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 5 - Land Acquisition and Involuntary Resettlement
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 7 - Indigenous Peoples
PS 8 - Cultural Heritage

The project is categorized as Category A in accordance with IFC’s Policy on Environmental and Social Sustainability (2012) due to potential significant adverse environmental and social risks and/or impacts that are diverse, irreversible, or unprecedented, and that require comprehensive assessment, stakeholder engagement, and robust management measures.

The key potential E&S risks and impacts associated with the project during construction are: (a) loss of collective customary land, access to grazing land, and livelihood impacts of pastoralists communities; (b) habitat disturbance during site preparation and infrastructure development; (c) a sizable workforce, giving rise to risks and impacts related to labor influx, worker accommodation, occupational H&S, pollution and contractor management; and (d) risks associated with traffic and transport along the Djibouti–Aysha corridor. The key potential E&S risks and impacts during operation will include: (a) impacts on birds and bats associated with WTG operation; (b) noise and shadow flicker impacts on the community. Both phases will involve other risk and impacts e.g. (a) community health and safety, security arrangements, and emergency preparedness; and (b) adequate self-sufficiency in waste management and emergency response provisions.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Policy and Management System: AMEA Power has a corporate integrated Quality, Health, Safety and Environment (QHSE) management system, certified as per ISO 9001, ISO 14001 and ISO 45001 requirements, respectively (https://www.ameapower.com/qhse-at-amea-power-2 /). These systems cover engineering, procurement, construction and operations of renewable energy projects. As part of the corporate systems, AMEA Power has a suite of corporate policies covering environmental protection, labor and working conditions, health and safety, security, human rights, supply chain management, gender equality and social sustainability. These policies are aligned with the IFC PSs.

At the project level, an ESMS is yet to be finalized. As set forth in the ESAP (#2), AMEA and the project company will develop a project-specific ESMS covering both construction and operation stages of the project. The ESMS will be based on AMEA’s corporate management systems and will operationalize the AMEA Power policies at a project level, including translation into local language and communication to contractors, workers and affected communities. The ESMS will include E&S management plans, communication, training, monitoring, and audit requirements and a legal and permit register for the project (ESAP#1). The project’s permit register will help to ensure identification, acquisition, and tracking of all applicable E&S permits throughout the project lifecycle and it will be regularly updated. AMEA Power will contractually require the EPC and O&M contractors to implement a project-specific ESMS and develop complementary documents to implement the systems as described below under management programs.

Identification of Risks and Impacts and Management Programs: AMEA has a corporate E&S risk and impact assessment procedure specifying minimum requirements for risk identification and management across all project phases, as well as a risk assessment methodology for identifying Occupational, Health and Safety (OHS) hazards and determining proportionate control measures.

E&S risks and impacts associated with the project have been identified and assessed through a series of studies prepared in line with Ethiopian national and regional regulatory requirements and IFC Performance Standards (PSs). These include an initial E&S impact assessment (ESIA) approved in 2021, which has been updated in 2025 and 2026. The updated ESIA (of May 2026) addresses IFC PSs and other lenders’ requirements and is disclosed with this ESRS. The identified key risks and impacts are related to land access restrictions affecting pastoralist livelihoods, biodiversity (notably birds, bats and gazelles), labor influx and worker accommodation, community H&S, traffic and transport, water supply, waste and wastewater management, security, and cumulative impacts. These impacts are discussed in the relevant sub-sections below. Certain components of the ESIA will need to be updated as described in the sub-sections below.

As part of the ESIA, several management plans have been prepared including a livelihood restoration plan, stakeholder engagement plan, workers and community grievance mechanism. All management plans will be consolidated within the Environmental and Social Management Plan (ESMP) appended to the ESIA. AMEA and APAWO will implement the ESMP and ensure its inclusion in the contracts signed with the EPC and O&M contractors (ESAP#1). Once the EPC is selected and detailed design is prepared, AMEA and APAWO will ensure that the project’s area of influence is reviewed to ensure any additional components (e.g. due to material transport, temporary road modifications, worker and material movements, water supply, wastewater management, and potential sourcing of construction materials from quarries or borrow pits) are included in the ESIA and ESMP along with the application of the mitigation hierarchy (ESAP#16).

AMEA has also developed an “E&S Employer Requirements” document typically appended to terms of reference for tendering processes, which sets minimum E&S performance requirements for AMEA projects. This document requires adherence to E&S Policies, international standards and national legislation, and mandates the appointment of qualified E&S, H&S, and security personnel. It further instructs contractors and subcontractors to provide E&S training.
As set forth in the ESAP#5, AMEA and APAWO will ensure operationalization of the ESMP through contractor-specific Construction and O&M E&S management plans (CESMP and OESMP). These plans will include specific plans addressing labor and working conditions, worker accommodation, community H&S, traffic and transport management, biodiversity management, water and waste management, security and stakeholder engagement. The CESMP and OESMP will be developed by the EPC/O&M Contractors and will require review and approval prior to their mobilization. The OESMP will also include a high-level decommissioning strategy (ESAP#5).

Cumulative impact assessment: A rapid cumulative impact assessment (RCIA) has been completed for the project, considering Aysha II wind power plant (WPP) and the Addis–Djibouti Railway, and has identified biodiversity related aspects as valued environmental components (VECs). The RCIA needs significant improvements in order to be compliant to IFC PSs. The RCIA needs to be strengthened to (a) cover all other projects (e.g. Aysha III WPP); (b) identify and assess additional VECs including social risks, noise and shadow flicker impacts and ecosystem services; and (c) ensure adequate stakeholder consultations in identifying and understanding VECs (ESAP#3). The RCIA also needs to include a clearly defined cumulative impact management and monitoring framework with defined roles, coordination mechanisms, or decision making processes.

E&S organization and capacity: Responsibility for E&S management at the Aysha I Wind project will be shared between AMEA Power, APAWO, and the future EPC and O&M Contractors. While initial social personnel have been mobilized at project level by AMEA, key E&S, HSE, labor compliance, and security positions required to manage a large, remote construction workforce have not yet been fully defined or staffed.

AMEA and APAWO will ensure early mobilization of suitably qualified E&S staff, clear delineation of roles and responsibilities between APAWO and the EPC/O&M contractors, and adequate resourcing to ensure effective implementation, oversight, and reporting of E&S performance (ESAP#). Specifically, to manage biodiversity risks and coordinate related mitigation measures, AMEA will appoint a Biodiversity Manager within the project company with experience delivering wind-wildlife programmes that meet IFC PS6. The biodiversity manager will oversee and report on all project mitigation and monitoring activities included in the project’s biodiversity management plan, discussed under PS6 (ESAP #4).

The CESMP and OESMP discussed above will include contractors’ organization chart detailing E&S, OHS, HR, and labor compliance roles and reporting lines across all project entities and a commitment to update this plan in line with evolving workforce numbers, sub-contractor arrangements and project needs (ESAP #4).

E&S training: AMEA Power’s corporate management system includes E&S training and competence requirements. For Aysha I, project-specific E&S training programs will be developed and implemented by the project company and the EPC/O&M contractors to ensure that workers, supervisors, and managers understand their responsibilities under the ESMS and ESMPs. Training will cover key topics including OHS, labor and working conditions, community engagement, code of conduct, emergency preparedness, and relevant environmental management measures, and will form an integral part of ESMS implementation (ESAP#2).

Emergency Preparedness and Response: Due to the project’s remote location and limited availability of public emergency services, effective emergency preparedness and response arrangements for the project will be critical. The project will need to develop on-site facilities to respond to any emergencies including for fire-fighting, medical emergencies and evacuation. While emergency scenarios have been identified within the ESIA, SLIP, and Framework ESMP, a project-specific Emergency Preparedness and Response Plan (EPRP) will be updated. The project will develop and implement comprehensive EPRPs for both construction and operation phases, covering credible emergency scenarios, roles and responsibilities, coordination with local authorities and communities, communication procedures, and training and drills. These arrangements will be integrated into the ESMS, CESMP and OESMP (ESAP#6).

