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 Policy and Management System: At the corporate level, Infinity Power has established a suite of Environmental and Social (E&S) policies and procedures, including an Environmental and Social Policy, a Community Investment Policy and monitoring toolkit, a biodiversity policy (with commitments to no net loss and a net gain approach by 2030), a supply chain procedure and a local skills development strategy. These policies are aligned with the IFC Performance Standards (PSs) and provide overarching principles for E&S risk management, to be implemented and tailored at the project level. These policies are shared with Project personnel, including the EPC contractors.
Infinity Power has also developed a climate change resilience framework to inform project design and construction, incorporating climate projections and Representative Concentration Pathway (RCP) scenarios to assess medium- and long-term climate risks. Infinity Power will apply this framework to the Touba and Laboa PV plants.
At project level, an Environmental and Social Management System (ESMS) manual has been developed, incorporating Infinity Power’s corporate policies and applicable requirements for both construction and O&M phases of the Project. The ESMS manual defines processes for the identification and management of E&S risks and impacts, including requirements for contractors. The EPC contractor will be contractually required to develop and implement project-specific Environmental and Social Management Plans (ESMPs) aligned with Infinity Power policies and applicable international standards. In line with ESAP #1, the Project will require that the EPC contractor prepares and implements a project-level and site-specific ESMPs for both construction and operations, consistent with IFC PSs, the World Bank Group Environmental, Health and Safety (EHS) Guidelines, Infinity Power policies, and the findings of the ESIA. The Project will review and approve all ESMPs prior to the commencement of construction.
Identification of Risks & Impacts: The Project has prepared an ESIA covering both solar PV plant sites and a proposed 90 kV OHTL, which was approved by the National Environmental Authority (ANDE) in July 2024. The ESIA assesses relevant baseline conditions and potential E&S risks and impacts associated with the Project in line with national requirements. Key potential E&S impacts identified include land acquisition and changes in land use; air emissions and noise; habitat loss; and hydrological impacts. Biodiversity baseline surveys, including flora, fauna, and avifauna assessments, were conducted to evaluate potential impacts (see PS6). Positive impacts include employment opportunities for local communities. The Project will update the ESIA in line with IFC PS1 to: (i) include a formal analysis of alternatives for site selection; (ii) strengthen the justification for the delineation of the Project’s area of influence; (iii) expand the assessment of certain Project components and associated facilities, including the existing and revised OHTL right of way and extend it to potential access roads, workers’ accommodation, reforestation areas, and borrow pits; (iv) assess the potential impacts on the cemetery in relation to the OHTL corridor to develop and implement a Cultural Heritage Management Plan. (ESAP #2)
Management Programs: The ESIA includes a framework Environmental and Social Management Plan (ESMP), which requires the EPC contractor to develop and implement a comprehensive suite of site-specific management plans prior to construction and for the operations phase. These plans will cover biodiversity management, labor and working conditions, air quality, waste management, traffic management, and emergency preparedness. The updated ESIA (as per ESAP #2) will provide additional requirements for the EPC to adopt in its preparation of the ESMP.
As set out in ESAP#1, the EPC contractor will be required to prepare and implement site-specific ESMPs covering both PV sites and the OHTL for the construction and operations phases. These plans will be updated periodically, as needed. The Project will review and approve all ESMPs prior to implementation.
Organizational Capacity & Competency: Infinity Power demonstrates adequate capacity to manage environmental, social, health and safety (ESHS) risks, including occupational health and safety (OHS), and has a good understanding of IFC requirements and international good industry practice. Infinity Power has appointed a Senior West Africa E&S Manager, based in Senegal, who serves as the acting E&S focal point for the Project. Additional corporate E&S resources include a Head of Sustainability and a Head of HSE, both based in South Africa, as well as a Head of Compliance supporting contractor evaluation, including E&S aspects. A Community Liaison Officer (CLO) has been recently hired to support stakeholder engagement at the site level. To further strengthen project-level capacity, the Project will recruit a dedicated EHS Supervisor on site. Together with remote resources, they will oversee E&S performance and interface with the EPC contractor during construction and operations (ESAP #3).
