PS6 and PS8 are not applicable and specific biodiversity and cultural heritage requirements are covered under PS1 and within the E&S management system.                                                  

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. The environmental and social risks and impacts associated with this project are limited, site-specific and can be readily addressed through generally accepted mitigation measures as described in this document and the attached Environmental and Social Action Plan (ESAP).

Neoenergia Coelba has established an effective E&S management system (ESMS) and dedicated E&S teams to manage and monitor their E&S performance. Thus, the key Environmental and Social (E&S) issues associated with this project as identified during IFC’s review are related to (i) Neoenergia Coelba’s capacity and competence on the implementation of the corporate environmental and social management system (ESMS) to manage E&S risks in its expansion and operations, (ii) fair and safe working conditions and management of OHS aspects including response to the COVID crisis in terms of job protection and worker safety; (iii) contractor management in terms of all relevant E&S issues, including working conditions and OHS; (iv) emergency response and preparedness; (v) gender, sexual harassment and Gender-Based Violence (GBV) issues at the workplace; (vi) resource and energy efficiency, and management of waste and emissions; (vii) land acquisition; (viii) biodiversity screening and management; (ix) impacts on Indigenous Peoples and ethnic traditional communities; (x) protection and management of cultural heritage sites, and (xi) stakeholder engagement.                                                  

 Policy

Neoenergia Coelba has adopted and follows Neoenergia’s Environmental and Sustainable Development Policies (2019) which are extended to all the companies belonging to the Neoenergia group. These policies are followed by the Company and its contractors and form an important component of Neoenergia Coelba’s E&S management framework. The Board of Directors recognizes the environment as one of the three pillars of the sustainable energy model, together with competitiveness and safety. 

Neoenergia Coelba is bound by Neoenergia’s corporate policies which include (i) Corporate Governance and Sustainability, (ii) Sustainable Development, (iii) Sustainable Management, (iv) Environment, (v) Climate Change, (vi) Biodiversity, (vii) Occupational Health and Safety, (viii) Risk Management, (ix) Corporate Security, (x) Human Rights, (xi) Stakeholder Relations, and (xii) Human Resources as well as by the Code of Ethics. These policies are applicable to contractors, joint ventures and other associations where the Company assumes management functions.

Environmental and Social Assessment and Management Systems

Neoenergia has an environmental management system that transfers corporate environmental policies to environmental guidelines, aligned with the United Nations Sustainable Development Goals.  Neoenergia Coelba has quality, safety and environmental programs and procedures based on ISO management systems standards, that are part of the Company’s corporate Integrated Management System (IMS). Neoenergia Coelba’s management system is certified under ISO9001:2015 and ISO45001:2018 standards and has in place a plan to conduct a feasibility analysis to obtain the ISO14001:2015 certification. As part of ESAP item #1, Neoenergia Coelba will expand the scope of the feasibility analysis currently under way to identify actions that will be required to ensure its management system comprises the elements deemed to be necessary by IFC Performance Standards to effectively “plan, do, check, act” with regards to the E&S outcomes. The analysis will be aimed at incorporating Neoenergia Coelba’s social policies, management plans, procedures and stakeholder engagement features, including clear procedures to consult with potentially affected communities and relevant stakeholders as an integral part of the management system.

Identification of Risk and Impacts

Neoenergia Coelba follows Neoenergia’s General Risk Control and Management Policy which considers regulatory, reputational and operational, technological, environmental and social risks. At the corporate level, the Board of Directors undertakes to develop all its capabilities to adequately identify, measure, manage and control risks.  Neoenergia’s Investment Policy, which is also followed by Neoenergia Coelba, provides the guidelines to carry out risk analyses associated with climate change and physical change in the environment, and requires systemic follow-up of environmental and land requirements to minimize environmental and socio-economic risks. Based on the directives derived from these policies, Neoenergia Coelba defines environmental and social objectives and action plans to properly manage the identified risks.

