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
Policy, E&S Management System and Assessment and Management of Risks and Impacts: The Group identifies and manages E&S risks and impacts associated with its investments through compliance with applicable national standards and E&S regulatory permits and requirements. Going forward, Duval will formalize and implement a Company level E&S management system (ESMS) aligned to IFC PS 1 requirements (ESAP #1).
In accordance with Ivorian legislative requirements, Duval commissioned an Environment and Social Impact Assessment (ESIA) for the Project in 2022 and is disclosed as part of this ESRS. ESIA has received the requisite approvals and includes a framework E&S Management Plan (ESMP), which provides the organizational structure for E&S management, mitigation measures and monitoring requirements applicable to the construction and operation phases of the project and are aligned with the WBG Environment, Health and Safety (EHS) Guidelines. Guided by the ESMP, Duval will ensure that relevant plans and sub-plans addressing E&S aspects such as air quality, noise, wastewater, Health and Safety, solid waste management and hazardous materials, traffic management, labor and working conditions management, etc., will be developed and implemented for the construction and operation phases. (ESAP #2).
Organizational Capacity: Duval’s E&S compliance across all investments is managed by the Group CSR Manager. At the Company level, Duval has recruited a Project Director and E&S Compliance Manager who will be responsible for overall E&S management for the Saint Paul development. Duval has also retained the services of an EHS consultant to provide construction related oversight.
Emergency Preparedness and Response: Duval will develop a site-specific emergency preparedness and response plan (ERP) and procedures for the construction and operations phases of the Project (ESAP #2). The procedures will describe emergency scenarios and specifies responsibilities, measures and required resources. The ERP will be based on local regulatory requirements and site conditions.
Monitoring and Review: Duval conducts both internal and external audits of the E&S aspects of its activities. The same is planned for the Project where internal audits will be undertaken by the operational team and external audits by the EHS consultant. As part of the Company ESMS, Duval will develop and periodically report on a minimum set of Key E&S Performance Indicators (KPIs) during the construction phase (ESAP #1).
PS2: Labor and Working Conditions
Human Resources Policies and Procedures and Working Conditions and Terms of Employment: The Saint Paul development is expected to employ up to 1000 workers at the peak of the construction period. Most of these workers will be employed by the construction contractor and sub-contractors and sourced from Ivory Coast. No workers will be housed on site. Up to 50 workers will be employed directly by the Company during the operations phase. The Company may also use third party service providers for security and cleaning and maintenance during operations.
At the Group level, Duval is a signatory to the United Nations Global Compact and has an Ethics and Compliance Charter reaffirms the ten principles of the Compact including Human and Labor rights. The Company has developed a Human Resources (HR) policy in line with IFC PS2 requirements, which has been endorsed by management. A HR manager has also been appointed. Going forward, Duval will develop a Company level HR Manual that includes recruitment and age verification, induction, performance management, discipline, and grievance management procedures, employment contract templates, and working terms and conditions, in line with national law and IFC PS2 requirements. (ESAP # 3). The HR policy and procedures will be applicable to all workers including those employed by third parties during operations, made readily accessible and clearly communicated at onboarding and through the provision of additional sensitization and training.
Grievance Mechanism: Duval will establish a Company Labor Grievance Mechanism for direct and contracted employees which will allow for anonymous and confidential filing of complaints in line with the requirements of IFC PS2 and national law (ref. ESAP #3).
Occupational Health and Safety (OHS): Key OHS risks during construction include slips and falls, potential hazards from on-site moving machinery, heavy load lifting, traffic accidents, exposure to electric shocks and burns, etc. To manage these risks, and in line with IFC PS2 and relevant WBG EHS Guidelines, Duval will require the construction contractor (see ESAP # 2 and 4) to develop a Health and Safety Plan covering key aspects such as: Risk and Hazard Assessment and associated management procedures for work activities; Protective Personnel Equipment (PPE) requirements; OHS signage requirements; medical support requirements; rest and sanitary facilities; 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 contractor 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.
Workers Engaged by Third Parties during Construction: Considering that most of the construction workforce will be employed by contractors, Duval will develop a set of EHS and labor specifications in line with PS2 that every contractor or subcontractor will be required to implement as part of its scope of work. These specifications will form part of the construction contract. Duval will also put in place a contractor monitoring procedure to monitor the performance of contractors with national laws, project E&S requirements and PS2 provisions (ESAP #4).
PS3: Resource Efficiency and Pollution Prevention
GHG emissions: The Project is expected to less than 25,000 tons of carbon dioxide (CO2) equivalent emissions per year. The Company plans to use electricity from the grid, with back diesel generators.
Resource Use and Efficiency: Duval is planning to employ several resource efficiency initiatives such as installation of LED lights as well as automated lighting system in public/common spaces. Duval is also currently studying the possibility of installing solar panels. In addition, Duval is committed to achieving Level 1 EDGE certification for the project where a Building Management System (BMS) will be installed to reduce operating costs through energy optimization.
Water and Wastewater: Water for the Project during operations will be sourced from the municipal network. Water needs during construction are expected to be limited to construction activities including dust suppression, with the contractor using bowsers to bring water to the site. The Project will be connected to the sewer network, where wastewater generated during operations will be discharged into. During construction, the contractor will install temporary septic tanks which will be periodically emptied and disposed of by licensed service provider.
