This is a Category A project as per IFC's Policy on Environmental and Social Sustainability given that in South Africa, two operational wind farms, Golden Valley and Excelsior Wind, have the potential to impact sensitive bird and bat species, some of which trigger Critical Habitat thresholds, through collisions with turbines and collisions with and/or electrocutions on overhead transmission interconnection lines. (Biodiversity-specific risks are described in more detail in the PS6 section of the ESRS). In Poland, none of the following impacts are expected for the existing assets already in operations, nor for the proposed pipeline of renewable energy projects: a) involuntary resettlement, b) significant risks to, or impacts on the environment including biodiversity, or c) significant occupational health and safety (OHS) risks.

 PS 1 - Assessment and Management of Environmental and Social Risks and Impacts

Policy

At the corporate level, the Company has detailed E&S policies, which are applicable to all of Engie’s subsidiaries, mergers and acquisitions, new projects and contractors. The policies form an important component of Engie’s E&S management framework, which includes: a) Corporate Governance and Sustainability, b) Corporate Environmental Policy, which includes: Climate, Biodiversity, Water and Circular Economy policies (producing goods and services in a sustainable way and avoiding waste and residue generation as much as possible), c) Occupational Health and Safety, d) Corporate Social Responsibility and protection of Human Rights, e) Contractor and Supply Chain Due Diligence and Management, f) Stakeholder Engagement and Social Investment, g) Whistleblowing Policy and h) Human Resources and Code of Ethics.

To enhance the Company’s E&S policies at the corporate level vis-à-vis the IFC Performance Standards and to prevent any potential E&S impacts derived from land acquisition for new projects in the pipeline, the Company will, as part of ESAP #1, develop a “Land Acquisition and Resettlement Policy” (LARP) aligned with PS5 to be applied to all greenfield or acquired assets utilizing IFC proceeds. The LARP will include guidelines for a) stakeholder engagement and grievance management during land acquisition, b) screening, prior to project acquisition, for past land acquisition issues, c) assessment of potential impacts, d) compensation for assets at replacement value, e) Company’s role and approach in case of government expropriation, f) and development of ‘Resettlement Action Plans’ or ‘Livelihood Restoration Plans’ in case of economic or physical displacement. The LARP will focus on cases where government expropriation is an option and/or any restriction to access is identified; and will apply to any new or future project, asset, or acquisition, including Associated Facilities (as defined in PS1).

Environmental and Social Assessment and Management Systems

Engie implements an environmental and social management system which transfers corporate policies into protocols aligned with the United Nations (UN) Sustainable Development Goals, UN Declaration on Human Rights, ILO conventions and Country regulatory framework, as well as with the French Sapin 2 law requiring alignment with the Duty of Vigilance (on ethics and corruption) and the European CSR Directive.

The EHS component of Engie’s management system is based on ISO standards and is applicable to all the companies, projects and activities under the control of Engie. The Company’s Policies, EHS Group Rules and standards, and general organizational procedures are the foundation of the Integrated Management System (IMS) of the Renewables Global Business Unit (R-GBU) (updated in May 2023), which has been implemented across the Company. According to the information provided during appraisal, each country or local entity develops and implements its own management system in line with these set of policies and rules and based on country-specific E&S requirements.

Engie’s IMS integrates a social management process that initiates with a screening for risks and impacts to communities and includes a review of impact studies, stakeholder mapping and stakeholder engagement.  The results of the social screening are centrally reported and tracked and are a key part of a decision to proceed.   IFC’s E&S appraisal confirmed that Engie’s IMS is operational and aligned with the ‘plan-do-check-act’ cycle for continuous improvement, with indicators, targets and metrics that are reported to senior management, who are also actively involved in the determination of improvements plans, annual E&S plans and targets.

Identification of Risk and Impacts

The Company implements several instruments and tools at corporate and project level to identify and assess E&S risks and impacts throughout the different phases of development, implementation and operations of projects.  At corporate level, the Company has developed ‘Engie Group Rule 04 – Risk Assessment & Control’, which details the way that the risk identification and assessment process is conducted and how the corresponding EHS controls are established.

