Land for the project is leased from government for a lease term of 49 years effective in 2020 (land in an area designated for commercial buildings), thus PS5: Land Acquisition and Involuntary Resettlement is not considered to be applicable. No conversion of natural/critical habitats will take place; therefore PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources does not apply. There are no indigenous people, and the presence of cultural artifacts are unlikely therefore PS7: Indigenous Peoples and PS8: Cultural Heritage, are not applicable.

The Key E&S risks associated with this Category-B project include: (a) E&S impact assessment for the proposed project as per IFC PSs; (b) company’s E&S staffing and management systems for construction and operation in line with IFC PSs; (c) assurance of fair, safe and healthy working conditions during construction and operation especially freedom of association and gender issues; (d) effluent, emissions and waste management; (e) life and fire safety design and implementation in line with WBG EHS Guidelines; (f) stakeholder engagement and grievance mechanism.

Policy, E&S Management System and Assessment of Risks and Impacts

DGL, a subsidiary of Duval created for the Project in Rwanda has a management endorsed environmental and social policy. The E&S policy includes commitment to responsible operational practice, and a mandate to implement policies and procedures to meet IFC PS requirements. For the new project, the E&S policy statement endorsed by management will be disclosed to the workforce. For the project, Duval commissioned and completed an environmental and social impact assessment (ESIA) (Annex-1) and received the relevant local approvals and licenses in 2019. Prior to project commencement in 2023, Duval hired a specialized consultancy firm to provide a supplementary ESIA, also called a supplementary lenders information package (Annex-2, SLIP) to fill in any gaps between the 2019 ESIA and IFC PSs requirements. The findings will be used as baseline data for developing management programs for the project level environmental and social management system (ESMS) (ESAP #1). Based on this ESMS, project teams shall enhance the country/project screening checklist to include environmental information, information about availability of local labor and suppliers, in addition to screen the project versus all IFC Performance Standards (including PS5 to 8 as well) and relevant international standards. Duval’s management will endorse the E&S policy and ESMS in compliance with applicable domestic legislations and sector-specific requirements and regulations as a minimum.

Organizational Capacity

The corporate impact director oversees the role of the E&S compliance manager. For each project constructed previously by Duval, there was an E&S coordinator on-site from the operations team, assisting and reporting directly to E&S compliance manager. The E&S coordinator is responsible for the safety and environmental protection of the construction operations on site, from the mitigation of the E&S risks and impacts of the project as well as for overseeing contractor workers and the security guards. For the Project, DGL will develop documented roles and responsibilities for the project E&S organization and will hire an E&S coordinator to assist the E&S compliance manager during construction and as well as operation phases (ESAP #2).

Management programs

In line with its compliance policy, an environmental and social management plan (ESMP) is developed for each new Duval project, considering the ESIA requirements, country specific screening of OHS and legal requirements, required permits, availability of resources including local labor, transportation, and E&S risks in the host country. Within its project level ESMS, DGL will develop management plans and programs to mitigate and manage the risks and impacts of its projects and activities identified by the 2019 ESIA and 2023 SLIP for this project (ESAP 1). The plans and management programs will address E&S aspects such as OHS risks, noise, resource efficiency, air emissions, wastewater, solid waste management and hazardous materials during construction and operation phases. The E&S management plans will include details such as where and how local licensed handlers will be selected, where the nearest government approved land fill is located, as well as methods to reduce the waste generated on site. Targets and key performance indicators (KPIs) are then placed to measure actual performance and implementation of these management programs against.  

Monitoring and Review

Duval conducts both internal and external audits of the E&S aspects of its activities. The same is planned for the Project where internal audits are undertaken by a member of the operational team and external audits are performed by a specialized consultant. There is an annual management review meeting where all audit results, OHS and environmental reports pertaining to DGL projects are shared with Duval for assessment and budget decisions.

Emergency response plan

DGL will develop a site-specific emergency preparedness and response plan (ERP) and procedures for the project (ESAP #1). The procedures will describe emergency scenarios and specifies responsibilities, measures and required resources. The ERP will be based on local regulatory requirements and site conditions.

 The Project is planned to have 500-600 contractor and subcontractor employees during construction and around 80-100 mostly local employees (30 full time and 70 contractor employees) during operation (80% males and 20% females).

