Based on IFC’s review of the project PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable as all the sites are located in mining areas with little or no remaining vegetation and modified habitats only. There are no critical habitats or legally protected and internationally recognized areas in the vicinity of the sites. PS7: Indigenous People is not applicable as there are no indigenous peoples in the project area; and PS8: Cultural Heritage is not applicable as the project is not located in an area of known historical or cultural significance and does not impact any known cultural heritage.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the Environmental and Social (“E&S”) impacts associated with the project are limited, generally project-specific and can be addressed through the implementation of good international industry practices.  Furthermore, it is possible to design and implement engineering and management measures to mitigate adverse impacts during construction and operation.  The environmental and social risks are moderate to minor and for those that have been identified, the OCPs ESMS, JESA HSE oversight and contractor management and the agreed Environmental and Social Action Plan provides appropriate mitigation.                                                  

OCP has developed a group level ESMS structure aligned to ISO 14001:2015 requirements. Each site whether operational or under development is required to develop and implement an ESMS following this framework. JESA has developed a HSE Project Execution Plan which incorporates OCP policy requirements and sets out the HSE management system to be implemented for the construction phase. This includes procedures to guide the selection process (e.g., pre-qualifications, request for proposal, evaluation, selection, contracting) and performance monitoring throughout the life of the contract (e.g., pre-mobilization, mobilization, project completion and demobilization) of the construction contractors. JESA has also drafted a set of minimum HSE requirements, which will be included in the request for proposals and in the draft contract for the construction contractors. Collectively the OCP and JESA requirements will be referred to as the project requirements. The sections below detail the ESMS as applied to the project during the construction and operations phase.

Policy: OCP has in place a formal sustainability strategy, supported by several group level policies (last updated in April 2020) including sustainability, environmental management, and occupational, health and safety (OHS). Each policy describes OCP’s commitments, along with the implementation, compliance, governance, and monitoring, reporting and review mechanisms.  These policies apply to all OCP sites and facilities including this project and are publicly disclosed on OCP website: https://www.ocpgroup.ma/sustainability/policies-and-standards. 

Identification of Risks & Impacts: Site selection was done as part of the pre-feasibility studies. Several criteria were considered in the selection of the sites, including the nature and use of the land, risk of flooding, ease of access, proximity to the grid, etc. OCP has undertaken EIAs in accordance with Moroccan legislative requirements for the Khouribga and Benguerir solar areas and cover the four selected sites and all the components including ancillary facilities, access roads and OTLs. The EIAs are generally in line with IFC PS requirements. The main impacts identified include contamination of soil and water resources, air and noise pollution, vegetation removal, waste management, increased traffic and loss of access to land, during construction; and water use (due to general water scarcity in the area) and waste management, during operations. Main positive impacts include employment opportunities and electricity production from renewable energy.  The EIAs include regional socio-economic baseline data and additional work will be undertaken to better understand current land use at the sites and assess and mitigate impacts related to economic and limited physical displacement as per IFC PS5 requirements. This is described in detail under PS5.

Furthermore, according to the project requirements, the construction contractors will undertake a HSE risk assessment for construction activities, identify suitable control measures and develop and maintain a risk register.  All task specific hazards will be managed using a Job Hazard Worksheet prepared following a Job Hazard Analysis (“JHA”) to be undertaken by the contractors prior to initiating any activities.

Management Programs: The project EIAs include framework EMPs, which provide the organizational structure for E&S management, mitigation measures and monitoring requirements applicable to the construction and operation phases of the project and are generally aligned with the WBG Environment, Health and Safety (EHS) Guidelines. The construction contractors and the operator will develop a Construction Environmental Management Plan (“CEMP”) and Operation Environmental Management Plan (“OEMP”), respectively, based on the framework EMP and in alignment with IFC PSs and WBG EHS Guidelines. (ESAP # 1).  These plans will be supported by a number of associated “sub” plans including: emergency preparedness and response; labor management; health and safety; waste management; spill prevention and response; traffic management; and stakeholder engagement (including grievance management).  Additional details about these associated plans and what they should include are provided in the applicable Performance Standard sections of this ESRS that follow.  

Organizational Capacity & Competency: Both OCP and JESA have strong capabilities to manage a range of HSE and OHS issues as well as understanding of IFC and international best practices provisions and standards.