E&S Monitoring & Review: Considering the project is yet to start construction, project-specific E&S monitoring and reporting systems are not yet operational. While the ESIA and SLIP identify relevant monitoring parameters and key performance indicators, a consolidated monitoring and reporting program remains to be developed. As part of the ESMS, the project will establish E&S monitoring and reporting framework for both construction and operation phases, including regular performance reviews, incident reporting, audits, and corrective action tracking, to support adaptive management and lender reporting (ESAP#7). The procedure will include requirements from the ESMP. Also, the relevant components of the framework will be operationalized within the CESMP and OESMP.

Supply Chain: AMEA has established corporate procedures for contractor and supply chain risk management, including requirements for responsible sourcing, labor standards, and compliance with international norms. AMEA has an established supply chain risk management system which includes a code of conduct aligned with PS2, risk assessment and mapping procedure, contractual clauses for alignment with the code of conduct, and ongoing monitoring of suppliers. For the project, these corporate requirements will be applied through project specific contractor and supply chain management arrangements to be implemented by the project company and the EPC Contractor. These arrangements will assist that E&S risks associated with contractors, subcontractors, and suppliers are identified, managed, and monitored in line with the project’s ESMS (ESAP#9).

PS2: Labor and Working Conditions

The project workforce is estimated at 800 during the peak construction phase for a duration of approximately 24 months, whereas the workforce will be reduced to about 25 during the operation phase for a duration of 25 years.

Human Resource Policy, Working Conditions and Terms of Employment: AMEA Power has established corporate level HR policies that are aligned with IFC PS2 requirements. These corporate commitments include requirements on fair working conditions, non discrimination, prohibition of child and forced labor, freedom of association, and access to grievance mechanisms. For the Aysha I Wind project, these corporate requirements will be operationalized through project specific HR policies, labor codes of conduct, and labor and working conditions management systems to be developed and implemented by the project company. The policies and procedures will clearly describe employment terms, working hours, wages, overtime, benefits, disciplinary procedures, and termination processes and will be reflected in written contracts signed with the employees. The policies will be translated in local languages (Somali and Amharic) and communicated to all the employees (ESAP#8).

AMEA has a labor code of conduct that applies to all its projects, including the Aysha I project. This document sets out
working conditions and worker rights standards based on good practices and ILO conventions. It provides guidance on workplace ethics and expected behavior, including respect for workers and the social environment, respect for religious customs and cultural heritage, zero tolerance of gender based violence and harassment (GBVH), and prohibitions on drugs, alcohol, and related misconduct. As per the ESAP#8, a project-specific Labor Code of Conduct will be prepared to ensure that all workers — across contractors, subcontractors, and the wider supply chain — clearly understand and adhere to these requirements. The code of conduct will be made available and communicated to the project’s workforce in English and local languages.

Occupational Health and Safety (OHS) and workers engaged by third-parties: AMEA Power’s corporate Integrated Management System includes occupational health and safety (OHS) requirements aligned with ISO 45001 and IFC PS2.

For the project, OHS risks are expected to be significant due to the scale of construction activities, remote location, heavy lifting, working at heights, traffic and transportation movements, and the establishment of worker accommodation facilities. At the same time, the project will rely extensively on contractors and subcontractors, particularly during the construction phase.

As discussed under PS1, AMEA has documented “E&S Employer Requirements” appended to Terms of Reference for tendering processes, which sets minimum E&S performance requirements for AMEA projects, which requires adherence to E&S Policies, international standards and national legislation, and mandates the appointment of qualified E&S, H&S, and security personnel. It further instructs contractors and subcontractors to provide E&S training. As part of the ESMS, the project will develop a contractor and supply chain management plan which will describe how labor and working conditions and OHS practices will be actively reinforced and monitored through contractors/subcontractors performance. The plan will describe various procedures for prequalification, onboarding, compliance monitoring, and oversight of all contractors, subcontractors, and suppliers to ensure adherence to the project’s labor and working condition standards, including reporting and audit requirements. Also, as required under the E&S Employer Requirements, as part of the CESMP/OESMP, the EPC/O&M Contractors will develop a project-specific HR Policy, which will be aligned with the project company’s HR policies and Procedures, IFC PS2, and national labor legislation and will be made accessible to all workers in the main language(s). (ESAP#9).

The EPC and O&M contractors have not been finalized yet but both contractors will develop specific Construction and O&M E&S management plans (CESMP and OESMP) as per ESAP(#5). These plans will include specific plans addressing OHS, labor and working conditions, and worker accommodation requirements. The plans will be developed and will be approved prior to their mobilization. The OHS plans in the CESMP/OESMP will cover hazard identification and risk assessment, safe systems of work, emergency response, training, incident reporting, and sub-contractor oversight as well as all relevant OHS-related monitoring and reporting requirements. Also, the plans will include heat stress management measures including worker awareness on hydration and heat-related symptoms, appropriate work–rest scheduling during high temperature periods, and the provision of drinking water, shaded rest areas, and suitable personal protective equipment. Implementation of the aforementioned plans and programs will be ensured through proper training, supervision and performance monitoring by contractors and the project company.

Non-discrimination and Equal Opportunity and GBVH: AMEA Power’s corporate policies and contractor requirements include commitments to non-discrimination, equal opportunity, gender equality, and prevention of harassment and abuse. These commitments apply to all workers, including direct, contracted, and subcontracted workers. The provisions of non-discrimination and equal opportunities are included in the “E&S Employer Requirements” document. Also, the workers grievance mechanism, discussed below, includes a dedicated, survivor centred process for handling Gender Based Violence, Harassment, Sexual Harassment, and Sexual Exploitation & Abuse (GBVH/SEA) complaints. The project will additionally implement these requirements through the project specific labor code of conduct and labor and working conditions management plan.

Grievance Mechanism: AMEA Power requires the establishment of accessible and non-retaliatory grievance mechanisms for workers, consistent with IFC PS2 requirements. For the project, a Worker Grievance Mechanism (WGM) has been prepared that provides multiple channels for lodging complaints, including anonymous submissions, and includes dedicated provisions for handling sensitive grievances such as GBVH related grievances. While the overall structure of the WGM is considered robust, as per the ESAP, the project will ensure that contractors develop and implement a WGM as well and integrate with other management plans with respect to typical high risk issues such as worker accommodation and transport arrangements (ESAP#10).

Child and forced labor: AMEA Power maintains a strict prohibition on child labor and forced labor through its corporate policies, contractor requirements, and supply chain management procedures, consistent with IFC Performance Standard 2 and ILO conventions. These requirements apply across all tiers of the workforce, including suppliers and subcontractors. For the project, the EPC/O&M contractor and their sub-contractors will be required to implement these prohibitions through project specific policies, contractual controls, and monitoring systems, including age verification and audit procedures through the labor and working conditions management plan, CESMP and OESMP.

Workers’ Accommodation: Given the remote location of the project, establishing workers’ accommodation camp at the project site is considered necessary. At this stage, no details on the camp design, layout, capacity, or facilities are available as that will be finalized along with the EPC contractor. As per AMEA’s E&S Employer Requirements, contractors are required to submit workers accommodation plan in compliance with IFC/EBRD workers accommodation standards and requirements as per the ESIA/ESMP. As per the ESAP#11, a project-specific workers’ accommodation management plan will be developed as part of the CESMP and OESMP, which will be aligned with IFC/EBRD/AfDB workers’ accommodation standards. The project company will review and agree on the worker accommodation plan with the EPC contractor and ensure that it fully reflects the accommodation needs of the EPC Contractor and all subcontractors and meets the IFC/EBRD/AfDB workers accommodation standards . The accommodation design will also consider the heat stress management measures. As discussed under PS3, complementary studies on water supply and wastewater management will need to be completed and outcomes reflected in these plans.

PS3: Resource Efficiency and Pollution Prevention

Energy Consumption and GHG Emissions: The Aysha I Wind project is expected to generate renewable electricity with significant climate benefits by displacing fossil-fuel-based generation from the national grid. The project is estimated to generate approximately 920 GWh per year based on the P90 (90% probability of exceedance) energy yield assessment, with greenhouse gas (GHG) emission reductions of approximately 368,000 tCO2 equivalents per year using a grid emission factor of 400gCO2e/kWh.