Neoenergia Coelba has an “Environmental Aspects and Impact Assessment” procedure to assess, measure and mitigate the environmental impacts arising from its activities.  Identified environmental and social risks from all the processes, activities and facilities are registered in an “environmental aspects and impacts identification and assessment matrix”, which details the type of risk or impact for each activity and an assessment of importance, magnitude and probability of occurrence.  In addition, Neoenergia Coelba has a system to identify and manage all environmental regulatory requirements, keep track of legal obligations and monitor compliance. 

During the environmental permitting process of new transmission and distribution lines and substations, Neoenergia Coelba secures the services of qualified and certified cultural resources specialists to conduct studies to identify and manage cultural resources in accordance with the requirements by the National Institute of Historic and Artistic Heritage (Instituto de Patrimônio Histórico e Artístico Nacional –  IPHAN). The qualified cultural resources specialist coordinates with IPHAN field surveys and potential rescue and restoration of archaeological, paleontological and historical resources, as deemed necessary by IPHAN.

In addition to these E&S impacts identification tools and procedures, Neoenergia Coelba conducts environmental and social impact assessments in line with Brazilian legislation prior to the development of any infrastructure projects in their concession with the support of specialized environmental consulting firms. To enhance the process of identifying E&S risks and impacts aligned with IFC standards Neoenergia Coelba will expand its E&S impact assessment process and develop: (i) a “Social Impact Assessment Procedure” (ESAP item #2) aimed at identifying and managing social impacts following IFC Performance Standards, including the assessment of impacts to Indigenous Peoples and provisions to consult with potentially affected communities and relevant stakeholders to identify and address their concerns; and (ii) a “Biodiversity Screening & Assessment Procedure” (ESAP item #3) in line with Performance Standard 6 to properly assess biodiversity impacts, including baseline requirements, risk assessment, management and monitoring of any future activity or projects to understand: a) all projects comply with Brazilian regulatory requirements; b) if the activity/project can be carried out (i.e. no  CAPEX items funded by IFC are undertaken in Alliance for Zero Extinction Sites or World Heritage Sites), and c) what management and monitoring requirements will be applicable depending on the type of habitat where these will be developed (Modified, Natural or Critical Habitat).

Management Programs

The Company’s environmental, social, health and safety management programs and plans are steered through the implementation of an overarching environmental management plan that forms part of the Company’s Electric System Management Strategy.  Neoenergia Coelba’s E&S plans and programs include prior analysis of environmental licensing and permitting requirements, risk assessment, emissions control, solid and hazardous waste, environmental noise, vegetation management, environmental compensation, reforestation, management of fauna, emergency preparedness and response, workforce management, equal opportunity, vocational and E&S trainings, security, contractors management, land acquisition, customer relations, community awareness and stakeholder engagement and grievance mechanisms. 

These programs and plans are in line with Brazilian legislation and mostly aligned with IFC requirements. They include details on monitoring actions, frequency of monitoring along with performance indicators and are reviewed and revised regularly. The appraisal identified the need for Neoenergia Coelba to develop the following management programs as part of ESAP item #4: (i) an “Erosion Control & Reinstatement Procedure” to ensure that the development of projects take into consideration the reduction of footprint, and preventive measures to control erosion and promote reinstatement of affected areas; (ii) a “Projects Biodiversity Management Procedure” to ensure that any new project related to CAPEX funded by IFC  includes provisions to mitigate impacts to biodiversity and achieve No Net Loss or Net Gain, as applicable, depending on the classification of habitat in line of PS6; and (iii) a “Cultural Heritage Chance Finds Procedure” in line with Brazilian regulations and IFC Performance Standards for chance finds during the construction of new transmission and distribution lines and substations.

Organizational Capacity and Competency

At the corporate level, responsibility for E&S management resides with the Sustainable Innovation and Climate Change (SICC) superintendent, who reports directly to the Adjunct General Director.  The superintendent oversees the departments of Innovation and Quality, Sustainability and Climate Change, ESG, and Social Responsibility. Neoenergia Coelba has assigned qualified personnel, including management representatives, with clear lines of responsibility and authority for managing E&S issues. The Sustainable Innovation and Climate Change manager is supported by two environment experts for transmission components, and ten Sustainability experts for distribution. Neoenergia Coelba’s Occupational Health and Safety (OHS) department is composed of forty OHS experts. The director of institutional relations reports directly to the Adjunct General Director.  In addition to three institutional relations staff, Neoenergia Coelba engages with clients and community members through the Client Service department, which is comprised by more than a hundred staff distributed throughout the seven regions, covering all its operations. To strengthen Neoenergia Coelba’s E&S organization, the Company will define as part of ESAP item # 5 a Neoenergia Coelba employee (a biologist versed in PS6) to manage all the biodiversity requirements and activities resulting from the implementation of the procedures previously described, which are necessary to align Neoenergia Coelba’s operations to IFC standards.