OCP has a Risk Management Team, which, under the supervision of the Audit and Risk Committee, carries out identification, analysis, and evaluation of risks including E&S risks and integrates them into the management plans of each business line in accordance with ISO Risk Management standards. In 2019, OCP created Sustainability Platform (“SP”) to coordinate and supervise implementation of the sustainability strategy as well as to discuss, co-create and initiate new ideas. The SP coordinates and supervises implementation of the sustainability strategy in cooperation with other departments such as Human Capital, Industrial Operations, Industrial Developments, etc. SP also oversees community engagement, compliance and sustainability external engagement. OCP also has “Health and Safety at Work” entities both at the group level and facilities level. The group level entity is responsible for structuring and leading the OHS management through the definition of standards, management system, processes, skills, best practices and modes of governance as well as supporting the facilities. The facility level entities are responsible for implementing HSE policy and standards, supporting the respective facilities in the deployment of the HSE excellence program and HSE projects.

During the construction phase, JESA will have a construction management team based at Khouribga and Benguerir sites. The team will be led by a Site Manager and will include a HSE Manager responsible for overall HSE management and performance, supported by a team of HSE personnel to monitor, act and report on the activities of the construction contractor. Additionally, at each site, the construction contractors will be contractually required to have a HSE person on-site supported by a team of HSE supervisors (see PS2 section for more information). Similar arrangements, tailored to fit the operations requirements will be put in place during the operations phase.

The project will finalize or establish the HSE organogram for the construction and operations phases of the project, respectively. (ESAP #2). Appointed personnel will have adequate qualifications and experience, including knowledge of international requirements and best practice.  As per the project requirements, the contractors will be required to set up and implement an appropriate HSE induction and ongoing training program for all workers.

Emergency Preparedness & Response: OCP has a corporate standard on emergency response planning. All facilities in Morocco have a Plan de Gestion des Crises (Crisis Management Plan) in place. For the project, JESA has developed an Emergency Preparedness and Response (“EPR”) Plan that sets out the emergency situations (fire, explosions and natural hazards), organization responsibilities and response requirements.  In line with the project requirements, the project EPR and in accordance with the IFC PS1 and PS4 provisions, an on-site ERP will be prepared for both the construction and operation phases of the project (ESAP # 3).  The response plan will include a communication protocol to alert local authorities, as well as the management team in addition to specific responses and evacuation procedures. Regular drills and emergency training and exercises will be developed covering the different emergency scenarios. Required number of fire extinguishers will be provided, together with fire buckets and automatic fire detection system will be made available at the entire PV array area, inverter stations, main control room and switchyard during operation.

Monitoring & Review: OCP has corporate standards on environmental performance monitoring and HSE performance control, audit and safety observations. Based on appraisal observations and document review, all facilities conduct regular environment and OHS monitoring.  OCP publishes an annual sustainability report, for which, the Global Reporting Initiative (GRI) provides assurance as per GRI requirements covering corporate’s sustainability performance during the financial year. Additionally, OCP discloses performance data / factsheets on specific E&S topics (https://www.ocpgroup.ma/performance-data) including on environmental management (e.g., air emissions, effluents, waste, climate, water and energy), human capital management (e.g., human capital, OHS, freedom of association, COVID19 response) and community engagement. Going forward, E&S performance data of the project during the construction and operation phases will be included in the sustainability reporting.   

As part of its project management system, JESA has outlined specific processes to monitor and measure the effectiveness of their and their contractor’s management plans / programs as well as compliance with relevant Moroccan legal requirements. JESA will draft monthly progress reports based on the review of the construction contractor reporting requirements including, the contractor’s progress reports, on-site inspections of the project in accordance with GIIP, and information provided by the contractor from time to time. As per the project Requirement’s, the construction contractors will develop and report on a minimum set of Key E&S Performance Indicators (“KPIs”) (ESAP # 4).

Supply Chain: JESA has a supply chain Code of Conduct prohibiting forced labor together with HSE requirements, as well as a supplier Capability Assessment procedure that includes labor and HSE provisions. The Code of Conduct is annexed to all JESA contracts. In addition, the general terms and conditions of JESA’s contracts requires that any supplier adheres to all applicable HSE laws/regulations, and JESA’s HSE policies and procedures. JESA will implement these requirements at the project level.                                                  

The project is expected to employ up to 450 workers at the peak of the 12-month construction phase of each plant. A majority of these workers will be employed by the construction contractors and sub-contractors and are likely to be sourced from Morocco.  Some expatriate staff may be retained for project management and specialized construction related work.  There are high expectations of employment opportunities amongst the local communities; therefore, JESA will work with the construction contractors and the local communities to ensure that local recruitment is maximized and equitable to the extent possible.  Up to 20 workers will be employed during the O&M phase of the project.