Furthermore, in line with the ESMS manual, the EPC contractor will be contractually required to appoint qualified E&S personnel, including an Environmental Officer, a Biodiversity Specialist, a Construction HSE Officer, and an HR Officer, to support implementation of the ESMPs on site. The EPC contractor will prepare an E&S staffing plan commensurate with Project needs, including appropriate resourcing and supervision arrangements (ESAP #3)
Emergency Preparedness & Response: Infinity Power has developed a corporate Emergency Preparedness and Response (EPR) template that defines minimum requirements, including roles and responsibilities, coordination with authorities, emergency procedures, control measures, training, and monitoring for the identification and management of potential emergency situations. The template is to be further developed and implemented at the Project level by the EPC contractor.
As per ESAP #1, the EPC contractor will prepare and implement site-specific Emergency Preparedness and Response Plans (EPRPs) in accordance with PS requirements. These plans will address a range of potential emergency scenarios, including medical emergencies (e.g., workplace injuries, disease outbreaks, and wildlife-related incidents), fire, extreme weather events (e.g., heatwaves and floods), transport incidents, and hazardous material spills. The EPRPs will include communication protocols coordinated with local authorities and communities, including evacuation procedures. Regular training, drills, and emergency response exercises will be conducted.
Monitoring & Review: As part of its corporate requirements, Infinity Power has established mechanisms to monitor E&S performance across its projects and contractors, including routine KPI reporting, inspections and audits, and annual sustainability reporting. At the Project level, site-specific ESMPs will include procedures and resources to monitor and verify the effective implementation of contractor management plans, in line with corporate requirements, national regulations, and IFC PSs. EPC contractor performance will be closely monitored during construction and operations as part of the ESMS requirements.
Management of Contractors and Sub-Contractors: At corporate level, Infinity Power requires E&S obligations to be embedded in contractor contracts. As part of the project ESMS development, Infinity Power will develop and implement a Project Contractor Management Plan consolidating all E&S obligations into a single procedure, to include specific E&S requirements, aiming to strengthen oversight and ensure compliance with international standards during the next project phases, covering child, forced labor, and significant safety issues requirements (ESAP #1).
PS2 – Labor & Working Conditions
The project is expected to employ up to 250 workers per site during the 15-month construction period, most of whom will be engaged by the EPC contractor. Given strong expectations for local jobs, the Project will coordinate with the EPC contractor and local authorities to emphasize local communities’ access to jobs. Around 18 workers per plant are expected to be employed during the project’s O&M phase.
Human Resources (HR) Policies and Procedures: Infinity Power has established corporate-level Human Resources (HR) policies broadly aligned with IFC PS2, covering recruitment, diversity and inclusion, non-discrimination and equal opportunity, freedom of association and collective bargaining, and grievance mechanisms. In addition, Infinity Power has developed an Ethics Toolkit, including a Code of Conduct (CoC), which addresses risks related to child and forced labor, discrimination and harassment. These policies apply to all Infinity Power projects, contractors, and workers, and will be implemented for the project.
As per ESAP #4, Infinity Power will develop a Human Resources Management System (HRMS) applicable to both construction and operations. The HRMS will include procedures on recruitment (including local hiring), terms and conditions of employment, performance management, freedom of association, disciplinary measures (including those related to gender-based violence and harassment (GBVH), and demobilization following construction in line with PS2. It will also include procedures for assessing contractors’ recruitment practices, training and mentoring programs, a Code of Conduct with zero tolerance for GBVH, and a worker grievance mechanism applicable to contractors and third-party workers (ref. ESAP#1).
The HRMS will apply to all Project workers, including those employed by contractors and subcontractors (e.g., security personnel), and will be translated into French, made accessible, and communicated through induction and ongoing training. Contractors’ practices are aligned with these requirements, and adequate HR resources are in place.
During construction, the majority of workers are expected to be recruited locally. On-site accommodation is anticipated only for the Laboa site. As part of ESIA update, the Project will include a worker accommodation risk assessment to define minimum standards for accommodation where required, including provision of basic services and welfare facilities in line with IFC PS2 and the IFC/EBRD guidance note on workers’ accommodation (ref. ESAP #2). The results of this assessment will inform the development of any necessary mitigation measures, including those addressing GBVH risks (ref. ESAP #1).