Emergency Preparedness and Response

Neoenergia Coelba has an overarching Emergency Preparedness and Response Plans (EPRP) and has in place emergency response plans for each of its operational bases. These plans include potential emergency scenarios (generated by both internal and external risk factors, such as spills, fires, criminal activities, and natural disasters), emergency contacts and communication flows (internal and with community leaders and government authorities), protocols for the use of equipment, and drills.  The Company discloses the EPRPs to employees and contractors’ workers, communities and local authorities.

Monitoring and Review

Neoenergia Coelba has procedures to monitor and evaluate the effectiveness of all E&S management programs as well as compliance with legal obligations and regulatory requirements.  The Company’s IMS has a module to evaluate safety, administrative and quality performance and closely monitors contractor’s activities on site. Field inspection programs are in place to assess the integrity of safety procedures, quality of execution and compliance with labor legal requirements.  Where gaps are identified a seven-step process is followed to i) describe the gap, ii) identify immediate actions to avoid, contain or reduce harm or risk, iii) define actions and controls, iv) conduct a root cause analysis of the identified gap, v) identify potential inspection failures, vi) develop and implement corrective actions, and vii) conduct a final verification. 

The Neoenergia group has a strong governance structure for the oversight of E&S matters. Environmental teams from all the companies, including Neoenergia Coelba, must report environmental and social issues to senior management, through meetings of the Board, Power Grid Committee and Sustainable Working Group. The Board of Directors and Power Grid Committee take place weekly. In addition, the Corporate Innovation and Sustainability Superintendency holds weekly meetings with all departments. Based on the E&S performance, the Company's Board of Directors analyzes and review the need to adapt and improve policies, objectives, procedures, key performance indicators and E&S practices in general.

Neoenergia has adopted the standards of the Global Reporting Initiative (GRI) and publishes annual sustainability reports. The documents state the investments, actions, indicators, and E&S performance by each of the group's subsidiaries, including Neoenergia Coelba.

E&S Contractor Management

Neoenergia Coelba assesses contractors, service providers and suppliers as part of the tender process.  Through the due diligence process, the Company reviews OHS and E&S performance and practices of prospective contractors, including labor conditions and quality control. E&S requirements and procedures are included in each contract. Contractors are required to adopt and implement the Company’s OHS policies, standards and procedures.

Audits to contractors and key suppliers are conducted regularly. The audits assess compliance with E&S requirements and with Brazilian legislation, identifying non-compliances, observations and improvement opportunities, reducing risks and mitigating impacts. After the auditing process, the contract managers monitor and track to completion the implementation of any identified non-conformities and corrective actions with suppliers and contractors.                                                  

 As of January 2022, Neoenergia Coelba had 5,356 direct employees and 11,764 contractor workers. The number of direct workers has been increasing at a rate of about 10% annually since 2019.  Approximately 90% of the direct workers are from the state of Bahia, with the rest coming from the other areas of the country.  Close to 19% of the total workforce are women. 

Human Resources Policies and Procedures

Neoenergia’s Human Resources Policy and Code of Ethics, which are duly followed by Neoenergia Coelba, are aligned with local regulations and consistent with PS2 requirements, covering labor and working conditions, including prohibition of child and forced labor, non-discrimination, promoting equal opportunity and respecting freedom of association. Employees are provided with contracts describing labor and working conditions, and through the induction program are informed of the corporate policies and the Code of Ethics, which are also available in the Company’s website.  E&S contractual agreements with all contractors require compliance with the Company’s Human Resources policies and the Code of Ethics.