Human Resource Policies & Procedures

DGL has an employee handbook which is currently under translation and includes a human resources policy that references IFC Performance Standard 2 requirements and will be endorsed by management. Groupe Duval is committed to equal opportunity and non-discrimination in its Ethics and Compliance charter which will be cascaded down to the Duval Great Lakes HR manual applicable to the Project. DGL will customize an HR manual for the Project including HR policies and procedures in line with the requirements of IFC PS2 with specific reference to freedom of association with worker organizations, non-discrimination, non-use of child/forced labor, retrenchment, accommodation, benefits, leave system and grievance mechanism at a minimum (ESAP #3). These HR policies and procedures will be communicated to workers in a local language through various channels including induction, regular training, and refreshers.

Working Conditions and Terms of Employment

Duval employment contracts will include working conditions and terms of employment, with reference to host country labor law. Company will review employment contracts for direct and contractor employees in line with IFC PS2 requirements in addition to the host country regulation requirements and will update them as needed accordingly (ESAP #3).

Workers organizations

Duval management is committed to encourage workers to be aware of their right about freedom of organization. Duval will develop relevant HR policies to address this commitment (ESAP #3).

Grievance mechanism

There is a grievance mechanism at Duval where the concerns are raised to HR in a confidential manner. The employee grievance mechanism will be enhanced to include applicability to contractor workers, anonymity, a separate channel for sexual harassment claims as well as a timeframe for providing a response to grievance raiser (ESAP #3). This update will be communicated to the workforce including applicability to contractor workers.

Child Labor and Forced Labor

Labour Law in Rwanda prohibits employment of child labour (young persons under 16) or forced labour. The company’s employment screening includes verification of birth certificates and national identity cards, to check the age requirements.

Occupational Health and Safety

Every project Duval executes has a specific OHS management plan developed and project risk assessments covering construction activities and operations. Duval also develops and annual training plan including health and safety topics for all employees, supervisors, and skilled workers as well as external specialized trainings for specific personnel such as those involved in security provision. Within the ESMS system, per ESAP item 1, the company will conduct an OHS risk assessments for high-risk activities (e.g., excavation, trenching, working at height, lifting operations, electrical, scaffolding, and hot works) for Inzovu, which will be communicated to all workers conducting these activities (ESAP # 1). 

Incidents recording, personal protective equipment (PPE), safety instructions, toolbox talks and safety trainings to employees and contractor employees as well as OHS KPIs will be integrated into the OHS management plan. Duval will develop and implement a corporate incident investigation and root cause analysis guidance, within the ESMS (ESAP #1) to ensure consistent practice in the investigation and root cause analysis of OHS incidents across construction and operation phases of the project. 

Gender

Duval is an equal opportunity employer and are committed to non-discrimination at the workplace. Duval will engage expertise to assess the risks of sexual harassment in the project workplace and explore options for engaging female employees on their safety risks and concerns and the risks of gender-based violence in affected communities and supply chains, perpetrated by workers and/or contractors who will be living or staying in local communities and by truck drivers (ESAP #4).

Workers engaged by Third Parties

Third party contractors include sub-contractors undertaking civil, electric and other works at Duval construction sites and security and cleaning services at Duval subsidiary offices and the project during operational phase. The company screens sub-contractors against E&S assessment criteria prior to signing the services agreement. Within ESMS that will be developed per ESAP #1, Duval will update its contractor management system to incorporate a requirement into their agreements with contractors, to follow Duval’s internal regulations and procedures, in line with IFC PS requirements, on occupational health and safety; grievance mechanism; and worker accommodation if provided.

Air pollution and GHG emissions

The Project is not expected to have more than 25,000 tons of carbon dioxide (CO2) equivalent emissions per year. The company plans to use electricity from the local network in Kigali. All diesel generators used as back-up power source will be fitted with air filters and air emissions tests will be conducted as required by local regulatory requirements. No fuel is stored on site during construction or operations.

Resource efficiency

Duval is planning to employ several resource efficiency initiatives such as installation of LED lights as well as automated lighting system in public spaces. DGL is also currently studying the possibility of solar panels installation at the project for providing hot water to the project during operation. In addition, there is a study for the issuance of EDGE certification for the project where a Building Management System (BMS) will be installed to reduce operating costs through energy optimization.

Water and Wastewater

Water for the project will be supplied directly by the municipality-provided water network during construction and operation. The main sources of wastewater on the project are sanitary wastewater generated by use of water in cleaning, washrooms, and toilets. For this, the construction site will be connected to existing sewers which is connected to the municipal sewer.