Working Conditions and Term of Employment: All workers, including those employed by contractors and subcontractors, will receive written contracts in French specifying terms and conditions of employment, including wages and benefits, working hours and overtime arrangements, leave entitlements, and occupational health and safety provisions, as per Ivorian labor law. Contracts for construction-phase workers will clearly indicate the temporary nature and expected duration of employment. As set out in ESAP #5, the EPC contractor will develop a Project workforce plan, including estimates of workforce composition by skill level, provenance, contract type, and gender. The plan will also include measures to prevent child and forced labor and ensure that these requirements are incorporated into contractual arrangements with contractors and suppliers.
Occupational Health and Safety (OHS): Key occupational health and safety (OHS) risks for the Project include slips and falls, interaction with moving machinery, manual handling, traffic incidents, electrical hazards, heat stress, wildlife-related risks (e.g., snake bites), and risks associated with module installation. Infinity Power has developed an EHS framework for EPC contractors covering, among others, training programs; job safety analysis and risk assessments; personal protective equipment (PPE) requirements; permit-to-work and lockout-tagout systems; OHS signage; medical support; welfare facilities; access control; induction and toolbox talks; incident reporting and investigation; and performance monitoring.
The EPC contractor will be contractually required to implement project-specific OHS plans and adopt Infinity Power’s EHS framework for both construction and operations, in line with Ivorian legislation, IFC PS2, and GIIP. This will include adequate EHS staffing to ensure effective implementation. As set out in ESAP #1, compliance will be monitored through regular inspections and audits, including periodic third-party reviews, with monitoring conducted quarterly during construction and semi-annually during the initial operations phase.
Labor risks within the supply chain: To manage E&S risks in procurement and the supply chain, Infinity Power has established structured processes, including vendor prequalification and selection procedures, a PV module supply chain risk assessment, an Ethics Guide, and a Code of Conduct (CoC) aligned with IFC Performance Standards. These frameworks address labor practices and human rights risks and are incorporated into supplier contracts.
The CoC requires compliance with national regulations and internationally recognized standards and is supported by due diligence procedures, including supply chain mapping, third-party risk assessments and background checks (covering risks such as child and forced labor), and ongoing monitoring of supplier performance. Shortlisted suppliers are required to disclose key sub-suppliers, and both suppliers and sub-suppliers must sign a forced labor declaration confirming compliance with applicable laws and international labor standards. Infinity Power maintains a list of approved suppliers and reserves the right to terminate contracts in cases of repeated non-compliance with CoC requirements. Infinity Power will consolidate these processes into a Supply Chain Management System (SCMS) aligned with IFC PSs and GIIP. The SCMS will include provisions for periodic third-party audits to verify compliance with labor and working conditions requirements. Audit findings and corrective actions will be shared with IFC (ESAP #6)
PS3 – Resource Efficiency & Pollution Prevention
Resource Efficiency – Energy and Water Management: Greenhouse gas (GHG) emissions during construction are expected to be limited and primarily associated with fuel consumption from generators, transport, and on-site equipment. Total emissions are expected to remain below 25,000 tCO2e per year. Water use during construction will be mainly for dust suppression, concrete works, minor batching activities, and domestic use. During operations, water consumption will primarily be associated with panel cleaning, with dry cleaning methods prioritized to minimize water use.
At the time of IFC’s due diligence, the assessment of the water source for the construction phase had not been finalized. The ESIA includes a preliminary assessment of groundwater use, with boreholes within the Project footprint considered for both construction and operations. Hydrogeological surveys have been conducted; however, additional studies are required to confirm groundwater availability, particularly at the Laboa site. The Project will undertake further hydrogeological assessments to confirm sustainable abstraction rates and ensure no adverse impacts on groundwater resources and surrounding communities prior to any groundwater use (ESAP #7).