Working Conditions and Terms of Employment

Contracts with direct employees specify labor conditions and through an induction process employees are made aware of the Company’s Human Resources policies, the Code of Ethics, and their rights and responsibilities. Neoenergia Coelba verifies that all contractors’ workers are registered in the Brazilian National Institute of Social Security (Instituto Nacional do Seguro Social - INSS) and that all taxes and fees related to workers’ benefits required by law are covered by contractors.  Through periodic audits and monthly field inspections the Company verifies adequate working and occupational health and safety conditions are provided by contractors and suppliers.

The Company has a “Talent Management” scheme and personal development plans. In 2021, 506 people were promoted and 589 employees throughout the organization received recognitions of excellence. In the same period, Neoenergia Coelba provided training to employees in technical matters, occupational health and safety and corporate culture and values.  Neoenergia Coelba works with technical institutions to train and certify electricians from local communities.  To date, 26 training programs have been conducted with the support of the Company, training 624 electricians from different communities. This initiative, which has some components to foster women participation, is highly appreciated by local stakeholders.

Worker’s Organizations

Ceolba has in place a collective agreement with the Union of Electric Workers of Bahía (‘Sindicato dos Electicitários da Bahia’ – SINERGIA). Approximately 30% of Neoenergia Coelba’s workers are members of this union, however the union represents all the workers, and working conditions and benefits negotiated and reflected in collective agreements are applicable to all Company’s workers.  The last collective agreement was subscribed in 2021 and is in effect until 2023.

Non-discrimination and Equal Opportunity

Neoenergia Coelba’s Human Resources and Human Rights Policies, as well as the Code of Ethics and the Recruitment and Selection procedure have provisions for equal opportunity and non-discrimination.  Approximately 19% of Neoenergia Coelba’s employees are women, with 30% participation at the management level, 25% of supervisors and 31 % at the director level.  The female participation in the contractors’ workforce is approximately 11%.

Through the implementation Neoenergia’s “Juntos” Program (or “Together”), Neoenergia Coelba implements diversity and inclusion initiatives to increase the participation of women and of people with disabilities throughout the organization.  The program includes campaigns for the empowerment of women and training and education to address GBV, racism LGBTQ+ issues within the organization and in the communities where it operates.  Through its electrician training program, Neoenergia Coelba has trained 122 women in co-ed and women-only groups. Per ESAP item #6, Neoenergia Coelba will develop a Gender Strategy to foster more women participation in the Company, especially with contractors and subcontractors, ensuring there is no unintended discrimination in the recruitment selection and promotion procedures and removing any barriers for women to be hired, retained and promoted in the organization, including risk of experiencing gender-based violence and harassment (GBVH). The Company will develop an action plan for the implementation of the Gender Strategy, which will include provisions to reduce the risks of GBVH in the Company, contractors’ and the communities where it operates.

Worker’s Grievance Mechanism

The Company has an online mechanism to address workers’ queries, concerns and complaints. All communications are registered and addressed. In addition, Neoenergia Coelba has in place a grievance mechanism managed by a third party to ensure transparency and avoid any form of retaliation. In 2022, the reported monthly average number of grievances received was 54, which were resolved in 13 days on average. The mechanism allows for anonymous complaints to be issued and is available to all employees and contractors’ workers through 24/7 telephone, email, or the intranet. The mechanism is broadly communicated through the induction program and routinely reinforced through safety talks conducted daily at the start of the working day. Neoenergia Coelba has technical guidance and procedures for receiving and investigating grievances. These specifically describe actions for conducting reports on labor abuse and sexual harassment.  As part of ESAP item #6, Neoenergia Coelba will review and enhance the procedure to ensure GBVH grievances are adequately addressed with a survivor centered approach and ensure all employees, contractors and subcontractor workers are aware of the mechanism and know how to properly access it.