At country / project level, the Company, via its subsidiaries, conducts Environmental and Social Impact Assessments (ESIAs) for its projects as required by national law. In addition to this process, and as part of a projects’ early development stage, a high-level E&S screening of risks and impacts is conducted. The Company’s Corporate Social Responsibility (CSR) team implements a CSR matrix, called the ‘materiality matrix’ to assess potential E&S risks associated with the project or asset prior to investment. The risk and impacts identification process managed by Engie’s CSR team studies twenty ESG-related challenges, which are classified into four categories: a) environment, b) labor, c) social, and d) governance. The CSR risk screening process includes an assessment of biodiversity, air pollution, circularity of economy, labor risks including ethics and working conditions, stakeholder engagement and potential impacts to communities; responsible procurement; and any prior project-related controversies. Once the risks and opportunities are identified, the process moves to the ‘risk control phase’, where specific E&S actions plans are defined and developed for each phase of project development.

To enhance the E&S risks and impacts identification process in line with IFC Performance Standards, Engie will complement the CSR risk matrix screening processes (ESAP #2) with the following supplemental E&S considerations: a) a requirement to conduct an adequate alternative E&S analysis for the site selection process including any associated facilities (i.e. transmission lines, access roads, etc.), b) extend the current biodiversity screening and assessment of new projects to properly identify Alliance for Zero Extinction Sites or World Heritage Sites, (as per IFC PS6 standards, no CAPEX items funded by IFC can be undertaken in these sites), c) identify if a cumulative impact assessment, as per IFC PS1 requirements, might be needed, and d) in cases where local regulations may not require an environmental and social impact assessment due to potential limited impacts (e.g. new projects in areas where preexisting energy operations, small projects, substations, etc.), carry out and document an E&S impact assessment for internal use in line with IFC’s PSs and with due consideration of the WBG EHS Guidelines, supported by stakeholder analysis and management (stakeholder engagement plans and grievance mechanisms) commensurate with the E&S risks and impacts of the project. Understanding the E&S impacts of a project, regardless of the limited characteristics of these impacts, will allow Engie to define appropriate and commensurate E&S controls.

Management programs

The Company’s corporate environmental, social, health and safety (ESHS) management programs and plans are applied to all sites and projects from construction through operations and maintenance. These include prior analysis of environmental licensing and permitting requirements, E&S risk assessment, emissions control, solid and hazardous waste management, environmental noise assessment, emergency preparedness and response, workforce management, non-discrimination and equal opportunity, E&S trainings, EHS contractors management, community awareness, and stakeholder engagement. These programs and plans are aligned with local legislation as well as with IFC requirements as referenced in PS3 and PS4 below. They include details on monitoring actions, frequency of monitoring along with performance indicators and are reviewed and revised regularly.

Organizational Capacity and Competency

At the corporate level, Engie’s organizational charts demonstrate an adequate number of E&S positions to manage the ESHS issues during construction and operations of renewable assets. The Company’s organization includes staff at corporate level in charge of ESHS management, as well as dedicated staff at country and business unit level, including country HSE coordinators, asset HSE managers and personnel.  Interviews with E&S staff at headquarters and during the field visits undertaken as part of IFC’s appraisal revealed that E&S staff have the necessary expertise and competencies to develop and implement E&S plans to manage E&S risks and impacts of new and existing projects.

The E&S aspects of the assets in Poland are managed by the Corporate E&S team in Paris with the support of the project's operations team including the respective asset/project manager and internal EHS specialists based in country. In South Africa, the local E&S team is comprised of an Environment Social and Governance Director, a Senior Social Performance Manager, an HSE Team Lead, Environmental Manager, and Senior HSE Manager. This staff provides support to all the South African assets including Excelsior and Golden Valley.  Each site has an HSE Supervisor, Environmental Supervisor and Community Project Officers.

Emergency Preparedness and Response Plan (EPRP)

Engie has a Crisis Management Plan that describes the Company’s response to incidents and emergencies. Specific functions and responsibilities are defined for regional directors, country managers, country HSE coordinators, and asset HSE managers and personnel. In addition, the Company has an Emergency Preparedness and Response protocol that outlines the Company requirements for the EPRP that each project or site needs to develop. The protocol requires the definition of control plans, includes potential emergency scenarios, emergency contacts and communication flows (internal and with community leaders and government authorities), protocols for the use of equipment, and drills. To test the strength of the organization and to ensure continuous improvement, the entities carry out drills. Additional training sessions are also delivered to employees. An annual report is prepared so that lessons can be learned across the group.