GHG emissions associated with the construction phase are expected to arise primarily from fuel consumption by construction equipment, generators, and transport vehicles and the same have been estimated. These estimates will be refined once the EPC Contractor is appointed and procedures will be included in the monitoring and review framework for monitoring fuel use and GHG emissions during construction and operation (ESAP#7).

Overall, the estimates indicate that the project’s GHG emissions will remain below the threshold of 25,000 tCO2, while contributing positively to avoided emissions at the system level.

Water Supply: Water consumption for the project is expected to be highest during the construction phase, driven by workforce requirements, concrete works, a construction camp and dust suppression activities, with substantially lower water demand during operations. As per the ESIA, the project will require approximately 32 m3/day of water during construction and around 0.5 m3/day during operation phase. The ESIA identifies several possible water supply options, including groundwater abstraction, tanker supply, and connection to existing pipeline infrastructure. However, water sourcing arrangements have not yet been finalized and that comparative assessment of options remains to be completed.

Given the project is located in an arid to semi-arid pastoral context, as per the ESAP#12, the project will undertake a water supply source assessment to identify sustainable water sourcing solutions that avoid adverse impacts on community water access in consultation with the community, relevant authorities and the EPC contractor. The assessment will include source yield /availability, legal access and permitting requirements, potential competition with community use and any water quality treatment needs. Also, project specific water management plans for construction and operation stages will be incorporated in the project ESMS, CESMP and OESMP including monitoring, permitting, and contingency measures for drought conditions.

Pollution Prevention: Potential sources of pollution associated with the project may include air emissions and dust during construction, noise and shadow flicker during operation, spills and leaks of fuels and hazardous materials, and vehicular emissions during operation. Most of these impacts can be addressed through appropriate mitigation measures. CESMP/OESMP will, therefore, include project-specific management plans addressing air quality and dust control, noise, hazardous materials handling, and spill prevention, consistent with Good International Industry Practice (GIIP) (ESAP#5). Noise and shadow flicker impacts are discussed in PS4 below.

Waste management: The project is expected to generate both non-hazardous waste (including packaging, construction debris, and domestic waste) and hazardous waste (including used oils, lubricants, chemicals, and biomedical waste from the site clinic) during construction and operation. While the ESIA commits to managing waste in accordance with the waste hierarchy, given the remote location, suitable licensed waste management and disposal facilities are not available in the project region.

To address this risk, the project will conduct a structured assessment of waste management and disposal options, prior to construction. The assessment will support the project in identification of proper storage, handling, treatment, recycling, and disposal options for various waste streams, and cover the construction, operations and decommissioning phases of the project in line with GIIP (ESAP#12). In the event that an onsite solution is selected, permitting, procurement, O&M implications will need to be fully accounted for and associated capital and operating costs will need to be factored into the project budgets. Also, project-specific waste management plans will be developed for both hazardous and non-hazardous waste and included in the project level ESMS and contractors’ ESMP defining handling, storage, transport, treatment, and disposal arrangements, as well as monitoring and contractor oversight mechanisms (ESAP#12).

Wastewater management: Sanitary wastewater generation is expected during both construction and operation phases, as worker accommodation facilities are anticipated to be established on site. Considering the project location, off-site wastewater treatment facilities are not available and thus the project will need to be self-sufficient in this regard. The project company and EPC contractor will, therefore, evaluate feasible wastewater management options, including on-site packaged wastewater treatment systems. The selected approach will be incorporated into project-specific ESMS and contractors’ E&S management plans for construction and operation, including permitting, effluent quality controls, monitoring, and emergency response measures, to ensure protection of soil, groundwater, and community health (ESAP#12).

Possible options on abovementioned aspects (i.e. water supply, wastewater and waste management) and selected alternatives will be included in the design agreed with the EPC contractor.

PS4: Community Health, Safety and Security

Community Health and Safety: The project may pose community H&S risks during construction and operation due to its scale, remote location, interaction with pastoralist communities, worker influx, and use of heavy equipment and materials. The potential risks identified during construction will include increased traffic and road safety hazards, dust and noise, interaction between workers and communities, exposure to hazardous materials as well as security management. During operation, the potential risks may will include noise and shadow flicker, low-probability technical failures such as equipment malfunction and security management.

Project-specific community health and safety controls will be developed, consolidated and operationalized through project-specific Community H&S Management Plans for the construction and operation phases (ESAP#13).

Shadow flicker impacts: Based on the ESIA and shadow flicker (SF) impact assessment, no shadow flicker impacts are expected for the sensitive receptors at the nearest settlements - Aysha, (4.2 km north east from the closest WTG), and Lasarat (approximately 2.8 km south west from its closest WTG). A conservative 2 km buffer was generated around the WTGs as part of the SF impact assessment which clearly illustrates that sensitive receptors are outside this zone.
However, certain “possible settlement sites” used by nomadic herders have been identified in the northern portion of the project area which fall within zones where SF exposure is predicted to exceed guideline values, including areas located beyond the established operational safety setback. Since these results are based on a worst-case modelling scenario, both documents acknowledge that actual impacts may be lower depending on weather conditions, topographical features, and the orientation of pastoralist shelters. Also, there may be potential impacts on seasonal pastoralists and their livestock (behavioral change due to SF). Lastly, the SF impacts are estimated to exceed at two ritual sites i.e.

(i) Ritual Site 01 - located in the village of Kelewle (at about 1 km from the nearest WTG): It is used three times a year to hold religious festivals like Eid-al-Fitir, Eid-al-Adha and Mowlid. This site is expected to experience more than 30 minutes of shadow flicker effects per day at various times throughout the year with the highest incidence being in November.

(ii) Ritual Site 03 - located in the village of Aligire (at about 450 m from the nearest WTG): It is used by the sub-clan Sheika for gatherings which take place once a year (usually initiated when demand arises due to a crisis such as conflict, drought, epidemics or the death of influential personalities). During this time, people from different areas, including Degego, Lasarat, Aysha, Dire Dawa and Djibuti travel to the site for this occasion and spend 2-3 days on this location, where they slaughter goats and cattle to pray for peace and prosperity. The site is expected to experience more than 30 minutes of SF effects between January and March, and also between September and December with the highest incidence being in October.

To address the above risks, as per the ESAP(#14), the project will (a) develop and implement a systematic monitoring process of land use, to be carried out during seasons of the year when nomadic herders use the northern area impacted by SF impacts; (b) engage with the affected herders and seasonal pastoralists and include them in the Stakeholder Engagement Plan (SEP), in order to inform and consult them about the project’s impacts, its E&S plans, prevention and mitigation as well as the grievance mechanism; (c) assess the likely impacts on seasonal pastoralists, livestock and ritual sites to better understand the level of shadow flicker impact, consult with the communities to develop and implement the required additional mitigation measures as needed.

Noise impacts: Noise modelling was undertaken as part of the ESIA for sensitive receptors in Degego Kebele, Daga Assah and K’Obe Shet. The study also considered cumulative effects of the existing Aysha II WPP. As per the baseline monitoring, permanent settlements like the Aysha town, Lasarat and Ged Goble villages have background noise levels exceeding the WBG EHS guidelines (i.e. 55 dB(A) during the day and 45 dB(A) during the night). The other locations within the project lease area i.e. Degego Kebele also have high background noise levels. In terms of predicted impacts, project’s incremental impact will be less than 3 dB(A) at all locations. However, additional noise modelling is required to (a) assess incremental impacts in Degego Kebele where noise levels may exceed WBG EHS guidelines during night time; (b) include highway’s contribution in the noise modelling as a separate layer and confirm exclusion of the railway line and its rationale; and (b) assess impacts on seasonal dwelling receptors in the mapped northern temporary dweller areas and the cultural heritage sites (ESAP#14). Based on revised modelling and impact assessment, required mitigation measures shall be implemented by the project.