Human Resources Policies and Procedures: OCP has publicly disclosed corporate policies on general human rights, general human capital, social dialogue, diversity, and inclusion and working conditions. These policies describe OCP’s commitments, implementation, governance responsibilities, reporting and review mechanisms. The working conditions policy includes a commitment to the eight International Labour Organization (“ILO”) core conventions. This includes freedom of association and effective recognition of the right to collective bargaining, elimination of all forms of forced or obligatory labor, effective abolition of child labour, and elimination of discrimination in employment. The policy also has specific commitments on working time, remuneration, physical and mental working conditions, social dialogue and retirement. OCP’s corporate policies are aligned with PS2 requirements and are applicable to the construction and O&M phases of the project.

Guided by the project requirements and consistent with the requirements of Moroccan law and PS2, each construction contractor and operator will develop (i) Policy statements on non-discrimination and equal opportunity, prevention of child labor and forced labor, freedom of association and sexual harassment; (ii) a set of Human Resources (“HR”) procedures including local recruitment, with provisions for increasing gender equality; worker induction; disciplinary requirements (including in relation to sexual harassment); and demobilization of the project workforce following completion of construction (iii) Workers Code of Conduct to account for respectful worker behavior including in host communities and zero-tolerance provisions against sexual harassment; (iv) Labor Grievance Mechanism; and v) a set of working conditions and terms of employment.   These HR policies and procedures, Code of Conduct, Labor Grievance Mechanism and working terms and conditions will apply to all project workers including those employed by any sub-contractors and be made readily accessible and clearly communicated at induction and through the provision of additional sensitization and training. (ESAP # 5). 

JESA will put in place appropriate monitoring requirements including third-party audit procedures to ensure that the construction contractors and their sub-contractors maintain statutory compliance with Moroccan law, the labor requirements, and PS2 provisions. (ESAP # 6).

Working Conditions and Term of Employment: The project will ensure that all employee contracts are consistent with Moroccan law and IFC PS2 requirements.  All employees (including those employed by contractors and subcontractors) will be provided with a contract in French/ Arabic, stipulating their terms of employment, working conditions (including health and safety requirements), wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, vacation, holidays as well as other leaves stipulated by national legislation.  Contracts of the construction phase workers shall have a clear description of the short-term nature of the project and provide an indication of the potential employment duration.

Workers’ Organization: As per the project requirements, contractors will develop a project specific policy statement ensuring that the project will not in any way prevent workers from seeking to join unions and other workers’ organizations and bargain collectively. 

Child and Forced Labor: The project will ensure that no child or forced labor will be used by the project at any time.  As per the project requirements, the contractors will ensure adequate contractual provisions are in place, such as proof of identification and age, with their contractors/suppliers.

Workers Accommodation: No labor camp is proposed under the project as the majority of the contractors labor force is expected to be hired from the nearby villages and towns.  Other workers including skilled labor and project management staff, who may come from outside the project area will be housed in rented accommodation. OCP will develop a transportation management plan to address the risks associated with transporting equipment and workers to and from the worksite (ESAP # 10).

Grievance Mechanism: Through its corporate policies on social dialogue and diversity and inclusion OCP has committed to implement grievance mechanisms across all OCP Group operations which are accessible, available in the local language of each location in which it operates and explained to employees. As per the project requirements, the contractors will develop and implement a labor grievance mechanism in line with the corporate policies and aligned to PS2 requirements. The mechanism will be accessible for construction workers including those employed by subcontractors and allow for anonymous and confidential filing and management of complaints including in relation to sexual harassment. The contractors will ensure communication of the grievance mechanism to all employees and contract workers.

Occupational Health and Safety: Key OHS risks for a PV project include slips and falls, potential hazards from on-site moving machinery, heavy load lifting, traffic accidents, exposure to electric shocks and burns, and safety issues related to panels module assembly. To manage these risks, guided by the project requirements and in line with IFC PS2 and relevant WBG EHS Guidelines, the construction contractors will develop a Health and Safety Plan covering key aspects such as: Job Safety Analysis and Risk and Hazard Assessment and associated management procedures for work activities; Protective Personnel Equipment (“PPE”) requirements; Permit to Work System; Lock Out-Tag Out System; OHS signage requirements; medical support requirements; rest and sanitary facilities; actions and procedures related to COVID-19; training requirements, including at induction and repeated/refresher Toolbox Talks; roles and responsibilities for implementation of plan; incident recording and investigation; performance monitoring; etc.  The contractors will also be contractually required to deploy a suitable number of appropriately qualified Health and Safety supervisors for effective supervision of compliance with the contractual provisions relating to OHS requirements.  A Health and Safety ealth Hplan and associated procedures will also be developed for the operations phase by the operator (ESAP # 7). 