Solid and Hazardous Waste Management: Construction and operations phases will generate a significant quantity of solid waste. Duval will develop a Waste Management Plan covering solid and hazardous waste for both its construction and operations phases (see ESAP #2).
Surveys carried out as part of the feasibility studies identified the presence of a limited quantity of asbestos in corrugated fibre cement sheets used to cover part of a building on site that was due to be demolished to make way for the Project. Duval has contracted a competent company to manage the safe removal and disposal of asbestos waste in line with relevant WBG EHS Guidelines .
PS4: Community Health, Safety and Security
Life and Fire Safety: For its projects in general, Duval integrates the infrastructure and life and fire safety (L&FS) design criteria, in line with host country building requirements and applicable international codes and standards. Smoke detectors, sprinklers and fire alarms are to be installed at the premises as per the local regulatory requirements. For Saint Paul, Duval will engage with a competent third-party L&FS specialist to a) review the design specifications against the WBG General EHS Guidelines and update as required; and b) upon completion of the construction, test and certify that the L&FS systems comply with national, as well as international fire safety and building codes for public access buildings, as referred to the WBG General EHS Guidelines (ESAP # 5).
Road Safety: The Project is in an urban-commercial area of the Plateau neighborhood of Abidjan. The construction of the facility will result in impacts on traffic and noise in the surrounding area. Duval will develop a Traffic Management Plan and Noise Management Plan (see ESAP # 2) to manage negative impacts on residents and businesses in the surrounding area during the construction and operations phases to the extent possible.
Security Personnel: The Project facility will occupy one city block. The site will be fenced off during construction with a single manned access point. A vetted security service provider will be retained for the construction and operations phase. All security guards will be unarmed. Duval will develop a Security Policy in line with PS4 requirements (ESAP # 6) and pro-actively manage interactions between Project personnel and the public in line with the Stakeholder Engagement Plan (see below).
PS5: Land Acquisition and Involuntary Resettlement
The Project will be developed on a 0.9 ha plot of land in the Plateau neighborhood of Abidjan. The land is owned by the Archdiocese of Abidjan; a 45-year lease was signed with the Company in June 2021. The Project site was the location of a chapel, a school run by the Diocese, a residential dwelling owned by the Archdiocese (housing a sexton), and shops operated by 34 vendors (27 formal vendors with 3-year leases set to expire in January 2021 and 7 informal vendors). In October 2020, the Diocese informed all the formal vendors that their leases would not be renewed and issued a notice to vacate by July 2021. The vendors were subsequently evicted by the representatives of the Diocese in July 2021 in accordance with applicable national law; informal vendors have been allowed to stay on the site until the start of project construction. The school located on the site was closed in the summer of 2021 and the teaching staff and students reassigned to other schools in the area. Non-teaching staff were not reassigned; the group has filed a complaint with the Labor Inspector over their dismissal. The sexton found alternative accommodation and continues to work at the chapel, which will be retained in the design of the Project but will be temporarily closed to the public during the construction phase of the Project.
Development of the Project has resulted in the unmitigated economic displacement of formal and informal vendors and the non-teaching staff of the school, as well as the physical displacement of the sexton who resided on the Project site. Duval has prepared a Livelihood Restoration Plan (LRP) to address these impacts in accordance with PS5 requirements. Implementation of the LRP will begin prior to the start of Project construction.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
A biodiversity study commissioned by Duval identified the presence of two species of bats roosting on trees on or near the site: Eidolon helvum or the Straw Bat with a Near Threatened IUCN classification and Hypsignathus monstrosus or the Hammer-headed Bat with Least Concern IUCN classification. Some of these trees are earmarked for cutting or pruning to make way for the development. The Eidolon helvun is a migratory species widely distributed across sub-Saharan Africa. Based on the information gathered as part of the study, the project area is modified habitat and does not support a globally, or nationally significant population of this species. Duval is committed to implement management measures such as on-site and offsite landscaping with appropriate and native tree species that will be able to provide habitats for such bats species in the future. Other measures include sensitization campaigns on bats conservation. These are deemed appropriate for the nature and significance of the impacts.
PS8: Cultural Heritage
The Project will be built on the current site of the Saint Paul chapel, whose facilities include a school built in 1901 and a presbytery built in 1931. The chapel itself will be integrated into the Project design and the Project will include limited renovation of the chapel structure. The presbytery will be converted into a mixed-used building, with commercial units on the ground floor and residential units for Archdiocese personnel on the second floor. The school was closed by the Archdiocese in 2021 and will be demolished during Project construction (see PS5). Duval will develop a Cultural Heritage Management Plan to identify and implement measures to protect cultural heritage throughout the construction process and ensure ongoing coordination with the Archdiocese in this regard (ESAP #2). The Cultural Heritage Management Plan will also address impacts on Affected Communities’ access to the chapel during the construction phase and will align with the Project’s Stakeholder Engagement Plan to ensure appropriate consultation is carried out. The Cultural Heritage Management Plan will include a Chance Finds Procedure to manage any discoveries of additional cultural heritage assets during the construction process.