Infrastructure and Equipment Design and Safety: project infrastructure includes WTGs, substations, underground and overhead transmission lines, access roads, temporary construction facilities, and worker accommodation camps. Risks to communities may arise from unsafe design, unauthorized access, or failure to adequately manage safety exclusion zones, particularly in an area used by mobile pastoralist communities and livestock. The project is also located in Zone 4, which is classified as a region of the highest seismic hazard. The project is committed to applying GIIP in the design, construction, and operation of infrastructure. Safety areas will be maintained around turbines to protect communities from blade throw and tower collapse (while walking and grazing will be permitted in these areas). Safety considerations related to infrastructure design, equipment siting, and interaction with communities will be integrated project-specific ESMS, CESMP, OESMP and emergency response arrangements, particularly once final design is confirmed (ESAP#2 and 5).

Community Exposure to Disease: Construction-phase worker influx may increase the risk of communicable disease transmission and place additional pressure on limited local health services. The ESIA identifies risks related to water-borne diseases, vector-borne diseases, and sexually transmitted infections, which may be exacerbated by the establishment of worker accommodation facilities in a remote setting.

Although high-level mitigation measures are proposed in the ESIA, key design elements like workforce, accommodation arrangements, and the feasibility of off-site water and sanitation services are yet to be defined. The project will, therefore, strengthen disease prevention and control measures through project-specific worker influx, accommodation, and community H&S management plans in the ESMS, including health screening, hygiene promotion, code of conduct enforcement, and coordination with local health authorities. These plans will be integrated into the CESMP and OESMP (ESAP#13, 2 and 5).

Transportation Safety: Transportation and traffic safety represent key community H&S risks (mostly during construction) due to the movement of construction vehicles, abnormal loads, worker transport, and delivery of equipment along regional and cross-border routes from Djibouti and Dire Dawa. Potential impacts include traffic accidents, unsafe interactions with pedestrians, livestock and pastoralist groups, dust generation, and temporary road modifications.

While the ESIA identifies these risks, detailed route-specific traffic and road risk assessments have not yet been completed for any temporary road diversion works and bypass that may be involved in movement of equipment from the port as these requirements are not yet fully defined. Therefore, prior to undertaking any temporary road diversions or bypass works, the project will conduct route-specific road risk assessments, which will identify communities, pastoralist routes, livestock crossings, schools, markets, and other social receptors, and assess road conditions, and peak risk sections along the transport corridor. The RRA shall be reviewed periodically and revised as necessary, including in response to a road traffic incident, community safety incident, or near miss. The project will also develop and implement traffic and transport management plans to manage vehicle movements, community interface, signage, speed controls, journey management and driver training. These plans will be integrated into the CESMP and OESMP (ESAP#13 ).

Security management: The ESIA identifies a range of security related risks linked both to the broader regional context—given the project’s proximity to the international borders and areas affected with armed clashes —and to project induced factors, including unauthorized entry into turbine or substation areas (with potential associated asset damage and safety risks), the presence and conduct of security personnel, gender based violence risks, and the potential for conflict with local communities and pastoralist groups.

AMEA has a publicly disclosed security policy (https://ameapower.com/_2022/wp-content/uploads/2022/04/Security-Policy.pdf). Under the policy, AMEA has committed to compliance with the national and local laws, Voluntary Principles on Security and Human Rights and IFC PS4 among other standards. AMEA also has a security risk assessment and management plan and a security risk assessment (SRA) was completed in 2025 for the project as per this plan. As per the ESAP(#15), AMEA will complete a conflict sensitivity analysis for the project, which will then inform the SRA. The SRA will be updated to address gaps identified in the ESIA and a security management plan (SMP) will be developed and implemented for the project in line with AMEA’s security policy (ESAP#15).

The project will also develop and implement a security code of conduct, integrated into the SMP, covering rules of engagement, proportional use of force, cultural awareness, community-security interaction protocols, and procedures for coordination with public security forces. The security code of conduct shall complement the general workforce CoC and be applied to all private security personnel and any public security forces deployed to support the project.

PS 5: Land Acquisition and Involuntary Resettlement

The project has secured a lease over approximately 84.46 km² of land from the Somali Regional State Environmental Protection and Rural Land Administration Bureau for the period 2025–2049. As with all land in Ethiopia, the land under the lease is legally held by the Government of Ethiopia but at the same time, it is held under collective customary tenure by the Somali-Issa Clan Community.

While this lease area falls within the administrative boundaries of four Kebeles namely, Aysha 01, Aysha 02, Dagago and Lasarat, available documentation indicates that the development footprint is more spatially concentrated and does not uniformly affect all Kebeles to the same extent. Land use within this area is characterized by dynamic and seasonal patterns of pastoral mobility, with households migrating into and through the project area of influence (PAoI) depending on the availability of pasture and water resources, as well as access to livestock markets. As a result, both the number and identity of households using the lease area vary across seasons and years and cannot be definitively established for the construction or operational phases. With the exception of certain safety buffer zones (where grazing will also be restricted), the project design will maintain continued access for grazing, temporary housing and seasonal movement across the majority of the lease area during both construction and operation.

While the lease area is administratively mapped to the four Kebeles, access to and use of these rangelands is not confined to residents of those Kebeles alone, and pastoralist users may originate from neighboring areas. This reflects the broader territorial extent of the Issa Clan, whose customary land use systems extend beyond Aysha Woreda and the Sitti Zone. The project has committed to avoid and minimize impacts through layout optimization, construction scheduling during periods of lower seasonal presence, prioritization of existing access routes and rehabilitation of temporary land take (back to grazing areas), as secured under through ESAP#16 (management of land acquisition and access restrictions, impact avoidance and minimization measures).

Displacement impact. The project does not entail physical resettlement or relocation of dwellings. Socioeconomic surveys and field investigations confirm the absence of permanent buildings within the lease area, with land use characterized by temporary housing and livestock kraals for pastoral-nomadic households. Seasonal settlements are typically established between May and November, depending on rainfall, pasture availability, and drought conditions. The past 2 census activities undertaken in 2025 and 2021 found 150-160 households temporarily residing on the leased land. The project will result in economic displacement from and permanent loss of ownership of communal land and restricted access and use of customary grazing areas. In the context of the communal land tenure system and seasonal mobility patterns, these impacts are expected to be experienced collectively at the clan level. Individual households to be relocated from the project area will however receive assistance by Project staff to identify the closest suitable area for temporary resettlement and moving belongings.

Resettlement Planning and Livelihood Restoration. Prior to the land leasing process, the project site was customarily owned and occupied by the members of the Issa Clan. A cut-off date was established following completion of the socioeconomic census and asset inventory and was disclosed to affected communities and endorsed by local authorities. A Livelihood Restoration Plan (LRP) has been developed to address economic displacement through a community-based approach aligned with PS5 and PS 7 requirements (Ref: PS 7 section of the ESRS). The LRP confirms that the majority of the lease area will remain accessible for grazing, provides for transitional support in periods where access is temporarily restricted, and introduces development-oriented livelihood restoration and benefit-sharing measures aligned with community priorities identified through consultation. These measures include provision of fodder support during construction and early operation to offset temporary access constraints, strengthening of veterinary services through provision of medicines and capacity building, revegetation and rangeland rehabilitation in areas disturbed by construction activities, and improvements to water access through rehabilitation of existing sources and/or development of new boreholes in the affected Kebeles.

Targeted provisions are included to ensure enhanced support to vulnerable households in line with PS5 requirements. While the LRP does not displace the collective approach to livelihood restoration, it specifies that vulnerable households will receive enhanced, tailored support within the overall program, recognizing their reduced capacity to adapt to temporary access restrictions and seasonal disruption of grazing patterns. In the Aysha context, this primarily captures women-headed households, who typically have fewer livestock assets and therefore lower livelihood resilience; and households headed by individuals who are physically impaired due to age, illness or disability, whose mobility constraints limit their ability to access grazing areas and sustain pastoral livelihoods. Targeted support to these vulnerable households in practice, will be anchored within the same package of livelihood restoration measures such as fodder support, veterinary services, rangeland rehabilitation, and improved water access, but with prioritized access, additional assistance, and closer implementation support to ensure that vulnerable households are not disadvantaged relative to the broader pastoralist community (ESAP#17). The additional support in the LRP is expected to be provided for 3 years and will cease once the implementation of the Benefit Sharing Program (outlined under PS 7) commences.

The company will undertake an independent PS 5 aligned close-out audit of the LRP implementation (ESAP#17).