Monitoring and Review

The Company has developed a corporate Vigilance Plan that covers all the measures established by Engie to prevent risks related to its activities and those of its controlled companies. It covers serious violations relating to human rights and fundamental freedoms, the health and safety of individuals and the environment. 

Engie has a successful program of internal audits (based on a risk profile) that assess OHS conditions, practices and performance across the board and on specific OHS subjects, focusing more on anticipating risks and implementing efficient preventive actions. The renewables GBU is required to nominate OHS experts for the assurance and oversight function to ensure compliance with OHS plans.  This team of experts verifies that the different standards, Group rules and procedures are properly applied at project level. Engie’s OHS corporate team also have an independent level of oversight in the overall performance of the Company.

To enhance the environmental compliance monitoring and identify opportunities for improvement, the Company will, as part of ESAP #3, define a similar program as the above mentioned OHS internal audits and undertake annual onsite environmental audits of each sub-project utilizing IFC proceeds to assess, monitor and measure the effectiveness of Engie’s E&S management programs, as well as compliance with any related legal and/or contractual obligations and regulatory requirements. The monitoring and review will also verify compliance and progress toward the desired outcomes of IFC Performance Standard 3, including the WBG EHS General Guidelines. If the internal audit identifies any environmental compliance gaps or the need for additional mitigation measures, Engie will document monitoring results and identify and reflect the necessary corrective and preventive actions in the amended management program and plans in a timely manner. 

Having an environmental monitoring and review program will support the continuous improvement cycle and bolster the “Avoid/Reduce/Compensate” principle that is a cornerstone of Engie’s environmental policy. The field-based environmental audit program will be risk-based, prioritizing projects and assets with a higher level of E&S risks or exposure, adjusting the frequency of onsite audits according to identified risks (i.e. if the initial audit does not identify major issues, the number of audits could be reduced).  

E&S Contractor Management

Engie has identified incidents involving Contractors as a key risk, therefore, a lot of focus is put on their E&S performance.  Engie implements an extensive due diligence for contractors, service providers and suppliers as part of the tender process, that allows the Company to assess and verify OHS, Corporate Social Responsibility (CSR) which includes Human Rights, such as child and forced labor, corruption risks and governance of prospective contractors. 

Several rules and tools (e.g. Group Rule 02 for health and safety with regards to contractors & subcontractors, minimum HSE requirements for projects and contractors, project contractor audit framework, contractor ID cards, H&S and O&M self-assessment for sites in operation) have been developed and are implemented to manage the E&S risks derived from contractors and contractors’ activities. E&S requirements and procedures are included in each contract. Contractors are required to adopt and implement the Company’s policies, standards and procedures. Engie’s rules, policies and procedures are applicable at corporate level and in all the countries where the Company operates, including Poland and South Africa.

PS 2 – Labor and Working Conditions

Engie has group-level Human Resources (HR) policies, which are broadly aligned with IFC PS2 and cover aspects such as hiring, rights, obligations (including non-discrimination and equal opportunities), freedom of association, prevention of child and forced labor, and working conditions. The principal documents regulating labor-related issues include a Diversity, Equity and Inclusion Policy, Sexual Harassment and Sexist Acts; Engie Group’s European Agreement on Professional Equality Between Men and Women; and Engie’s Ethics Charter and Practical Guide to Ethics which constitute Engie’s Code of Conduct.  Engie’s subsidiaries establish country- or asset-specific, policies aligned with the group-level policies that also comply with local regulatory requirements.  Engie’s HR policies apply to contractors and to a limited extent to the supply chain.  Ethics audits are conducted for all Engie subsidiaries.  Engie’s subsidiaries are required to adhere to local and national labor laws and, where worker protections are not adequate, will ensure the following minimum benefits: paid maternity and paternity leave, disability benefits, health insurance, and death benefit.

For the projects in South Africa a country-specific human resources policy has been developed as well as policies on Compensation for Occupational Injuries and Diseases (COIDA), Grievance Policy, Leave policy, Disciplinary code, Employee handbook, Study assistance policy HIV/AIDS and discrimination policy, prevention and elimination of harassment, and violence and discrimination policy.