Occupational Health and Safety

Neoenergia Coelba has a robust, well-structured and sophisticated occupational health and safety (OHS) management system which is ISO45001 certified and based on Neoenergia’s OHS corporate guidelines and policies. The system encompasses all the activities carried out by Neoenergia Coelba employees, contractors and subcontractors and is heavily centered in ensuring high quality OHS training and competency of all the workforce, particularly those involved in high risks activities, such as working with energized equipment and live lines, working at heights and electrical safety. Neoenergia Coelba follows Brazilian OHS and technical regulatory standards (known as “Brazilian NR”), but also implements a series of actions, programs and activities that go beyond legal compliance and foster a strong safety culture and a continuous evolution, improvements and maturity of its OHS management system. Examples of these are: (i) standardization and review of OHS operating procedures; (ii) training of the workforce in OHS practices and procedures; (iii) induction of newly hired employees (from own teams and third parties), (iv) rigorous OHS compliance assessment of internal rules and legislation, (v)  clear definition of OHS roles and responsibilities in the field, (vi) regular updates to the accidents and incidents investigation process, enabling new failure analysis methods to identify systemic root cause; (vii) safety inspections and procedures with visible participation of supervisors and managers, operational inspectors, technicians and occupational safety engineers; (viii) a behavioral observations program; (ix) OHS audit program and audits.

With regards to occupational health, Neoenergia Coelba has a Medical Control and Occupational Health Program (PCMSO as per its Portuguese acronym) aligned with Regulatory Standard No. 7 (NR7). The PCMSO is based on identified hazards and factors of risk in the work environment and integrates a set of initiatives to promote the health and wellbeing of workers. With regards to COVID19, the Company has implemented controls and monitoring processes to address risks and exposure to COVID in line with government regulations and good international practices. Implemented measures include COVID awareness raising, social distancing, enhanced sanitation protocols, regular PCR tests, periodic health checks and distribution of PPEs.                                                  

 Resource Efficiency and Greenhouse Gas (GHG)

Neoenergia Coelba, as part of the Neoenergia, follows the group’s climate change policy which is aimed at promoting a culture of awareness with regards to the threat of global warming and at identifying actions in the areas of mitigation and adaptation, resources efficiency and Greenhouse Gas (GHG) estimation and reduction. The policy establishes a company-wide commitment to gradually reduce the intensity of GHG to below 150 grams of CO2 per kWh by 2030, which entails a 50% reduction in the intensity of emissions compared to 2007, which was defined as the base year. The Innovation and Sustainability Superintendence oversees the implementation, monitoring and reporting of the policy in all the companies of the group, including Neoenergia Coelba.

The Company estimates Scope 1 & 2 of GHG emissions and discloses the obtained results in the annual Greenhouse Gases inventory, which exposes the emissions from all activities for CO2, SF6, CH4, and N2O.  The annual GHG report is prepared in line with the requirements established in the NBR-ISO 14064-1:2012 Standard: “GHG effect. Part 1: Specification and guidance to organizations for quantification and reporting of emissions and GHG reductions”, and in the guidelines of the Brazilian GHG Protocol Program.

The 2020 report indicates that Neoenergia Coelba produced 16,653 tCO2e for Scope 1, which includes fugitive emissions of SF6 and other refrigerant gases, emissions from the fleet of vehicles, and GHG resulting from changes in the use of soil because of the vegetation clearance and pruning, and 256,934 tCO2e for Scope 2, which includes energy consumption and losses in the transmission and distribution grid. Neoenergia Coelba maintains a collaboration with the Emissions Inventory and the Mitigation and Adaptation to Climate Change Plan of Salvador, as well as with the Bahia Climate Change Forum.

To further enhance the GHG management, the Company will develop as part of ESAP item #7 an “SF6 Management Plan” to provide framework guidance on SF6 management, monitoring and reporting according to industry best practices to prevent and minimize risks and impacts.

The Company has many resource efficiency initiatives for its customers as well. For example, with the program “Power and Citizenship and Energy for the Community”, Neoenergia Coelba replaces inefficient light bulbs with more economical, durable and efficient LEDs. The Company foster the substitution through mobile units that are parked in strategic points and through door-to-door campaigns that are carried out in populous districts and communities in Bahia, where energy efficiency awareness is raised. With this program Neoenergia Coelba substituted in 2021 nearly 240,000 inefficient light bulbs with LEDs in 175 communities and 213 institutions.