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

The project is located within the Djibouti xeric shrublands ecoregion. It is sited on flat terrain and characterized by exposed sand and soil with scarce and scattered grasses, small shrubs acacia bushes, rocky outcrops as well as a small seasonal watercourse, artificial ponds and areas of invasive thicket. It does not overlap with any legally protected areas. The nearest Key Biodiversity Areas (KBAs) are the Ali Sabieh – Assamo 50 km northeast and Salak 60 km east of the project site in Djibouti and Somalia respectively. A wide range of raptor species, including five that are globally threatened, use the airspace over the project and surrounding landscape, one of which breeds in low numbers within the site. The site is also regularly used by two species of globally threatened gazelle species.

A critical habitat assessment (CHA) determined that the project was not within Critical Habitat. Raptors using the site include several collision risk susceptible species including Egyptian Vulture (IUCN Red List – Endangered), Bateleur (IUCN Red List – Endangered), White Backed Vulture (IUCN Red List – Critically Endangered), Tawny Eagle (IUCN Red List – Vulnerable), and Scissor-tailed Kite (IUCN Red List – Vulnerable) which also breeds within the site. The area is an important area for Dorcas Gazelle (IUCN Red List – Vulnerable) and Soemmerring’s Gazelle (IUCN Red List – Vulnerable). Baseline bat studies suggested a potentially low risk to bats but further studies are needed. For collision susceptible raptors, globally threatened gazelles and bats IFC Natural Habitat No-Net-Loss (NNL) requirements will be applied.

The project will implement a comprehensive program to avoid and minimize risks to priority biodiversity values. This will include safeguarding measures to avoid of impacts on sensitive habitats, including seasonal water features important to amphibians and other species during the wet season, and regular gazelle congregating areas; transmission line mitigation to minimize electrocution and collision risk an observer-led turbine shutdown on demand program for birds, turbine cut-in speed curtailment for bats; and a raptor food management program to remove livestock carcasses that may attract scavenging raptors close to turbines.

To strengthen the biodiversity baseline and inform mitigation and adaptive management, the project will undertake a program of additional biodiversity surveys, including flora (incl. invasive species) surveys and habitat condition mapping and assessment, at-height and mist-net surveys for bats, priority terrestrial fauna surveys, priority breeding and flight activity bird surveys, provisioning ecosystem services survey (grazing, water resources). Based on the findings from these surveys the project will reassess the outcomes of the CHA and if Critical Habitat is triggered then the project will develop a Biodiversity Action Plan (BAP) and associated Biodiversity Evaluation and Management Plan (BMEP) with credible, lender agreed offsets to achieve net gain for any Critical Habitat features. (ESAP #18). The project will also update the RCIA to align with the outcomes of the CHA, PS6 and IFC Cumulative Impact Assessment guidance (ESAP #3).

The project will implement the construction phase elements in the Biodiversity Management Plan (BMP) and develop associated GIIP standard subplans including: i) pre-clearance plan, ii) invasive species management plan iii) flora and habitat restoration plan, iv) priority terrestrial fauna protection plan v) priority breeding bird protection plan, vi) powerline/met mast bird flight diverter installation and maintenance plan. All plans will be implemented by appropriately qualified and experienced experts/consultancies agreed with lenders. (ESAP #19).

Similarly, the project will implement the operation phase elements of the BMP (ESAP #19). As part of this plan, the project will contract an internationally recognized wind-wildlife expert or consultancy to design and oversee the post-construction fatality monitoring (PCFM), observer-led shutdown on demand (OLSDOD), bat curtailment and raptor food management programs. The expert will be retained for the first three years to provide ongoing technical support to these programs and other operational phase monitoring, mitigation and reporting actions in the BMP. The OLSDOD program will be implemented using observers specifically trained and experienced in turbine shutdown procedures for birds. For the PCFM program the wind wildlife consultancy will train and oversee a locally contracted ecological consultancy to implement the program. The PCFM, OLSDOD, and bat curtailment programmes will be implemented for at least three years, and only discontinued with lender agreement following a review of species impacts and mitigation effectiveness.

PS7: Indigenous Peoples

Identification and Screening of Indigenous Peoples: The project is located entirely within Aysha Woreda, Somali Regional State, an area inhabited exclusively by members of the Issa Clan and its sub-clans. The Issa community meets the characteristics of Indigenous Peoples under IFC Performance Standard 7, including self-identification as a distinct social and cultural group, collective attachment to land and natural resources, and existence of a distinct customary governance institutions. The Issa Clan is governed through a distinctively established customary governance system (Xeer Issa), which manages land allocation, grazing rights, mobility, social obligations, and dispute resolution. These customary structures operate alongside formal state governance. Livelihoods are almost entirely dependent on nomadic and transhumant pastoralism, with households rearing camels, cattle, sheep, goats, and donkeys across communally managed rangelands.

The Issa Clan is governed through Xeer Ciise, an oral customary law system recognized by UNESCO in 2024 on the Representative List of the Intangible Cultural Heritage of Humanity. Three core institutions exercise governance authority: the Guudi, an assembly of elders responsible for social, political, and economic community matters; the Gande, which acts as a constitutional court reviewing the legality of Guudi decisions; and the Ugaas, the supreme traditional authority and symbol of law, drawn by custom from the Wardiq sub-clan. Government authorities at Federal, Regional, Zonal, Woreda, and Kebele levels make key decisions affecting the community in consultation with and after agreement with clan leaders.

Land Acquisition for the project and related PS 7 requirements: The project secured a land lease of approximately 84.46 km² from the Somali Regional State in 2024, for a period extending from October 2024 to June 2049. Prior to the government-led land leasing process for the project, as with all land in Ethiopia, the land was constitutionally owned by the State but in this case, the land was also held under collective customary ownership and use by the Somali-Issa Clan.
Under Xeer Ciise, land, grass, and water are shared resources across the Issa territory, and no individual or sub-clan holds exclusive rights. No permanent structures or residences exist within the lease area. Land use is seasonal, with pastoralist households migrating into the project area primarily during the rainy season in search of water and pasture. No physical displacement of community members is therefore anticipated. However, the project will impose temporary construction-phase access restrictions across approximately 6.49 km² (8% of the lease area) and permanent operational-phase safety buffers across approximately 15.21 km² (18% of the lease area) around each WTG, restricting settlement while permitting grazing and movement. Less than 1% of the lease area (approximately 0.751 km²) will be permanently occupied by project infrastructure. These restrictions constitute impacts on the Issa Clan's customary land and natural resource use under PS7, experienced collectively given the communal tenure system.

The project land lease process was undertaken through a combination of customary and formal governance systems, reflecting the dual structure of land tenure in the Somali Regional State. The company undertook stakeholder engagement between 2019 and 2025, including consultations with community members, women and youth groups, and local (kebele and woreda) authorities. Additionally, the engagement process involved the cultural leaders of the Somali-Issa Clan, namely the Ugaas as the clan leader and representatives of the Guddi as the Clan Elders. These consultations covered key aspects of the project, including land requirements, lease conditions, anticipated impacts, and potential benefit-sharing arrangements. Engagements were undertaken in a culturally appropriate manner and in the Somali language and included both general community meetings and targeted focus group discussions.

Although the land leasing process was aligned with national community land leasing laws and involved active community consultation, further steps were needed to enhance observance of a structured community level decision-making process that is aligned with a culturally appropriate systems under the Xeer as the Issa customary governance system. IFC has determined that Free, Prior and Informed Consent (FPIC) is required under Performance Standard 7 because the project affects land and natural resources that are customarily owned and used by the Issa Clan and sub-clans, including areas used for grazing, seasonal settlement, and pastoral mobility, which form a core part of the Issa community’s socio-cultural identity and collective attachment to land (ESAP#20).

As part of the appraisal process, a more detailed assessment on customary decision-making arrangements was undertaken. This resulted in the need for additional community engagement on the land lease process and the nature of their consent. In response, the Supplementary Lenders’ Information Package (SLIP) set out additional actions required to align the project with PS7 requirements, that culminated in the development of a Benefit Sharing Framework and the negotiation of a formal community agreement with the Issa Clan (ESAP#21). The framework establishes a structured process for good-faith negotiations, clarification of consent-granting authorities, and documentation of decision-making in accordance with customary governance systems.