Worker’s Organizations

Engie is a signatory to the Fundamental Conventions of the International Labour Organisation (ILO) that include the guarantee of freedom of association and the principles of collective bargaining. Both Poland and South African assets guarantee freedom of association while European legislation prevents tracking and reporting on number of unionized workers to ensure neutrality with regard to worker’s choice to join or not.  Engie forbids any discrimination based on union membership and respects and protects the autonomy and independence of trade union organizations and the right to organize, while complying with national laws and regulations in force.

Non-discrimination and Equal Opportunity

Engie’s Diversity, Equity and Inclusion Policy established at a corporate level in 2022, is rolled out across the group as Be.U@Engie, encouraging staff to “be you, be united, be unique”. The 5 pillars of the program include gender equality, respect for staff’s differing origins, inclusion of LGBTQ+ workers, as well as those with different abilities spanning all age groups. This policy applies to all direct and indirect workers. The policy prohibits, among others, discrimination on the basis of age, gender, sexual orientation, race, ethnicity, color, marital status and political orientation. 

Engie actively promotes gender parity through its Program 50-50.  The program includes equal remuneration for men and women, non-discrimination in recruitment, maternal leave, mentoring women, equal access to vocational training, transparency in remuneration, among other aspects. The program is reinforced through trainings, (such as on inclusive leadership). The program has set a target of 40 - 60% women in management positions globally by 2030, as well as gender salary equity with a difference of less than 2% and includes a program of proactive recruitment and advancement of female workers, training women in management positions applying also to its subsidiaries and starting with hiring women at management level.  In order to assess work conditions worldwide (including Poland and South Africa), data on gender parity is tracked, monitored and reported.

Gender-Based Violence and Harassment (GBVH)

Engie’s corporate approach to prevention of GBVH, and applicable to conditions worldwide (including Poland and South Africa), is governed by the Sexual Harassment and Sexist Acts, and is overseen by the Group Human Resources Ethics, Compliance and Privacy department. The guidance is implemented by individual country human resources’ departments, or by regional hubs where countries do not have a dedicated HR team, in alignment with local regulations.  The document outlines definitions of sexual harassment as well as procedures for preventing it that include raising awareness, training, incident reporting and survivor support.  In line with Engie’s pro-active promotion of women’s employment, Engie has developed a zero-tolerance policy on Preventing and Combating Domestic Violence. ENGIE implements a group-level whistleblowing system to manage complaints. Reports are reviewed and addressed every month in a dedicated committee involving Ethics and HR, under the supervision of the General Secretary. In addition to the ethics hotline, incidents of sexual harassment and/or abuse can be reported through the AlloSexism hotline, dedicated to GBVH.

Worker’s Grievance Mechanism

Engie’s human resources processes include a group-level whistleblower channel managed by Engie’s compliance unit, which focuses on ethical complaints, and which is aligned with its Ethics Policy. This process is available to all Global Engie employees globally, sub-contractors and suppliers. Grievances can be submitted anonymously with whistleblowers protected from retaliation. The South African sub-projects have developed and implemented a labor grievance redress mechanism which is broadly disclosed to workers.

At appraisal it was identified that in the case of Poland, in addition to the corporate tools already implemented, there is an enhancement opportunity (ESAP #4), related to the need for the Company to establish a Worker’s Grievance Mechanism (WGM) following national and IFC's PS2 requirements to be implemented on each sub-project in Poland where IFC proceeds will be used. The WGM will include: a) a mechanism to receive and handle grievances from workers, including those from migrant workers; b) the categorization of complaints by risk level and topic; c) tracking, monitoring and reporting, including KPIs. The WGM will be made available to all project workers, irrespective of their employer. The company will disseminate information and provide ongoing training about its use to the workforce, including contractors and subcontractors (in a language the workers understand). The WGM shall include specific considerations related to gender-based harassment/violence (GBVH) grievances. It will consist of multiple entry points to raise and address allegations, including options to report anonymously if preferred. The company will appoint an adequately trained grievance officer to coordinate the implementation of the WGM.

