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

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.

The Project is categorized A, according to IFC’s Policy on E&S Sustainability (2012), with potential significant adverse E&S risks and/or impacts that are diverse, irreversible, or unprecedented, due to significant displacement of informal land-users along the railway corridor, significant railway pedestrian safety risks and as the railway crosses the Lope National Park which is a World Heritage Site (WHS). Key E&S risks and issues associated with the Projects are: (i) corporate E&S management systems and staffing to manage the operations in line with IFC PSs requirements; (ii) assurance of fair, safe and healthy working conditions including accommodation for employees and Contractor workers in compliance with country’s labor laws and IFC PS2 requirements (IFC and EBRD Guidance Note on Worker Accommodation); (iii) waste management and pollution prevention in line with World Bank Group (WBG) Environment, Health and Safety (EHS) Guidelines; (iv) railway safety and security management strategy; (v) progressive displacement of informal land users within the railway corridor in alignment with IFC PS5 requirements; and, (vi) implementation of biodiversity management program and biodiversity action plan (BAP) conventions in alignment with the WHS, Lope National Park and IFC PS6 requirements.

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 and E&S Management System: SETRAG has adopted an overarching Environmental, Social and Governance (ESG) set of Policies from the Eramet Group including; (i) Risk Management Policy, (ii) Human Resources Policy, (iii) Policy to prevent protected wildlife trafficking, (iv) Security Policy, (v) Procurement Policy, and (vi) Ethics Charter. Also, SETRAG has developed a Sustainable Development Policy, Human Rights Policy, a Policy against Gender-based violence and an Environmental Good Practice Charter. These policies set out SETRAG’s overarching E&S objectives and principles including compliance with national laws and alignment with the IFC PSs and the World Bank Group (WBG) EHS Guidelines. These policies are operationalized through SETRAG’s E&S Management System (ESMS) manual that was revised in July 2024 to further align with the IFC PSs. Going forward, SETRAG will review and enhance its existing ESMS to account for the new project by including a Phase III Contractors Management Framework to require the development and implementation of a Construction E&S Management Plan (CESMP) and other sub-plans and standard operating procedures (SOPs) commensurate to their scope of work and aligned with SETRAG’s policies, ESMS and IFC PSs. Also, SETRAG will incorporate standard clauses in contracts regarding the E&S and HR staff to be mobilized as well as legally binding provisions for Contractors to align their E&S performance with IFC PSs and WBG EHS Guidelines (ESAP #1).

Identification of Risks and Impacts: In 2015, SETRAG developed an E&S Diagnostic and an E&S Management Plan ('PGES’) for the PRN program. Subsequently, SETRAG has complied with the national requirements and has developed E&S assessments commensurate to the category and scope of the specific rehabilitation projects including full E&S impact assessments (ESIA) for the refurbishment of the Owendo-Kango section (2024) and for sand extraction in Booué (2019), both of which are included in this disclosure. For other isolated activities such as installation of pylons for the traffic management system (TETRA), stabilization of embankment (KP 287 & KP 307), extension of bypasses or new bypasses at stations, the practice has been to develop E&S impact notices (NIES) and obtain relevant regulatory approvals prior to commencement of works. Going forward, SETRAG will enhance its E&S scoping procedure to include a requirement for future ESIAs and / or NIES to meet IFC PSs requirements especially as it relates to analysis of project alternatives, biodiversity and ecosystem services baselines and impact assessment (ESAP #2).

SETRAG addresses physical climate risks including rising temperatures and drier seasons that have led to more frequent fire outbreaks in its E&S assessments. Additionally, SETRAG has organized awareness campaigns with communities and authorities to promote responsible practices and reduce fire risks. Going forward, SETRAG will integrate climate-related safety and operational risks into existing OHS and emergency response systems. This includes: (i) finalizing and implementing the adverse weather procedure; (ii) incorporating measures for extreme heat (e.g., working hours, rest/hydration protocols); (iii) strengthening flood response and drainage maintenance in high-risk areas; and (iv) formalizing wildfire prevention and response protocols (ESAP #3).

Management Programs: SETRAG’s ESMP (PGES) identifies typical risks and impacts associated with the railway modernization project and proposes mitigation measures to address these risks and impacts. In addition to the overarching ESMP, each ESIA/NIES has a framework ESMP specific to the task. Furthermore, the company has developed a comprehensive management program which comprises a series of associated sub-plans and other risk management procedures including (i) Community and Stakeholder Engagement Plan; (ii) Emergency Response Preparedness Plan; (iii) Waste Management Plan; (iv) OHS Management Plan; (v) Hazardous Materials Management Plan; and (vi) Biodiversity Management Plan. Finally, SETRAG assigns specific E&S responsibilities to project managers, environmental officers, community liaison officers, and contractors and integrates training and capacity-building programs like site induction training and regular toolbox talks to ensure personnel are aware of their E&S responsibilities. As part of this IFC financing, SETRAG will develop a Site E&S Pre-clearance Procedure as a management tool for Contractors and SETRAG to ensure that all E&S pre-requisites are met before commencement of work at each specific project, which includes: a) pre-construction E&S assessment and socio-economic inventories; b) safety risk assessment; c) security risk assessment; d) site specific transport risk assessment covering the movement of personnel and materials; e) stakeholder engagement schedule; and, f) construction kick-off coordination process for relevant departments (ESAP #4).