Resource Efficiency – Greenhouse Gases: Greenhouse gas emissions (“GHG”) from the project during construction, are expected to be minimal and predominantly associated with the use of fuels such as in generators, transport, on-site equipment, and machinery.  Although the quantities of emissions have not been calculated, these are expected to be low and significantly less than 25,000 tones CO2 equivalent (tCO2eq/year).  The project is expected to generate approximately 424.4 gigawatt hours (GWh) of electricity per year, resulting in a predicated annual GHG reduction of 285,216 tCO2eq/year.

Resource Efficiency – Water Consumption & Availability: For the construction phase, it is estimated that approximately 80 m3/day of water, would be required for civil works and domestic use at each site. For the operations phase, it estimated that around 4033 m3/year (an average of 60 m3/year/MWp) and 8155 m3/year (an average of 60 m3/year/MWp) of water will be required for wet cleaning of the solar panels at the Benguerir and Khouribga plants respectively.  Water used for wet cleaning will be supplied by trucks from the Khouribga and Benguerir wastewater treatment plants and stored in tanks at each site. No water will be sourced from boreholes or other surface water sources. The domestic water needs during operations, estimated to be 100 l/ day, will be met via piped connections from either the OCP water network or the municipal network. The water needs of the project constitute a less than 1% of the total water requirements related to the mining and processing activities in each mining area.

Pollution Prevention – Waste: The EIA identified waste streams generated during the construction and operational phases. The overall volumes of both solid and hazardous waste generated by the project during both phases are expected to be low.  It is anticipated that the project will produce both non-hazardous wastes, such as paper, wood, plastic, scrap metals and glass, and a limited quantity of potentially hazardous materials such as transformer oils, lubricants, paints, batteries, etc. as well as some electronic waste. Furthermore, leaks from contractors’ vehicles and equipment may impact the soil/subsoil. 

The project will develop a Waste Management Plan for the construction and operations phase, aligned with local legal requirements, the EMP, project requirements, and IFC PS3 and WBG EHS general provisions (ESAP # 8).  The waste management plan will commit to the reduction of wastes whilst maximizing the re-use and recycling of materials and will outline the process for appropriate waste segregation, storage, transportation and disposal.  The plan will also include specifics for management of broken, expired or surplus PV panels, address local requirements for the designation of a hazardous storage area, provide details on hazardous waste disposal solution(s) in line with good international industry practices (“GIIP”), and includes provisions to ensure hazardous waste contractors are licensed from the relevant authority. The project will also develop a spill prevention and response plan commensurate with the potential risks present at the site.  This will address the prevention and control of releases and accidents (ESAP # 9).

Wastewater will be collected in impermeable tanks and transported by a licensed contractor to the wastewater treatment plants. 

During the operational phase, no environmental pollution impacts of effluents are anticipated with the exception of wastewater, primarily derived from panel cleaning, and regular household waste generation.  The company will implement pollution prevention measures in accordance with national law, IFC’s PSs, and project EIA provisions.                                                   

 Community Exposure to Disease: All the sites are located in rural mining zones which have been operational for decades. Aside from a few dwellings on the Ouled Fares site and a shepherd’s hut on the Benguerir site (see PS5 section), the other two sites do not have any habitation. There are scattered dwellings and settlements located in the surrounding vicinity of all the sites, all within the mining zones. The nearest cities are Khouribga and Benguerir located around 5 km and 8 km from the respective mining areas.  The growth of these cities has been partially linked to the development of the mines. The impact due to the influx of a construction workforce in the area is likely to be relatively small. The project intends to maximize recruitment from local communities to the extent possible. Workers who come from outside the project area will live in rental accommodation available in the two nearby cities, with contractors providing transport to and from the site. As per the project requirements, the contractors will be required to have a worker Code of Conduct, adequate health and safety controls including related to COVID-19, and onsite medical facilities for all workers. These measures are deemed sufficient to manage the risks to the community as a result of exposure to disease.