Child and Forced Labor

Engie, through an ethics clause, contractually prohibits child and forced labor in contractor’s workforce. These terms apply to contracts signed by subsidiaries with contractors and suppliers as outlined in Engie’s “General Terms and Conditions of Purchase”. The contractor must demonstrate compliance with these laws for 6 years prior to contract signing.  Compliance with these provisions is assured through monthly internal labor audits of all contractors. Failure to comply with these stipulations allows Engie and subsidiaries to terminate the contracts.  Particular attention is paid to contracts with suppliers providing goods and services with higher human rights risks such as solar and wind procurement.

Supply Chain

The following documents govern Engie’s supply chain management and alignment with France’s SAPIN II regulations: Vigilance Plan, Ethics Charter, Code of Conduct for Relations with Suppliers, Due Diligence Policy for Direct Suppliers and Subcontractors.  The requirements outlined in these documents apply throughout the supply chain, including to wind and solar components, and are incorporated in the standard Ethics and CSR clause found in all Engie’s contracts. The group’s supply chain CSR objectives are managed by the headquarter Procurement Department with Chief Procurement Officers at a Business Unit level reporting to them.

Engie’s Supply Chain Code of Conduct requires suppliers to comply with laws and regulations, as well as Company commitments including social responsibility, and avoidance of conflict of interest. Through a supply chain due diligence program, Engie has identified 250 preferred suppliers, and 1,350 major suppliers who are pre-vetted and approved. The Company’s procurement policy includes a supplier code of conduct to address and prohibit labor issues including child and forced labor with provisions for termination of contracts should a violation occur. Engie employs third parties, such as EcoVadis, and Aperio to conduct CSR assessments of key suppliers. EcoVadis’ assessment includes scoring on the company’s environment, labor and human rights, ethics and sustainable procurement. Engie has a set a target that 100% of its major and preferred suppliers will have an EcoVadis minimum score of 45/100 by 2030 – a score that, according to EcoVadis, indicates that CSR issues are being well managed. As part of its goal to decarbonize its main suppliers, Engie has set an objective of 100% of its preferred suppliers (except energy supply) being aligned or certified by Science Based Targets (SBT) by 2030.  

Engie implements an extensive due diligence for contractors, service providers and suppliers as part of the tender process.  The due diligence is conducted in two stages, an initial process is conducted at the country or regional level; if no red flags are identified the due diligence continues through the standard process. For country offices, if additional support or due diligence is required, the Paris corporate office can provide support. A red flag is automatically triggered for high-risk suppliers including solar and wind components, triggering Engie’s internal due diligence, third-party assessment and/or site visits, as required. As part of the due diligence, Engie requires a “bill of materials” – a list of all the material in the components. 

Occupational Health & Safety

In 2022, Engie and its subcontractors experienced severe work-related accidents. As a result, a major company-wide response and comprehensive action plan “ENGIE One Safety” was deployed to update all safety standards and procedures to ensure the application of the highest safety standards across the Group and its contractors. This action plan focuses on improving the safety culture and managerial leadership and promoting commitment and vigilance among all individuals to protect their lives and those of others. This plan is based on an in-depth assessment of employee and contractors’ OHS culture conducted in early 2022 by a specialized consultancy firm.

As a result, Engie now has a robust, well-structured, and sophisticated occupational health and safety management system which is based on ISO45001 standards and GIIP. The system encompasses all the activities carried out by employees, contractors and subcontractors and is heavily centered on ensuring high quality OHS training and competency of the workforce, particularly those involved in high risks activities. Engie follows country specific OHS and technical regulatory standards, and also implements a series of corporate actions, Group rules, programs and activities that go beyond legal compliance, foster safety culture and continuous improvement.

PS 3 - Resources Efficiency and Pollution Prevention

Resource Efficiency and Green House Gases (GHG)

ENGIE has set its corporate-wide carbon-neutrality target for 2045 on Scopes 1, 2 & 3 and aims to halve the carbon-intensity of the energy it produces between 2017 and 2030, and to avoid the emission of 45 million tons of CO2 by its customers. The Company has committed to: a) a GHG reduction plan; b) a climate vigilance plan; c) a natural resources consumption reduction program, and d) a business model adaptation program to make it resilient to climate change. In 2022 the GHG estimation for Scope 1 & 2 of the Renewables GBU was 71,100 tCO2eq. The GHG emissions from the Poland and South African assets will be included in the Company’s records once the acquisition is completed. An area of improvement that can support Engie’s efforts to reduce its GHG inventory is to include any GHG-related emissions from SF6, which is normally used in some equipment in substations. In this context, Engie will, as part of ESAP #5, develop an “SF6 management plan” to provide framework guidance on SF6 mapping, management, monitoring and reporting according to industry best practices to prevent and minimize risks and impacts. The Company will apply the SF6 management plan to the assets funded by IFC in South Africa and Poland.