Water & Wastewater Management

According to the information provided by the Company, the main source of water supply is from the potable water municipal grid. The Company tracks and reports water consumption figures in the annual sustainability report. According to the 2020 report, the potable water consumption reached 1,576 liters per employee with a sustained decreasing trend (i.e. reduction in water consumption figures) over the years. All the effluents and liquid discharges from the Company storage and distribution centers, workshops, office buildings and facilities are discharged to the local sewers operated by the local sewage company.

Pollution Prevention and Control

Pollution prevention is fully embedded within the Company’s environmental management system. Neoenergia Coelba has developed and implemented different management and monitoring plans to ensure their activities are conducted to minimize adverse impacts on human health and the environment, including for areas under the direct control of the Company, and areas managed by contractors and subcontractors. There is a culture of pollution prevention, and in all the areas and work fronts that were inspected during the appraisal the implementation of environmental mitigations is evident, with good housekeeping, adequate segregation of residues and with the required pollution prevention measures commensurate to the nature of the activity and the corresponding risks and impacts.

Solid Waste Management

Neoenergia Coelba has a solid waste management program (“PGRS” for its Brazilian acronym) aligned with the waste management hierarchy, good industry practices and Brazilian regulations. Waste is segregated at source, collected and classified in hazardous, non-hazardous, recyclable and non-recyclable waste streams, temporarily stored in dedicated storage facilities, and disposed-of following local regulations and procedures. The PGRS establishes roles and responsibilities, waste management practices, and cradle-to-grave recording, monitoring and reporting requirements. All the waste management process is documented in manifests, logbooks and waste management databases which are kept up to date and are regularly monitored and audited. Contractor environmental requirements include provisions they need to follow to comply with the Company’s waste management program.

In addition, the Company has a recycling program called “Vale Luz”, to encourage consumers to practice waste recycling. Neoenergia Coelba grants discounts on energy bills in exchange for recyclable waste directed to cooperatives of waste collectors and recycling industries. With this initiative Neoenergia Coelba collected 601 tons of recyclable waste in 2021, which represented 294K R$ in discounts of energy bills for customers.

Hazardous Materials & Waste Oil

Hazardous materials and chemicals (e.g., solvents, paints, cleaning agents, oils) are handled through Neoenergia Coelba’s hazardous materials procedures and management plans. These define OHS and environmental provisions for the safe transportation, handling, storage and use of hazardous materials, including emergency response.  Compliance with the provisions of these plans is verified through Neoenergia Coelba’s assurance process, and if any deviation is observed, corrective actions are defined and monitored to completion.

Polychlorinated biphenyls (PCBs) are typically present in oil-cooled electrical equipment such as transformers or condensers. The use of PCBs in new electrical equipment is prohibited in Brazil and PCBs are regulated to ensure that power distribution companies develop a detailed inventory program for identifying PCB levels in transformer oils to ensure the protection of the environment and human health. In accordance with this regulation, PCB containing materials and equipment should be out of operation until 2025, and after that they need to be disposed until 2028, in line with the Stockholm convention. Neoenergia Coelba has an inventory of transformers and equipment containing PCBs.

Neoenergia Coelba has a contract with specialized companies for the management, disposal and reclassification of PCB containing equipment. The reclassification takes place according to Brazilian environmental standards and the grid removed equipment is managed and disposed of in an environmentally appropriate manner by a licensed contractor.

Any equipment removed from the electrical grid goes through a screening process, where technical analyses are performed and if contamination is identified the equipment goes through the process of decontamination or removal in line with environmental standards and regulations. These activities are carried out by specialized contractors that are duly licensed by Brazilian environmental agencies.

To further align Neoenergia Coelba’s environmental practices to IFC’s General EHS Guidelines and the Guidelines for Electric Power Transmission and Distribution, the Company will undertake as part of ESAP item #8 a Technical Review of all facilities storing grid removed transformers and develop an improvement plan in those areas or facilities where gaps with these standards are identified.