Road Safety & Traffic Management: During construction, the dominant vehicle movement patterns will be in relation to the transportation of construction workers on a daily basis over the 18 months construction period and material and equipment at defined periods.  Increases in traffic related to the project may represent a safety risk for the other road users and communities adjacent to the roads being used. Whilst the EIA has quantified transport movements in the immediate vicinity of the project area, it does not adequately identify the transportation routes used to bring in equipment and workers, the baseline conditions and the associated impacts and mitigation. The project shall undertake a Transportation Risk Assessment and guided by the findings, develop a Project Traffic and Transport Management Plan (ESAP # 10).  The plan will define transport routes to be used for equipment deliveries based on the risk assessments undertaken to evaluate road traffic and conditions with aim of minimizing impacts.  It will also define a safety inspection program for project (especially for local subcontractors) and implement ongoing monitoring of vehicles and proper use of safety measures.

Security Personnel: The sites are located in mostly unfenced mining zones. A permanent fence will be erected around the perimeter of the sites.  Security and access control to the site will be provided on a 24-hour basis by a third-party security company retained by the contractors/ operator.  Security guards will not be armed.  Many of these guards are expected to be hired from the local community. OCP maintains good relations with households and settlements found within the mining zones and is committed to managing the project’s use of and relationship with third-party security personnel to ensure that security provision is managed properly to safeguard both the security and human rights of communities, workers, and other stakeholders impacted by its operations, in line with PS4 requirements.  To enable this, OCP will document a specific security management policy consistent with PS4 requirements including IFC’s “Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts” which will include the Code of Conduct, gender-based violence (GBV) aspects and implement clear guidelines on use of force as well as processes on background checks of the guards. The policy will be contractually binding for the private security provider and communicated to the security guards as part of the induction, as well as refresher training. In addition, the community grievance mechanism (discussed under stakeholder engagement) will also allow for complaints related to security forces including in relation to GBV (ESAP # 11).                                                  

OCP has group level policies on community engagement and responsible local community relations. In 2018, OCP launched a platform - Act4Community, to create a relationship of trust with local communities and mobilize employees for community engagement. It is led by dedicated teams from each operational facility and volunteer employees who can donate up to 30 days of their time. The platform relies on thematic workshops, door-to-door engagement, trade forums and meetings with targeted stakeholders (local associations, communities, local authorities, projects owners, etc.).

OCP has developed a Stakeholder Engagement Plan (“SEP”) in line with IFC PS 1 requirements and has undertaken a round of stakeholder engagement activities in September and October 2022, to disclose the project and the EIA findings to the nearby communities and households. Issues raised during these engagement activities relate to equitable access to employment and other economic opportunities, and consideration of corporate social responsibility programs. The SEP has outlined further stakeholder engagement activities linked to specific project milestones for OCP to implement. A full time Community Liaison Officer will be retained at each site to manage stakeholder relations between the project and the communities and to support the project’s social manager.

Community Grievance Mechanism (“CGM”): OCP has established an independent Ombudsman platform (https://www.ombudsman-ocp.org/en), which is an independent institution, neither reporting to nor structurally affiliated with any legal or administrative compliance department that exists in OCP’s organization. The aim of the Ombudsman Office is to process and examine claims and recommend fair solutions to parties with the objective of reducing disputes between OCP and its partners. The Ombudsman will also provide mediation when required and identify interaction opportunities between OCP group and its stakeholders. In addition, at each facility level, grievances are received (either oral & written complaints) that are processed according to the complaint type; and integrated in the agenda for facilities’ management meetings. In order to answer the environmental grievances received in the past years, OCP has organized approximately 30 meetings on-site with local NGOs through site visits and open house days since 2019.

The SEP has provided an outline of a CGM that allows for submission and management of grievances (including the lodging of anonymous grievances), reporting, and feedback loops.  The project will establish and maintain a site level CGM and registry prior to the start of the construction phase and for the duration of the project in line with PS1 requirements (ESAP # 13).  The Community Liaison Officer will also serve as a grievance officer and will act as the interface between construction contractor and the local stakeholders on community matters including the recruitment of local workers and management of grievances as a result of the construction contractors’ actions and activities.                                                                                                   

 Mr. Hassan Kaddouri  

OCP Green Energy

Lot 660, Hay Moulay Rachid, 43150, Benguerir – Maroc

Tel: +212 (0) 522 22 20 25

FAX: 05 25 07 31 34