Water & Wastewater Management

Engie has a Water Policy as a key element of its Corporate Environmental Policy. Engie reported during the appraisal that the Company is starting to calculate the water footprint for all its operations. The footprint assessment will be expanded to Poland and South Africa and included in the Company’s E&S reporting accordingly. Engie uses different water sources in the renewable energy projects, depending on the location of the assets and the available water supply alternatives. With regards to solar panel cleansing, the Company is exploring technologies for making panel cleansing more water efficient. With regards to wastewater, if municipal sewers are not available at any project location, systems to collect effluents and liquid discharges from facilities are installed and designed to provide treatment in line with local regulations and environmental permits. Quantities of wastewater used in the renewable projects that are already in operations is minimum. The environmental audit program described in ESAP #2 will help to monitor the compliance with these policies and with any related legal or permitting obligations and regulatory requirements.

Pollution Prevention and Control

Pollution prevention is part of the Company’s environmental management. Engie has developed and implemented different management and monitoring plans to ensure their activities are conducted to avoid or minimize adverse impacts on human health and the environment. This including areas under the Company’s direct control, and areas managed by contractors and subcontractors. As mentioned in ESAP #3, the Company will define an environmental assurance program to undertake annual onsite E&S internal audits of each sub-project utilizing IFC proceeds to assess adherence with applicable local E&S laws, with Engie’s corporate policies, and with the IFC Performance Standards and WBG EHS Guidelines. Any deviation from the standards or procedures or any opportunity identified during the regular audits and visits will cascade into further mitigation measures, ensuring that the objectives of PS3 are properly met.

Although most of the wind power projects in Poland and South Africa are located on agricultural land or very low density  areas with limited presence of environmental receptors, given the time elapsed for some of the wind power sub-projects that are part of the IFC financing, and the differences in standards and approach derived from local regulations over time, as part of ESAP #6, Engie will conduct a desktop review of potential operational impacts from environmental noise, ice throw and shadow flicker vis-à-vis the World Bank Group EHS Guidelines for Wind Energy. The assessment will identify current or potential wind turbines that could pose a risk or nuisance for project stakeholders and, based on the assessment, determine if further investigation (i.e. field environmental monitoring to confirm any findings) is merited, and/or if appropriate mitigation measures are required. The desktop review would be aligned with Engie’s vigilance plan that fosters a permanent monitoring of the right of local communities to a healthy environment, while at the same time ensuring that all IFC financed projects are compliant with the EHS Guidelines. For all future sub-projects considered for IFC proceeds, the Company will ensure that operational impacts are assessed, mitigated and managed in compliance with national standards, and IFC’s WBG EHS Guidelines as well.

PS 4 - Community Health, Safety, and Security

Risks and impacts to host communities of sub-projects and the public are individually assessed during the CSR screening process established by Engie and will be enhanced according to ESAP item #2 and #6 mentioned above. Based on the findings, appropriate mitigation measures will be defined and implemented during the design, construction and operation of each project needs.

Security Personnel

Both Polish and South African assets employ private security guards to secure the facilities. Three private security firms are employed for the Company’s Polish assets, with guards at 4 wind farms being armed. In South Africa, three different security firms are employed to guard all assets and are unarmed. Several South African assets have basic security management plans. Neither Polish assets, nor South African assets have signed MOUs with public security forces. Where possible, in both countries, sites are fenced, and there is restricted entry.