Pollution Prevention: During construction, minor risks of air, water, and soil pollution are anticipated and can be mitigated through standard pollution prevention and control measures included in the Project’s environmental management plans. Wastewater will be collected in impermeable tanks and transported by licensed contractors to approved treatment facilities. During operations, no significant pollution impacts are expected, with the exception of wastewater from panel cleaning and routine domestic waste generation. The Project will implement pollution prevention measures in line with national regulations, IFC Performance Standards, and the ESIA.
The Project will generate non-hazardous waste (e.g., paper, wood, plastics, scrap metal, and glass) and limited quantities of hazardous waste (e.g., transformer oils, paints, batteries, and electronic waste). Waste volumes are expected to be low during both construction and operations. The project will develop and implement a Waste Management Plan aligned with national requirements, Infinity Power’s policies, IFC PS, and the World Bank Group EHS Guidelines. The plan will include measures for waste minimization, reuse and recycling, and procedures for storage, segregation, tracking, transport, and disposal. It will also ensure waste traceability, define criteria for selecting licensed third-party contractors, and include specific provisions for the management of hazardous waste and end-of-life PV components (ref. ESAP #1).
Pollution Prevention – Hazardous Materials: Hazardous materials used during construction and operations will include hydrocarbons, oils, lubricants, and paints. These materials will be stored in designated, impermeable areas with restricted access, in accordance with national requirements. The Project will develop and implement a project-specific Hazardous Materials and Spill Prevention Management Plan for both construction and operations, based on Infinity Power’s corporate policies. The plan will cover procedures for transport, storage, refueling, spill prevention and response, training, inspections, maintenance, monitoring, and reporting, and will be aligned with IFC Performance Standard 3 and the World Bank Group EHS Guidelines (ref. ESAP #1).
PS4 – Community Health, Safety & Security
Road Safety & Traffic Management: During construction, traffic will primarily be associated with the transport of materials and equipment over the 15-month construction period. Uncertainty remains regarding the potential need to upgrade the access road to the Laboa site. The Project will undertake a Traffic and Transport Risk Assessment and, based on its findings, develop and implement a Traffic and Transport Management Plan (ref. ESAP #1 and #2). The plan will define access routes, assess road conditions and traffic risks, and will include measures to minimize potential land-related impacts on communities and road users, based on PS5 requirements.
Community Safety of the OHTL: Key health and safety risks associated with high-voltage transmission lines include electrical shock, potential line failure, and exposure to electromagnetic fields, which require adherence to established safety distances. The right-of-way (RoW) for the existing Touba–Laboa OHTL was established approximately 13 years ago; however, some encroachment has been observed in proximity to nearby villages.
For the construction work of the new OHTL, the EPC contractor will request the CI-Energies to facilitate temporary access to the existing RoW. This access will be limited to the time necessary for the works, and land disturbance will be managed by an ad-hoc procedure (ESAP #9). CI-Energies will take control of the OHTL once the project construction is terminated.
Security Personnel: A permanent fence will be installed around the Project sites. Security and access control will be provided on a 24-hour basis by a third-party security company, retained by the EPC contractor during construction and by the Project during operations. Security personnel will be unarmed. The Project will undertake a Security Risk Assessment and develop and implement a Security Management Plan for both construction and operations, in line with IFC Performance Standard 4. The plan will include procedures for community engagement and communication to promote awareness and minimize potential conflicts (ref. ESAP #1). Security arrangements will be subject to regular monitoring and periodic audits as part of the Project’s overall E&S management and reporting framework.
PS5: Land Acquisition and Involuntary Resettlement
The Project land, composed of two sites covering 50 ha each, is made available by the Government of Cote d’Ivoire. The Laboa site is established on land that had been in the Government’s property for a long period of time, while the Touba site rights are held by CI-Energies and are being transferred to the State. The Project land was used for perennial and commercial agriculture (cashew and cocoa), as well as subsistence crops (e.g., cassava, pepper, and beans), hence there is economic displacement as a result of the change of land use
A cut-off date established in 2022 identified 44 project-affected persons (PAPs), including 13 PAPs for the Touba PV plant and 31 PAPs for the Laboa PV plant and the new OHTL. Economic displacement impacts on landowners and land users have been addressed through a Livelihood Restoration Plan (LRP) prepared by CI-Energies in 2023. The LRP includes measures such as: (i) agricultural support (improved inputs and training); (ii) support for livestock activities; (iii) business development assistance; and (iv) employment and skills development. The National Agency for Rural Development (ANADER) has been designated to support implementation of livelihood restoration activities.