Organizational Capacity and Competency: SETRAG has a sustainable development Direction (DDD) covering social, environmental, biodiversity and energy, as well as safety and security Direction (DHSRFS), covering both workers safety and rail safety/security, both distributed between headquarters and along the railway, with occasional external support. Adequate management capacity has been allocated, notably with the mobilization as of September 2024 of new DDD and DHSRFS Directors supported by over 20 middle management national staff, to ensure SETRAG’s risks and impacts are properly identified, assessed and managed as well as reported to senior management. Also, SETRAG has been monitoring ESAP progress as well as overall E&S performance through monthly steering committees, with participation from all relevant Directorates. As part of this IFC investment, SETRAG will require Contractors (ref. ESAP #1) to deploy a dedicated E&S organizational structure led by an EHS Manager.

Emergency Preparedness and Response: SETRAG has developed and implements an Emergency Preparedness and Response Plan (EPRP or PIU), that outlines procedures for hazard identification, communication systems, emergency resources, and incident management. Additionally, SETRAG has a medical center in Owendo headed by a medical doctor, as well as 8 infirmaries along the railway and 672 staff trained in First Aid. SETRAG’s EPRP was recently updated in 2024 to further align with IFC PS requirements by defining clear roles and responsibilities including those of the incident commander and operations officer, internal and external resources, training, crisis management and approach to various emergency scenarios. As part of this IFC financing, SETRAG will extend its EPRP to cover; (i) accommodations (cités); (ii) revised hazard studies including risks related to hydrocarbon storage facilities; (iii) hydrocarbon spill scenarios including protocols for continuing operations or restarting operations after an incident; (iv) post-incident E&S management procedure; (v) emergencies related to accidents involving passenger trains; and, (vi) revised emergency response tiering, including conventions with external support services and combined drills for Tier III response (worst case scenario) (ESAP #5). Also, SETRAG will procure four fire trucks for its main stations and secure onboard medical service providers and response teams on passenger trains.

Monitoring and Review: SETRAG has an internal audit procedure which defines the purpose, authority, and responsibilities of the internal audit function. It outlines the audit’s independence, reporting structure, scope, and adherence to international standards and includes provisions for audit planning, reporting, quality assurance, and consulting services. Also, the ESMP includes monitoring requirements, as well as schedule and responsibilities. Additionally, The ESMS Manual identifies KPIs and defines monitoring and control measures. Finally, SETRAG has a tool to track Key Performance Indicators (KPIs) at operation and construction sites. As part of the Contractors Management Framework for Phase III activities (ref. ESAP#1), SETRAG will include requirements for monitoring key E&S indicators, levels of E&S monitoring and a clear reporting structure, ensuring reported issues can reach the client’s upper management as necessary.

PS2: Labor and Working Conditions

SETRAG currently employs 1,711 full time employees with permanent or fixed term contracts split into 83% male and 17% female. This workforce is divided into categories: 306 managers, 843 supervisors, and 562 workers. Additionally, SETRAG utilizes up to 2570 contract workers, from external service providers, that are engaged in providing services such as health, waste and water management, energy production and distribution, worker accommodations upgrades, railway repair and maintenance and security. SETRAG workforce is not expected to change with Phase III rehabilitation works. Any additional workers will be provided by Contractors, and their numbers will be based on workforce needs at each segment of railway (estimated around 150 to 200 persons at a given time). It is expected that both Company and Contractor workers will be deployed across the refurbishment sites at any given time.

Human Resources Policies and Procedures: SETRAG has set up a dedicated HR department led by an HR Director and implements labor practices in compliance with the Gabonese Labor Law. SETRAG’s labor and working conditions are set out by the Eramet Group HR policy, SETRAG’s Code of Conduct or Règlement Intérieur, Collective Agreement (2021) with associated procedures outlining the principles, commitments and guidelines in relation to labor recruitment and management, applicable across all operations and for all direct employees including; induction, performance evaluation, disciplinary practices and termination, and terms of employment (wages, benefits, working hours, overtime, rest days, breaks, and leave). SETRAG’s HR management system is aligned with IFC PS 2 requirements and ILO Conventions, in relation to workers’ organization, forced labor, child labor, non-discrimination, gender-based violence, and health and safety as well as working conditions and rights.

Working Conditions and Terms of Employment: HR process encourages non-discrimination and equal opportunity for its staff with over 30% of female within its administration and management. Each worker receives a written contract that outlines the working conditions and terms of employment including salary, working hours, probations, and benefits. Work is performed on the bases of 40 hours a week with overtime computed separately, monitored for each worker to keep it within regulatory limits and paid accordingly. Also, all SETRAG employees benefit from a unified social protection framework.