Based on available documentation and site-level engagement, some elements consistent with FPIC, particularly informed consultation and use of customary decision-making processes—appear to have been undertaken prior to formalization of the land lease. While meaningful consultation occurred, FPIC was not formally structured, documented, or confirmed in accordance with IFC PS7 requirements at that stage.

The project acknowledges this sequencing and treats FPIC as an ongoing process. Accordingly, the achievement of FPIC is being treated as an ongoing process to be completed during appraisal and prior to construction, with the expectation that consent will be formally documented through a signed Benefit Sharing Agreement between the project and the affected communities, and maintained throughout the project lifecycle through continued engagement. Given the nature of project impacts namely restrictions on access rather than physical displacement, the company has integrated PS 7 requirements into the ESMP, Livelihood Restoration Plan (LRP) and the Benefit Sharing framework, rather than an Indigenous Peoples Plan.

FPIC will be formally confirmed and maintained through a structured process aligned with PS7, building on prior engagement and customary governance arrangements (ESAP#21). The project’s confirmation of FPIC will focus on: (i) the permanent loss of customary land associated with project infrastructure; (ii) the restrictions on land use and access related to safety buffers and operation of the wind farm; and, (iii) the package of agreed mitigation, livelihood restoration, and benefit-sharing measures over the life of the project.

FPIC will be confirmed through additional culturally appropriate consultations and the conclusion of a formal agreement with Issa Clan representatives (ESAP#21), including: (i) village-level engagements conducted in Somali language with traditional male elders, and separately with women and youth groups, allowing time for internal deliberation according to Issa customary practices; (ii) joint meetings at kebele and woreda level bringing together customary authorities, women and youth representatives to deliberate on project impacts, land use implications, and proposed commitments; and, (iii) documentation of consent through a written agreement, translated into Somali, confirming agreed benefit-sharing and community development commitments linked to the use and permanent loss of customary land (ESAP PS7-3). This agreement will serve as confirmation of FPIC and will be concluded prior to the commencement of construction activities affecting customary land.

Proposed Benefit Sharing Framework: The project has established a Benefit Sharing Framework covering the expected 25-year project life. The project will commit to an annual budget in accordance with the finalized FPIC agreement. The project will establish a formal committee to manage the funds, with governance arrangements that reflect a collaborative approach between the project, local administration, and culturally recognized community leadership, ensuring inclusive and locally grounded decision-making.
The benefit sharing framework includes a phased approach to confirming and maintaining FPIC. Phase 1 (construction) focuses on immediate, high visibility projects such as water access, social infrastructure, employment and other activities. Phase 2 (operation) focuses on long-term, sustainable development projects funded by the annual revenue percentage committed by the project. The Benefit Sharing Framework is explicitly tied to the FPIC process. The finalization of the specific funding amounts, the formal establishment of the Trust, and the agreement on the Phase 1 priority projects will be codified in the formal, signed FPIC Agreement between AMEA Power and the Issa Clan leadership prior to the commencement of construction.

Priority investment areas as identified by the community include, education, water infrastructure and access to electricity, among others. The Aysha Community Development Trust will solicit proposals from the community, and traditional leaders will prioritize them based on the Xeer decision-making process. T The transfer of responsibility for the operation and maintenance of community infrastructure will be undertaken after formal agreement with the relevant public authorities and will include considerations on their technical, financial, and institutional capacity to ensure sustainable long-term management.

PS8: Cultural Heritage

The project ESIA, supported by the SLIP and supplementary studies, confirms the presence of both tangible and intangible cultural heritage within the pAoI associated with the Somali-Issa clan. Identified tangible cultural heritage resources consists of burial grounds and ritual sites. The SLIP identifies approximately 43 burial grounds, and three ritual sites located within the project lease area. The identified sites are not formally designated at national or international level and therefore do not meet the criteria for Critical Cultural Heritage under PS8; however, they constitute living cultural heritage of high local significance and require a appropriate protections aligned with PS 8 requirements.

The company will verify all cultural heritage sites and provide a GIS based map of their location. The updated cultural heritage sites map will be validated through consultation with the Somali-Issa clan representatives and where applicable government authorities tasked with cultural heritage in Ethiopia and the company will keep appropriate records of this engagement. The validated map will also show individual and group graves, burial grounds, and ritual sites, along with the necessary buffer zones. Records of engagement with stakeholders will be proof that stakeholders have approved and the information has been included in project layout and construction guidelines. The consolidation and validation of cultural heritage data is required to support detailed project design and layout optimization, through the development of an accurate and validated constraints map that ensures full avoidance of all burial and ritual sites, in line with commitments to protect culturally sensitive features (ESAP#22).

The burial and ritual sites are defined by the Somali-Issa clan as non-replicable, immovable cultural heritage. The community members also confirmed that transferring and relocating bodies is culturally unacceptable. As indicated under PS 4, two of the ritual sites were identified as sensitive receptors to potential shadow flicker impacts. Following finalisation of the noise and shadow flicker assessments, further refinement is required to ensure that cultural heritage considerations are fully integrated into operational management, particularly in relation to safe and continued access to ritual sites. This will confirm site-specific safety buffer zones and set clear guidelines for access, timing, and use to prevent impacts during operations. AMEA will then enhance its operational phase requirements for the Cultural Heritage Management Plan (CHMP) to include site-specific SOPs capturing protection and defined access controls for ongoing community access to the immovable tangible and intangible heritage linked to these burial and ritual sites. The plan will also include chance find procedures (ESAP#22).

Intangible cultural heritage in the project AoI are also connected with the Somali-Issa clan and consist of traditional practices and knowledge systems, namely pastoralist mobility patterns, customary land use systems, traditional dances, and the Xeer Issa customary governance framework. As indicated under PS 7, the Xeer Cisse is recognized by UNESCO under its register of intangible cultural heritage. Based on the ESIA, SLIP, LESA review and as validated through records of community engagement for the project, the intangible cultural heritage is not expected to be directly affected by the project.

Stakeholder engagement for the project has been undertaken through the ongoing E&S risk assessment processes by the client that commenced in 2019. The project consultation approach is broadly aligned with PS1 requirements and is documented in the ESIA and related supplementary studies including the LRP, biodiversity assessments, as well as screening and assessment of impacts on the Somali-Issa clan as an IP community. Community consultations were held at locations and times compatible with pastoral livelihoods and allowed sufficient time for internal community deliberation in alignment with Issa customary law (Xeer Issa). Given the pastoral and clan-based social context of the Project area, engagement has relied primarily on oral communication, use of the Somali language, and engagement through customary leadership structures, with meetings adapted to seasonal mobility patterns and pastoral livelihoods. Information disclosure has been undertaken using culturally appropriate approaches, recognizing low literacy levels and the importance of trusted intermediaries in community decision-making processes. Further details on the level of engagement to date and future engagement requirements are outlined under PS 5, 7 and 8 of this ESRS.

Communities raised concerns about losing customary land, restricted access to grazing, migration routes, and settlement areas. They requested clear information on construction schedules, transport, workforce presence, and safety zones to limit disruption. Community feedback on E&S management included local job opportunities, fair recruitment, traffic and safety risks, social risks from worker-community interaction, and grievance resolution needs. Support for the Project depends on respect for land rights, ongoing access, effective livelihood restoration, benefit-sharing, and community development. The company plans to address these through integrated land management, livelihood support, and consultation in line with Performance Standards 5, 7, and 8. Disclosure of the E&S management plans related to these issues have been undertaken with the communities in the 4 Kebeles and the community elders.

AMEA Power engaged project-affected communities, particularly the Issa Clan and local stakeholders in Aysha 1, Aysha 2, Dagago, and Lasarat kebeles, through targeted disclosures and consultations. These meetings included clan leaders, women and youth groups, and regional authorities to document Free, Prior and Informed Consent (FPIC) and conduct good-faith negotiations. The company shared information about project plans, benefit sharing, stakeholder engagement, and land lease impacts to inform communities about project scope, land changes, risks, benefits, and to gather feedback and agreement on FPIC processes.

