driver technical knowledge, vehicle maintenance and defensive driving. SODIGAZ will develop a transportation management plan per ESAP #3a.

Security Personnel: the company employs a total of 48 unarmed security agents spread across SODIGAZ and its subsidiaries. Security personnel is either directly employed by SODIGAZ or via third parties. The construction site of the future solar power plant in Pamnoguin as well as the construction and operation of new service stations will require the recruitment of additional security personnel.

As part of IFC’s financing, SODIGAZ shall undertake a security risk assessment considering all SODIGAZ assets and operations per ESAP #2d. The results of the security risk assessment shall be used to develop a company security management plan, per ESAP #3l. These shall both be developed in a manner consistent with PS4 requirements and GIIP, namely the Voluntary Principles on Security and Human Rights.