CI-Energies prepared a draft LRP that has not yet been formally validated; as a result, compensation for loss of assets has not been completed and livelihood restoration measures have not yet been implemented. At the time of IFC’s due diligence, economic displacement had already occurred at the PV sites, with PAPs having vacated the land and relocated crops following instructions from local authorities.
To meet IFC Performance Standard 5, the Project will: (i) update the socio-economic baseline and asset inventory; (ii) review and update compensation rates, including disturbance allowances, based on current market values; and (iii) assess and update the LRP to ensure alignment with PS5, including provisions for financial literacy support and a completion audit. Following this, the Project will develop and implement a detailed LRP implementation plan and schedule, including a dedicated grievance mechanism for addressing land related issues. (ESAP #8)
To address potential impacts from associated or ancillary facilities not yet fully defined (e.g., access road upgrades and worker accommodation), the Project will develop a Land Acquisition and Resettlement Policy consistent with PS 5 to guide any future land acquisition and displacement (ESAP #9). Community consultations during appraisal identified legacy concerns related to outstanding compensation associated with the existing Touba–Laboa OHTL, constructed in 2014 by CI-Energies. While these issues are not attributable to the Project, they may present reputational risks and influence stakeholder perceptions. The Project will address these concerns through its Stakeholder Engagement Plan (SEP), including targeted communication to manage expectations (ref. ESAP #12).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Modified, Natural and Critical Habitats: The ESIA, including the Environmental and Social Vulnerability Assessment (ESVA), indicates that the Project footprint does not overlap with protected areas, Key Biodiversity Areas (KBAs), Alliance for Zero Extinction (AZE) sites, or Important Bird Areas (IBAs). Biodiversity surveys identified the presence of some IUCN Red List species. A rapid Critical Habitat Assessment (CHA) confirmed that no critical habitat is present, and key biodiversity impacts are characterized by loss of natural habitats in generally good condition, comprising a mosaic of semi-deciduous forest and savannah and potential collision of birds and electrocution on structures.
The EPC contractor will be required to develop and implement a Biodiversity Management Plan (BMP) consistent with the ESIA findings and applicable IFC PS 6 requirements due to potential bird collisions with wires and electrocution on structures. The BMP will include: (i) identification of key biodiversity features; (ii) mitigation measures for all Project phases (construction, operation and decommissioning); (iii) measures to address potential avifauna interactions with the OHTL (e.g., installation of bird diverters); (iv) a monitoring program with defined indicators; and (v) clear roles and responsibilities (ESAP #10). A qualified biodiversity specialist will be appointed to support implementation (ref. ESAP #3).
Construction activities for the OHTL will be scheduled to avoid bird breeding seasons, where feasible. During operations, biodiversity monitoring will include procedures to record incidental wildlife mortality and inform adaptive management.
Reforestation/Compensation: To offset the clearing of approximately 100ha for the two PV sites, the Scaling Solar Initiative supported the development of a Reforestation Action Plan to support the achievement of no net loss of biodiversity. The plan provides for the reforestation of approximately 120 ha, including 60 ha within classified forest areas and 60 ha on community lands and includes the use of native and threatened species identified in the ESIA. Implementation will be led by CI-Energies, with support from the national forest development agency (SODEFOR) and the Ministry of Water and Forests, with long-term management to be transferred to these entities.
As per ESAP #11, the Project will: (i) integrate the Reforestation Action Plan into the Biodiversity Management Plan (BMP); (ii) clearly define roles, responsibilities, and budget for implementation; and (iii) establish a monitoring framework with appropriate indicators consistent with IFC PS6. Land access for reforestation activities will be managed in accordance with the Project’s Land Acquisition and Resettlement Policy, and any land-related impacts will be addressed in line with PS5 requirements (ref. ESAP #9).