As part of ESAP #7, the company will develop and implement a Security Management Framework aligned with IFC PS4 outlining steps to be taken to minimize and manage potential risks to communities and individuals posed by the Company’s security arrangements. A Security Management Plan based on the Framework document and commensurate with risks and impacts, will be developed for each sub-project utilizing IFC proceeds. The Plans should be based on a security risk assessment and include: a) an overview of internal and external risks identified in the security risk assessment; b) mechanisms to screen and audit private security firms and guards; c) required training for security forces including use of force, human rights, and prevention of GBVH; d) definition of engagement mechanisms and coordination with public security forces when needed, and e) procedures for reporting, responding and documenting security incidents, and f) disclosure to communities. The sub-project's community grievance mechanism (further detailed in ESAP #12) will be available to members of the community or employees in the event of a security personnel code violation or other grievances related to security personnel. 

PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

Engie manages biodiversity impacts under an overarching corporate biodiversity policy, most recently updated in October, 2022. Specific objectives and targets for enhancement of biodiversity management systems are articulated in the Company’s Act4Nature commitments enacted in May, 2021. This policy is integrated into Engie’s CSR matrix and implemented by Engie’s CSR department, working in coordination with Engie’s R-GBU, as well as country-specific management teams.  

All of the Polish assets are located in modified habitat (mostly plowed crop fields with some quarry/mine areas) at sites widely distributed across the country.  None overlap or are likely to impact Key Biodiversity Areas (KBA) or legally protected areas, and none generate impacts to Natural or Critical Habitats, per PS6.  The two wind farms have been operational since 2009 (Tychowo) and 2013 (Kukinia) and completed three and eight years of post-construction bird/bat fatality monitoring, respectively. The Kukinia wind farm has committed to implement for the life of the project, a nocturnal cut-in speed curtailment regime from 20 July to 30 September each year to mitigate bat collision fatalities. As post-construction fatality monitoring has already been carried out in the past, the company will now implement a Wildlife Incident Reporting System on its Polish assets to document any chance find wildlife injuries or deaths that are observed at any of its solar or wind facilities per ESAP #8.

In South Africa, the three operational PV solar facilities are all located within the inland Nama Karoo biome and were developed in government-delineated renewable energy zones.  All three sites are located on flat, low-mid elevation plains that were previously covered by sparse, desert shrubland vegetation.  All three sites were used for low density livestock grazing prior to construction, and botanical baseline characterizations were used to avoid impacts to highly sensitive plants and microhabitats. Baseline ecological characterizations are consistent with the PS6 definition of Natural Habitat. Per ESAP #9, the Company will conduct an assessment to document the extent of loss and develop a strategy to achieve ‘no net loss’ of Natural Habitat in compliance with PS6. All three sites are located in close proximity to pre-existing transmission lines, with project-associated interconnection lines of 2.2 km (Prieska) or less. Two of the sites overlap Important Bird Areas (IBA)/KBA, as follows: Konkoonsies II overlaps the Mattheus-Gat Conservation area (IBA ZA025); and Aggeneys overlaps the Haramoep and Black Mountain Mine (IBA ZA026), and for this reason the identification of additional conservation actions will be factored into ESAP#9.

The two operational South African wind farms, Golden Valley and Excelsior Wind, have been developed and managed in adherence with South Africa’s renewable energy - biodiversity regulatory framework, following national guidelines promulgated by the South African Bat Assessment Association (SABAA for bats) and the Birds and Renewable Energy Specialists Group (BARESG for birds).

The Excelsior Wind Project is located in the wheat belt of the Western Cape Province, and includes a project-associated overhead transmission interconnection line of ca. 15 km.  The project is located inside of an IBA/KBA (Overberg Wheatbelt), and includes patches of Natural Habitat (Renosterveld shrubland) on rocky hilltops, though all Project infrastructure is sited in modified habitat (plowed wheatfields). The project is located in Critical Habitat for the following biodiversity values: Renosterveld vegetation, Black Harrier (IUCN EN, nationally EN), Cape Vulture (IUCN VU, nationally EN), and Blue Crane (IUCN VU, nationally NT).  The company has developed a Biodiversity Action Plan (BAP) for the Project and is implementing offset programs to create conservation gains for each of the CH receptors.  Per ESAP #10, the Company will consult with relevant stakeholders to update the BAP, including the associated offsets, other mitigation programs, and monitoring programs, as necessary, to achieve and document net positive gains for CH receptors.  