Grievance Mechanism.
A Local Community Grievance Mechanism (LCGM) has been established since December 2025 and disclosed to affected communities in the four Kebeles. The LCGM is designed to be accessible, culturally appropriate, and free of charge, with multiple intake channels including grievance boxes at Kebele offices and the project site, direct engagement with Community Liaison Officers (CLOs), and provision for anonymous submissions. The mechanism has been communicated in local languages and adapted to the pastoralist context, including provisions for mobile populations, whose grievances may remain open until they return to the project area or alternative contact is established.

The LCGM is intended to serve as the primary mechanism for addressing grievances related to land acquisition, livelihood restoration, and benefit sharing under the LRP, and these cases will be tracked separately to ensure focused monitoring of displacement-related impacts. So far, there are no grievances logged into the system. Nonetheless, the mechanism is operational in advance of construction and prior to full ESMS roll-out, ensuring that the PAPs including seasonal pastoralist users, have access to a formal grievance process during LRP planning and early implementation. Over time the LCGM will adjust to handle construction and operation phase related grievances.

Project affected communities in the 4 Kebeles have been sensitized about the grievance mechanism through community disclosure meetings. The company will align the community GRM with other project-level processes, including the Worker Grievance Mechanism, specific measures for SEA/SH and specific measures for responding to community complaints related to the project security personnel (ESAP#23).

AMEA will disclose the ESRS-ESAP at the following addresses: Aysha Woreda Administration Office and Project Affected Kebele Administration Offices of Aysha 1, Aysha 2, Lasarat and Dagago in Ethiopia.

Additionally, AMEA has disclosed project details and key documents on their own website: https://www.ameapower.com/aysha/

Any queries and/or comments about the project may be directed to:

Vito Saluto
Head of ESG
AMEA Power
Marina Plaza Office Tower
Dubai, United Arab Emirates
+971 4 222 2499
Vito.Saluto@ameapower.com

Broad Community Support is in progress for this project. FPIC verification is under progress. A visit will be planned after disclosure and before Board review.