Solid and hazardous waste management

The E&S consultant of Duval has assessed the solid waste and hazardous waste management streams locally available in Kigali. Hazardous waste, such as empty paint and thinners canisters, will be kept in a container under lock and key with restricted access to trained personnel. Each container is provided with a fire extinguisher and danger signs outside. These materials are stored and disposed of by licensed waste handlers contracted in Kigali Duval will develop and implement a solid and hazardous waste management plan according to E&S consultant’s assessment for the construction and operational phases (ESAP #1).

Infrastructure and Equipment Design, Life and Fire Safety

For its projects in general, Duval integrates the infrastructure and life and fire safety (LFS) design criteria, in line with host country building requirements and applicable international codes and standards. Smoke detectors, sprinklers and fire alarms are to be installed at the premises as per the local regulatory requirements. A competent third-party consultant is responsible for performance testing, commissioning, and certification prior to occupation of buildings. For Inzovu, Duval will engage with a suitably qualified fire safety specialist to conduct a review of the design specifications to be reviewed and updated against the L&FS section of the WBG General EHS Guidelines (ESAP6a) and upon completion of the construction, test life and fire safety and certify that these systems comply with national, as well as international fire safety and building codes, as referred to in the L&FS section of the WBG General EHS Guidelines, for public access buildings (ESAP #6b).

Road Transportation

As a part of the ESMS, per ESAP #1, DGL will develop a specific traffic management plan (TMP) in line with the traffic assessment (Annex 3) conducted in 2020 for the Project site. The assessment identified the surrounding motorways, street access, peak traffic times and expected traffic impacts of the site on its surroundings once the development becomes operational. Impacts on traffic during construction phase were part of the supplementary impact assessment (SLIP) conducted in 2023 which identified the presence of the Convention Centre located less than 1km away, a school less than one kilometre from the Project site and a busy pedestrian footpath near the Project site. Informed by the findings of both assessments, the TMP will address road transportation safety hazards and risks and establishes principles for management of transport of equipment and material to site during construction phase, fleet management and driver management and parking set-up and management during both construction and operation phases.

Security personnel

Duval security measures on its projects include security personnel and CCTV cameras linked to a security control room. The company employs unarmed security guards to manage access control and emergency response. For Inzovu, the company will install several access-control points to check all pedestrian entrances and parking gates, hire a private security firm, conduct a security risk assessment to develop a security management plan accordingly (ESAP #1). Training for security guards from the private security provider is conducted by external agencies.

Stakeholder Engagement, External communications and Grievance Mechanisms

Duval regularly engages with regulatory agencies and locally with communities from the project areas though activities of corporate social responsibility (CSR), DGL engaged in stakeholder consultations in March 2023 specifically on The Project in Rwanda, with stakeholders including business representatives, community leaders, local NGOs, and the local representatives of the districts (Gasabo), sectors (Kimihurura), cells (Rugando) and villages impacted by the Project. Outcomes of the consultations will be used to develop the stakeholder engagement plan and community grievance mechanism (ESAP #5).

At the project construction site, a billboard will be used to announce the phone number as per local regulatory requirements. In addition, a standardized e-mail through which it communicates and responds to community concerns. In previous Duval projects, the concerns, compliments, and complaints received from the public are recorded in a logbook at the premises of the subsidiary then directed to the relevant managers for response. Most concerns raised were related to noise and were routed to the relevant department to resolve the issue. Under ESAP #5, for Inzovu, the team will undertake trend analysis and share these reports with management for review.

Protecting communities against gender-based violence      

Duval will engage with experts to help assess the risks of gender-based violence in affected communities and supply chains, perpetrated by workers and/or contractors who will be living or staying in local communities and by truck drivers (ESAP #4). In addition, Duval will continue to implement a code of conduct for employees and contractors that prohibits gender-based violence and provide training to all employees and contractors on gender-based violence code of conduct. As per ESAP 5, a grievance mechanism for reporting sexual exploitation and abuse perpetrated by employees in affected communities will be developed and implemented.

Contact Person: CARLIER Cécile

Company Name: Groupe Duval

Address: 45 Av. Georges Mandel, 75116 Paris, France

Email: CCARLIER@groupeduval.com

Phone:   01 46 99 47 10