The Golden Valley wind farm is located in the Eastern Cape Province, on private ranch land used for domestic livestock production, and covered primarily by Natural Habitats including Bedford dry grasslands on the plains, with Great Fish Thicket shrub/woodlands on the slopes and on lower ground in the western portion of the area.  The project also includes an associated overhead transmission interconnection line of ca. 9 km. This project does not overlap or have potential to affect any legally protected areas or internationally recognized KBA and is not considered Critical Habitat.

Both of these wind farms have potential to impact sensitive bird and bat species through collisions with turbines and collisions and/or electrocutions on the project-associated overhead transmission interconnection lines, and both projects have implemented a series of impact mitigation measures, including observer-led shut down-on-demand curtailment for priority bird species, vulture food management programs, installation of bird flight diverters on project-associated overhead powerlines, installation of acoustic bat deterrent devices, and others.  Both projects have implemented bird and bat fatality monitoring programs following industry-standard protocols and effort levels and covering both the wind turbines and the project-associated powerlines, and both have developed Biodiversity Monitoring and Evaluation Plans (BMEP) describing these, and other biodiversity monitoring programs that are being implemented. Per ESAP #11 the company will enhance and expand these BMEP, transforming them into comprehensive operations-phase Biodiversity Management Plans (BMP) that describe a set of bird and bats mitigations and associated monitoring programs sufficient to achieve, and document satisfaction of the pertinent standard (“net gain” for CH triggering biodiversity receptors, “no net loss” for NH receptors, including collision impacts to non-CH birds and bats), in compliance with PS6.  

 Engie’s stakeholder engagement policy is based on the following documents: Engie’s group-level Stakeholder Engagement Referential and the CSR Matrix. Engie’s group-level stakeholder engagement policies are aligned with both the European Union (ESRS S3) and AA1000 Stakeholder Engagement Standard as well as Engie’s Environmental and Societal Responsibility Policy.  As part of early project screening, Engie conducts stakeholder mapping and screens for project-related conflict. In 2016, Engie set the target that by 2020 all projects would implement stakeholder engagement programs. Currently all medium to large projects must implement a Stakeholder Engagement Plan. By 2025 the policy will be enhanced to include all Engie sub-projects.  As part of Engie’s stakeholder engagement roll-out, over 700 staff members have been trained. The Referential requires that sub-projects first identify and then map stakeholders so that they are grouped and prioritized based on their level of influence on the project. Based on this initial effort the sub-project will define engagement efforts. Staff training needs for staff are also assessed to ensure capacity for robust engagement. To complete the process, the sub-project must develop and implement a Stakeholder Engagement Plan that will include monitoring and evaluating the process as well as internally and externally reporting.

Polish sub-projects conducted stakeholder engagement initially with commune members at meetings, and where relevant, through disclosure of the ESIA. The South African sub-projects have well-developed stakeholder engagement plans as well as a community grievance mechanism.  Meetings are held with representatives from four municipalities at least quarterly. Projects have a social investment program aligned with the South Africa’s National Development Plan with education as a specific focus area.

Engie has developed a whistleblowing system that is available to stakeholders of the Group and managed by an external service provider. The system is intended for the reporting of any actions, events or behavior that could affect the integrity and/or the rights of individuals, Engie’s operations, or have serious consequences in terms of liability (health/safety, environment, human rights, labor and trade union rights, respect for people, privacy, etc.). The anonymity of complaints is assured when made anonymously as is freedom from retaliation.

As per ESAP #12, for all sub-projects to be developed utilizing IFC proceeds in Poland, the company will apply its Stakeholder Engagement Referential to include the development and implementation of project-level Stakeholder Engagement Plans (SEP) to meet PS1 requirements, including a formal community grievance mechanism that includes methods to: a) communicate the grievance mechanism to stakeholders; b) receive and register complaints; c) screen, assess and address issues raised; d) document and track grievances; e) provide feedback to stakeholders on grievance mechanism results; and f) monitor and adjust the management program including defining key performance indicators (KPIs), as appropriate.                                                  

 Contact Person:  Anne-Sophie Quelin

Company Name: Engie S.A.

Address:  Tour T1, 1 place Samuel de Champlain, Faubourg de l'Arche, 92930 Paris La Défense Cedex,

Email:  anne-sophie.quelin@engie.com

Phone:  +33 (0)1 44 22 00 00