48265 - EDP UCL LAC

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Environmental & Social Review Summary

Project Number

48265

Company Name

EDP, S.A.

Date ESRS Disclosed

Jan 16, 2025

Country

Latin America and the Caribbean Region

Region

Latin America and the Caribbean

Last Updated Date

Aug 6, 2026

Environmental Category

B - Limited

Status

Pending Approval

Sector

Renewable Energy Holding Companies

Industry

Infrastructure

Department

Regional Industry INF LAC & EUR

Project Description

EDP, S.A. (“EDP” or the “Company”), is a global energy company domiciled in Portugal. IFC’s proposed financing consists of a 7-year unsecured corporate loan of up to US $222 million to EDP. The proceeds will be primarily used to support the Los Cuervos solar park in Mexico managed by Parque Solar Los Cuervos S. de R.L. de C.V. (the Project Company), a Mexican special-purpose company owned by EDP.
Los Cuervos is a 200 MW solar PV power plant located in Aguascalientes, Mexico, at a site leased from three different “ejidos”, which are communal lands. It was developed and built by means of turn-key engineering, procurement, and construction (EPC) contract. Operations and maintenance (O&M) are managed by a third party through an O&M contract. The project reached commercial operations in 2023 and operates a substation as well as an overhead transmission line (OHTL), with lease contracts for the rights of way from ejidos (~3 km). Los Cuervos is not located within Legally Protected Areas or (LPAs) or Key Biodiversity Areas (KBAs). Workers travel to the project from Aguascalientes city or neighboring towns.

Overview of IFC's Scope of Review

IFC's appraisal of the proposed investment comprised a review of project-specific and corporate-level environmental, health, safety, and social (E&S) information such as EDPR’s 2023 and 2025 Annual Report (shttps://tinyurl.com/drtjskm4, https://edpr-investors.com/sites/edpr-investors/files/document/2026-02/EDPR_IntegratedAnnualReport.pdf), E&S assessments, and managements plans, and human resources (HR) policies and procedures. The appraisal included discussions with EDPR’s corporate-level E&S staff in Madrid, Spain, in July 2024, an in-person appraisal visit to the Los Cuervos project in July 2024, including meetings with EDPR’s in-country personnel, contractors, and local stakeholders, and update virtual meetings in July 2026.

E & S Project Categorization and Applicable Standard

While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources

Environmental and Social Mitigation Measures

Stakeholder Engagement

EDP has a comprehensive corporate Stakeholder Engagement Policy (https://tinyurl.com/EDP-SEP) and procedures outlining principles for identifying and engaging stakeholders. Los Cuervos has a Stakeholder Engagement Plan (SEP) that includes stakeholder consultations and community meetings to consider concerns and suggestions and agree on social investment programs. As per ESAP #7, Los Cuervos will update its SEP in alignment with

PS1, including roles and responsibilities, stakeholder mapping, gender and age group disaggregation, analysis, and prioritization (including Vulnerable Groups, women, children), type of engagement (with specific consideration for Vulnerable Groups, women, and children), frequency of consultation, monitoring KPIs and reporting.

Los Cuervos has a formal grievance mechanism with different channels such as telephone, email, and meetings. As part of ESAP #7, Los Cuervos will update its GMP in alignment with PS1, including a process to evaluate grievances related to access to ejido communal land, determine eligibility of the grievance, and if found eligible, make targeted benefits available to the grievant(s).

Broad Community Support

Environmental & Social Action Plan

S.no	Description	Anticipated Completion Date
1	Los Cuervos will: (i) document a site-specific integrated E&S audit schedule (addressing environmental, social, OHS, and E&S contractor audits); and (ii) develop an additional E&S monitoring KPI to track water consumption. These deliverables will be consistent with applicable legal requirements, E&S authorizations, IFC PS, and relevant WBG EHS Guidelines.	01/30/2027
2	Los Cuervos will develop and implement the necessary site-specific HR related procedures appropriate to its size and workforce. The procedures will include a description of working conditions and requirements for staff and contractors, ensuring compliance with IFC PS2, local labor regulations and EDPR’s policies regarding freedom of association and collective bargaining, prohibition of child and forced labor, terms and duration of the employment relationship, wages and benefits, wage calculation and pay slips, working hours, overtime, rest days, breaks, deductions, working conditions, termination procedures, health insurance and pension. These procedures will be written in such a way as to be easily understood by workers and will be communicated during inductions and annual refresher training.	01/30/2027
3	Los Cuervos will implement a Grievance Management Procedure (GMP) applicable to workers (including contractors), in alignment with PS2 to: (i) document that there are multiple accessible channels for reporting grievances (e.g. online, phone call, email, letter, and in person); and (ii) to ensure gender-based violence and harassment (GBVH) grievances are adequately addressed with a survivor-centered approach, managed by a designated team that has received specific GBVH training.	01/30/2027
4	Los Cuervos will develop a water efficiency plan, consistent with the IFC PS and relevant WBG EHSGuidelines.	01/30/2027
5	Los Cuervos will update the Emergency Preparedness and Response Plan (EPRP) to formally define how they assist and collaborate with the Affected Communities, local government agencies, and other relevant parties, (including but not limited to the hazard of wildfires).	01/30/2027
6	Los Cuervos will develop and implement security management protocols, aligned with IFC PS4, and all security personnel will comply with the principles of conduct outlined in those protocols.	01/30/2027
7	Los Cuervos will update their site-specific Stakeholder Engagement Plans (SEP), in alignment with PS1, including roles and responsibilities, stakeholder mapping, gender and age group disaggregation, analysis, and prioritization (including Vulnerable Groups, women, children), type of engagement (with specific consideration for Vulnerable Groups, women, children), frequency of consultation, monitoring KPIs and reporting. The SEPs will also document a PS1 aligned stakeholders Grievance Management Procedure (GMP). The GMP will include periodic disclosure and socialization of the mechanism to Affected Communities. Los Cuervos will update its GMP, in alignment with PS1, to ensure that (i) it is culturally adequate, gender sensitive, and responds to the local communities’ needs and resources, and (ii) it evaluates grievances related to access to ejido communal land, determines eligibility of the grievance, and if found eligible, make targeted benefits available to the grievant(s).	11/30/2026

Client Documentation

File Name	Actions
EVIS Los Cuervos.pdf
Capitulo I MIA Cuervos rev.pdf
Capitulo II MIACuervos rev.pdf
Capitulo III MIA Cuervos rev.pdf
Capitulo IV MIA Cuervos rev.pdf
Capitulo V MIA Cuervos rev.pdf
Capitulo VI MIA Cuervos rev.pdf

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.

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Environmental & Social Review Summary

Project Description

Overview of IFC's Scope of Review

E & S Project Categorization and Applicable Standard

Environmental and Social Mitigation Measures

Stakeholder Engagement

Broad Community Support

Environmental & Social Action Plan

Client Documentation

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Environmental & Social Review Summary

Project Description

Overview of IFC's Scope of Review

E & S Project Categorization and Applicable Standard

Identified Applicable Performance Standards

Environmental and Social Categorization and Rationale

Environmental and Social Mitigation Measures

Environmental and Social Mitigation Measures

Stakeholder Engagement

Stakeholder Engagement

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