Pesticide Use

If the Company has right-of-way clearing, cleaning and gardening practices and management plans and needs to use any herbicides or pesticides, it will follow all the Brazilian Legislation. Grid and right-of-way maintenance is predominantly manual (i.e., physical clearing of undergrowth and regular cutting of vegetation), which are activities usually performed by contractors, who follow general precautions and controls as established in Neoenergia Coelba’s vegetation management plan.                                                  

 Neoenergia Coelba has programs to educate communities about the hazards associated with accidental contact and manipulating electrical equipment. The Company provides instructive information to communities in presentations at schools at home and other venues, via brochures, posters, the internet, radio, television and through influencers on social media. Issues addressed include safe use of electricity at home, staying away from broken transmission and distribution cables, avoiding illegal access into the Company’s lines, warning children about the dangers of playing near lines, and other safety precautions around electric installations. The “Lives Saved” program encourages all employees to identify unsafe acts related to manipulation or use of electric devices being conducted by community members and provide advice to stay safe.  

All Company employees that operate vehicles are trained on defensive driving and conduct vehicle inspections prior to starting a journey.  In addition, Neoenergia Coelba works with the police on campaigns to strengthening safe driving conditions of the population, and with the fire department to share experiences on risk identification and emergency response.

Neoenergia Coelba has regional contractors for operations and maintenance in each of the 7 regions where it operates, increasing the local participation of workers and reducing the transportation requirements, and the need for migrant workers. 

Security Personnel

Neoenergia Coelba uses a government sanctioned security contractor (“SegurPro”) to provide protective services for its facilities.  In total, 138 guards are distributed through its operations, of which 22 are armed.  Armed security guards are only stationed at 7 key facilities during the night shift.  All guards receive training on Human Rights, use of force, the Code of Ethics, and Company specific security operations.  As per ESAP item # 9, the Company will conduct a Security Risk Assessment to identify the risks posed by security arrangements to those within and outside facilities and determine whether such private security personnel are being vetted, hired, equipped, and trained adequately. Based on the assessment, the Company will develop a Security Forces Management Plan for managing private security force to avoid potential harm to employees, communities and other stakeholders. This plan should include formal procedures for reporting, responding to and documenting security incidents, training requirements including GBV prevention and management, and reviewing of security record of security contractors, consistent with IFC PS4.                                                  

 Throughout the state of Bahia there are indigenous and quilombola communities that are served and affected by Neoenergia Coelba. The Brazilian legislation recognizes Indigenous Peoples (IPs), determines the rights and obligations of these groups and has requirements to address potential impacts and implement mitigation measures. When IPs are affected, Neoenergia Coelba engages with the National Foundation of Indigenous Peoples (Fundação Nacional do Indio – FUNAI), the federal entity responsible for the establishment and implementation of policies related to IPs and the entity responsible for defining, in consultation with IP communities, the mitigation and compensation measures to be implemented when power projects are developed within or near their territories.

The rights of the quilombola communities are also recognized in the Brazilian constitution and are managed by the Palmares Cultural Foundation (Fundação Cultural Palmares).  When quilombos are affected, a study specifically focused on the potential social and environmental impacts on quilombola communities is required to be conducted as part of the environmental licensing process.

Two public civil actions have been filed against Neoenergia Coelba in 2007 and 2014 for the use of the right of way in electricity grid corridors through the lands of the Kiriri and Tuxtá indigenous communities respectively. Both cases remain unresolved and under the legal system.  

As part of ESAP item #11, Neoenergia Coelba will develop an Indigenous Peoples Framework applicable when indigenous and quilombola communities are affected by any Neoenergia Coelba’s operations, to ensure principles aligned with PS7 are fully implemented. The framework will include clear principles and guidance to (i) identify IP and quilombola communities potentially affected by projects, (ii) identify potential impacts and mitigation measures with a gender perspective, through robust consultation of potentially affected communities, (iii) obtain Free Prior and Informed Consent (FPIC), when necessary, (iv) prepare and implement indigenous people plans,  (v) establish mechanisms for monitoring and periodic reporting each agreement reached with affected communities, (vi) ensure accessibility to a culturally appropriate grievance mechanism for indigenous and quilomobola communities.