S.no	Description	Anticipated Completion Date
1	Develop and maintain a permit register for both construction and operation stages of the project and obtain all required E&S related permits for these stages.	03/31/2027
2	(a) Develop a project-specific E&S management system (ESMS) covering both construction and operation stages of the project. The ESMS to be based on AMEA’s corporate management systems and shall operationalize the AMEA Power policies at a project level. The ESMS will include E&S management plans, communication, training, monitoring, and audit requirements and a legal and permit register for the project. (b) Implement the ESMS for construction and operation stages of the project. The implementation will include translation in local languages and inclusion of relevant provisions and requirements in the contracts signed with the Engineering, Procurement and Construction (EPC) and Operation and Maintenance (O&M) contractors. ESMS to include training plan for both construction and operation stages. [Expected Timeline for Operations ESMS: Prior to Start of Operations]	03/31/2027
3	Update the rapid cumulative impact assessment (RCIA) in order to be compliant with IFC PSs, including: (a) covering all other projects (e.g. Aysha III WPP); (b) identifying and assessing additional valuable environmental components (VECs) including social risks, noise and shadow flicker impacts and ecosystem services; (c) completing adequate stakeholder consultations in VEC selection and their significance; (d) aligning with the outcomes of the critical habitat assessment (CHA), PS6 and IFC CIA guidance; and(e) including a clearly defined cumulative impact management and monitoring framework with defined roles, coordination mechanisms, or decision making processes.	07/30/2027
4	(a) Ensure early mobilization of suitably qualified E&S staff, clear delineation of roles and responsibilities between APAWO and the EPC/O&M contractors, and adequate resourcing to ensure effective implementation, oversight, and reporting of E&S performance.(b) Appoint a Biodiversity Manager within the project company with experience delivering wind-wildlife programmes that meet IFC PS6, who will oversee and report on all project mitigation and monitoring activities included in the project’s biodiversity management plan.Once the EPC contractor is appointed: (c) An updated EPC Contractor organisational chart to be provided, clearly detailing E&S, HSE, Security, HR, and labour compliance roles and reporting lines across all project entities.(d) A contractors’ recruitment and mobilization plan detailing E&S, OHS, HR, and labor compliance roles and reporting lines across all project entities and a commitment to update this plan in line with evolving workforce numbers, sub-contractor arrangements and project needs.	12/31/2026
5	Ensure operationalization of the ESMP through: (a) Development and implementation of a construction-stage E&S management plan (CESMP) by the EPC contractor; (b) Development and implementation of an operation stage ESMP (OESMP) by the O&M contractor [Expected timeline: Prior to Start of Operations]; and(c) Development of a high-level decommissioning strategy and end-of-life project plan [Expected timeline: Prior to Decommissioning].These plans will include specific plans as described in the ESRS.	03/31/2027
6	(a) Develop on-site facilities to respond to any emergencies involving fire-fighting, medical emergencies and evacuation.(b) Develop and implement comprehensive emergency preparedness and response plans (EPRPs) for both construction and operation phases, covering credible emergency scenarios, roles and responsibilities, coordination with local authorities and communities, communication procedures, training and drills as well as required elements from traffic and security management plans. These arrangements will be integrated into the ESMS, CESMP and OESMP, discussed in actions above.	03/31/2027
7	Establish E&S monitoring and reporting framework for both construction and operation phases, including regular performance reviews, incident reporting, audits, and corrective action tracking, to support adaptive management and lender reporting. The framework will include requirements from the ESMP. Also, the relevant components of the framework will be operationalized within the CESMP and OESMP.	07/31/2027
8	(a) Development of project specific HR policies as well as labor code of conduct, aligned with the project company’s HR policies and Procedures, IFC PS2, and national labor legislation and will be made accessible to all workers in the main language(s).(b) Development of a project specific labour and working conditions management plan, also including with provisions on non-discrimination, equal opportunity and anti-harassment. This will be part of the ESMS, CESMP and OESMP.	03/31/2027
9	Develop a contractor and supply chain management plan which will describe how labor and working conditions and occupational, health and safety (OHS) practices will be actively reinforced and monitored through contractors/subcontractors' performance. The plan to describe various procedures for prequalification, onboarding, compliance monitoring, and oversight of all contractors, subcontractors, and suppliers to ensure adherence to the project’s labor and working condition standards, including reporting and audit requirements.	03/31/2027
10	Contractors to develop and implement a Workers Grievance Mechanism (WGM) and integrate with other management plans with respect to typical high risk issues such as worker accommodation and transport arrangements. WGM to cover all contractors and sub-contractors’ workforce.	07/31/2027
11	Develop and implement a project-specific workers’ accommodation management plan as part of the project ESMS and aligned with IFC/EBRD/AfDB workers’ accommodation standards. The project company will review and agree on the worker accommodation plan with the EPC contractor. The plan should full reflect the accommodation needs of the EPC Contractor and all subcontractors and relevant elements shall be integrated in the CESMP and OESMP. The accommodation design to also consider the heat stress management measures.	03/31/2027
12	Undertake a best practicable environmental option (BPEO) for identifying: (a) Sustainable water sourcing solutions that avoid adverse impacts on community water access in consultation with the community, relevant authorities and the EPC contractor. The assessment to consider source yield /availability, legal access and permitting requirements, potential competition with community use and any water quality treatment needs. Include the selected options in the project-specific ESMS and contractors’ E&S management plans.(b) Waste management and disposal options to identify proper storage, handling, treatment, recycling, and disposal options for various waste streams, and cover the construction, operations and decommissioning phases of the project in line with good international industry practice. Include the selected options in the project-specific ESMS and contractors’ E&S management plans.In the event that an onsite solution is selected, permitting, procurement, account O&M implications and associated capital and operating costs into the project budgets. In the event that external companies are preferred to manage waste, conduct appropriate ‘Duty of Care’ due diligence before executing the formal service agreements to verify their compliance with Applicable Standards. (c) Feasible wastewater management options, including on-site packaged wastewater treatment systems and incorporate the selected approach into project-specific ESMS and contractors’ E&S management plans for construction and operation, including permitting, effluent quality controls, monitoring, and emergency response measures, to ensure protection of soil, groundwater, and community health.	03/31/2027
13	(a) Conduct a route-specific road risk assessments to identify communities, pastoralist routes, livestock crossings, schools, markets, and other social receptors, and assess road conditions, and peak risk sections along the transport corridor both from community and workforce safety. Identify specific mitigation measures and incorporate them in the community health and safety management plan (discussed below). The RRA to be reviewed periodically and revised as necessary, including in response to a road traffic incident, community safety incident, or near miss.(b) Develop a community health and safety management plan which incorporates influx management, prevention of community exposure to disease (e.g. health screening, hygiene promotion, code of conduct enforcement, and coordination with local health authorities), safety considerations related to infrastructure design and siting, traffic and transport safety, and emergency response planning.	03/31/2027
14	(a) Assess the likely impacts on seasonal pastoralists, livestock and ritual sites to better understand the level of shadow flicker (SF) impact,consult with the communities to develop and implement the required additional mitigation measures as needed.(b) Develop and implement a systematic monitoring process of land use, to be carried out during seasons of the year when nomadic herders use the northern area impacted by SF impacts [Expected Timeline: Prior to Operation]; (c) Engage with the affected herders and seasonal pastoralists and include them in the Stakeholder Engagement Plan (SEP), in order to inform and consult them about the project’s impacts, its E&S plans, prevention and mitigation as well as the grievance mechanism [Expected Timeline: Prior to Operation](d) Conduct additional noise modelling to: • assess incremental impacts in Degego Kebele where noise levels may exceed WBG EHS guidelines during night time; • include highway’s contribution in the noise modelling as a separate layer and confirm exclusion of the railway line and its rationale; and • assess impacts on seasonal dwelling receptors in the mapped northern temporary dweller areas and the cultural heritage sites. Based on revised modelling and impact assessment, identify required mitigation measures to be implemented by the project and include them in the ESMP.	07/31/2027
15	(a) Complete a conflict sensitivity analysis for the project, to inform the security risk assessment (SRA). (b) Update the SRA to address gaps identified in the ESIA and a security management plan (SMP) in line with AMEA’s security policy. (c) Develop and implement a security code of conduct, integrated into the SMP, covering rules of engagement, proportional use of force, cultural awareness, community-security interaction protocols, and procedures for coordination with public security forces. The security code of conduct will complement the general workforce code of conduct and be applied to all private security personnel and any public security forces deployed to support the project.	07/31/2027
16	As part of the detailed design process and the siting of project components:(a) Ensure that residences and areas of importance for livelihood activity, including water points and any vital grazing routes / areas, have been identified and decisions on siting are made to minimise any displacement. This should be confirmed as part of the documentation for detailed design and a summary given in an update to the LRP. (b) Determine whether any project components need to developed outside of the lease area or cause displacement impacts beyond those already envisaged in the LRP, and must assess whether any upgrading or use of the access routes from the port to the project area will create physical or economic displacement. If displacement impacts from these components / activities are expected then the LRP will be extended (or a supplemental RAP or LRP be developed) and shall be implemented in line with the requirements of PS5.	03/31/2027
17	(a) Update the LRP to: • Provide additional detail on the livelihood support measures and support to vulnerable people, and particularly on the scope, timing and implementation process for fodder support as a transitional support measure. This should include consideration of how mitigation will support land users from outside the local communities. This update should be provided once communities have confirmed preferences for the livelihood support measures and prior to the start of construction.• Include the commitment that monitoring during LRP implementation will include collection of feedback on livelihood impacts and satisfaction indicators so as to provide an early warning of any corrective actions required in LRP implementation. This could include focus groups and should start within one year of the start of construction. [Expected Timeline: Prior to Start of Construction] (b) Implement an independent LRP completion audit to assess whether the LRP has been implemented as planned and that livelihoods have been restored [Within the agreed period after LRP implementation]. If necessary, the completion audit should define corrective actions and these should be addressed before this action can be closed. The LRP should be publicly disclosed in full or summary form.	12/31/2029
18	To address strengthen the biodiversity baseline and inform mitigation and adaptive management, undertake a program of biodiversity surveys, in accordance with the biodiversity management plan (BMP) including: • Flora (incl. invasive species) surveys and habitat condition mapping and assessment• At-height and mist-net surveys for bats • Priority terrestrial fauna surveys • Priority breeding and flight activity bird surveys • Provisioning ecosystem services survey (grazing, water resources). All surveys will be conducted by qualified experts agreed by lenders. Based on the findings from these surveys the project will reassess the outcomes of the CHA and if Critical Habitat is triggered then the project will develop a Biodiversity Action Plan (BAP) and associated Biodiversity Evaluation and Management Plan (BMEP) with credible, lender agreed offsets to achieve net gain for any Critical Habitat features	03/31/2027
19	(a) Implement the construction phase elements in the BMP and develop associated GIIP standard subplans including: • Pre-clearance plan, • Invasive species management plan • Flora and habitat restoration plan• Priority terrestrial fauna protection plan • Priority breeding bird protection plan • Powerline/met mast bird flight diverter installation and maintenance plan.All plans will be implemented by appropriately qualified and experienced experts/consultancies acceptable with lenders.(b) Implement the operation phase elements of the BMP. As part of this plan, the project will contract an internationally recognized wind-wildlife expert or consultancy to design and oversee the post-construction fatality monitoring (PCFM), observer-led shutdown on demand (OLSDOD), bat curtailment and raptor food management programs. The expert will be retained for the first three years to provide ongoing technical support to these programs and other operational phase monitoring, mitigation and reporting actions in the BMP. The OLSDOD program will be implemented using observers specifically trained and experienced in turbine shutdown procedures for birds. For the PCFM program the wind wildlife consultancy will train and oversee a locally contracted ecological consultancy to implement the program. The PCFM, OLSDOD, and bat curtailment programmes will be implemented for at least three years and only discontinued with lender agreement following a review of species impacts and mitigation.	03/31/2029
20	Agree on a Benefit Sharing Framework (BSF) that defines the Benefit Sharing Program and proposes the approach to further consultation and for achieving FPIC through the Project lifecycle. The BSF will: • Clarify the status of customary ownership of the Issa Clan in relation to the land covered by the Land Lease Agreement. • Clearly indicate how the Project will engage with Issa clan and sub-clan leaders in a way that aligns with their governance structures; and • Clarify on how the consent of non-local nomadic or transhumant pastoralists will be reflected in the process. BSF will form the basis of the Free, Prior and Informed Consent (FPIC) discussed below.	09/15/2026
21	(a) Organize additional culturally appropriate consultations and the conclusion of a formal agreement with Issa Clan representatives (at least one month after the disclosure of BSF and agreements), including: • village-level engagements conducted in Somali language with traditional male elders, and separately with women and youth groups, allowing time for internal deliberation according to Issa customary practices; and• joint meetings at kebele and woreda level bringing together customary authorities, women and youth representatives to deliberate on project impacts, land use implications, and proposed commitments. (b) Document consent through a written agreement, translated into Somali, confirming agreed benefit-sharing and community development commitments linked to the use and permanent loss of customary land. This agreement will serve as confirmation of FPIC.(c) Demonstrate that ongoing FPIC has been achieved (a) at the start of operations, and then (b) periodically in line with the plan given in the Benefit Sharing Framework [Expected Timeline: Prior to Operations].	09/15/2026
22	(a) Consolidate the Cultural Heritage Assets present within the Project area, through: • Consolidate a Cultural Heritage Constraints Map that verifies, reconciles, and plots all burial sites and ritual locations with accurate coordinates and culturally appropriate buffer zones. • Undertake consultations with relevant cultural heritage authorities and clan leaders to validate the Cultural Heritage Constraints Map. (b) Develop and implement a Cultural Heritage Management Plan (CHMP), which will include:• A chance find procedure • Considerate coordination with affected communities in the case of ritual gatherings being affected by noise or shadow flicker effects. • Site-specific SOPs capturing protection and defined access controls for ongoing community access to the immovable tangible and intangible heritage linked to these burial and ritual sites.	03/31/2027
23	Update the community grievance mechanism to align with other project-level processes, including the WGM, specific measures for sexual abuse/sexual harassment and specific measures for responding to community complaints related to the project security personnel.	07/31/2027