Workers Accommodation: SETRAG has 1048 building units within the estate included in its concession with 485 housing units occupied by its own workers, 318 housing units occupied by third parties including 55 by government employees, and 106 buildings occupied by community services like schools, health units and community halls. Also, SETRAG provides accommodation for transient workers at a few railway stations to allow train conductors change overs. Since 2023, SETRAG has been implementing a program to rehabilitate workers’ accommodation which covers construction and / or refurbishment of up to 400 houses and is expected to be completed by 2030. However, the housing units assigned to third party users are not included in the ongoing refurbishment program. Further, the upgrade program includes improvement of the water distribution network, which largely depends on water supplied from boreholes installed at 19 locations, not all of which are equipped with potable water treatment systems. In the meantime, drinking water is supplied in the form of bottled water. For Phase III construction works, Contractors may set up temporary accommodation depending on the works locations. As part of this IFC investment, SETRAG will update its accommodation or housing strategy defining minimum standards for third party accommodations under SETRAG management, and detailing the roles and responsibility as well as accountability for maintenance of accommodation ceded to third party as well as ensuring that all project housing units, including Contractor accommodations, align with IFC PS2 requirements (IFC and EBRD Guidance Note on Worker Accommodation) and are monitored and maintained regularly (ESAP #6).

Workers’ Organization: SETRAG does not prohibit the freedom to associate and workers right to form and join workers organization. SETRAG has 11 unions represented and 82 staff elected representatives. Staff representatives are elected as per the Labor Law regulation stated in the Collective Agreement. Union activities include regular monthly meetings with the 82 elected staff delegates, providing employees with a platform to address concerns. Currently five out of 11 unions comply with administrative requirements, others face delays in fulfilling obligations such as account management and office renewals. Also, SETRAG conducts social dialogue through the Health and Safety Committee (CSST) and Economic and Social Consultation Committee (CPCES). Furthermore, the unions serve as one of the uptake points for typical employee’s grievances like working conditions, housing, transportation, and health. Finally, SETRAG maintains engagement between management and unions and supports ongoing cooperation and responsiveness to workforce issues.

Gender: SETRAG completed gender-based violence (GBV) awareness campaigns in 2024 for authorities, subcontractors, service providers, and employees. Also, capacity building and support were provided to GBV champions and community representatives. GBV champions are deployed at each principal train station. As part of the ESMS update and implementation, requirements for GBVSH sensitization will be cascaded to the Contractors through the Contractors Management Framework (ref. ESAP#1).

Workers Grievance Mechanism: SETRAG developed and is implementing a workers grievance mechanism for its internal workforce (updated in May 2023). The mechanism starts informally with the immediate manager, then progresses to a formal written process if unresolved. However, the workers are free to lodge a complaint directly without going through their supervisor or manager. The formal process includes the right to accompaniment, confidentiality, thorough documentation, written communication of outcomes, and an impartial appeal process. Also, a confidential reporting platform has been enhanced to allow all parties, including service providers, to file complaints, including anonymous complaints. Most of the complaints made on this platform are related to pay, working conditions, and management. Furthermore, SETRAG manages GBVSH by partnering with Agir pour le Genre to conduct awareness campaigns and provide capacity building and support for GBV referents and community relays among employees, subcontractors, service providers, and local communities. The GRM is segregated such that gender-based violence complaints are handled by a separate department (ICT). Finally, the Eramet Group whistleblowing system is available to all employees and stakeholders.

Occupational Health and Safety: SETRAG has a structured approach to risk management and safety oversight within the organization under its QHSSE Directorate. This Directorate is organized into dedicated departments covering OHS and emergency response, railway safety, and security (railway police). Key safety indicators are monitored, such as accidents, high-potential events, and near misses using an Eramet Group software (SAFEE). Additionally, procedures are in place for incident management. Workplace safety culture is maintained across the company and OHS requirements including regular training are included in Contract provisions for service providers and contractors. Finally, SETRAG addresses both work-related and general health issues among employees, such as malaria and musculoskeletal disorders, with support from the National Social Security Fund. The total recordable injury frequency rate (TRIFR) has dropped significantly from 4.4 in 2020 to 0.7 in 2024, below the Group target threshold of 1 (corresponding to very good safety level for similar sectors).

Workers Engaged by Third Parties: SETRAG works with around 206 service providers who deploy a total of 2570 workers across the PRN program. Contractors are mandated through contractual clauses to comply with national labor laws, SETRAG’s EHS requirements (including SETRAG’s commitments to its lenders), and code of conduct. They receive safety training from SETRAG and are managed via a procedure that includes pre-qualification on E&S topics and OHS oversight. Contractors and service providers performance is reviewed annually by the Procurement Directorate, with inputs from other departments including E&S criteria especially compliance with local labor requirements.

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency: SETRAG’s primary activity is transportation, relying on fossil fuels for train operations. Water resources are also utilized; however, no processing of water resources occurs within the company’s activities. SETRAG actively promotes energy efficiency through its projects and operational initiatives, with most of its electricity sourced from the national grid.

Water is supplied by the Société d’Énergie et d’Eau du Gabon (SEEG) in areas close to urban centers. In remote locations, SETRAG operates 19 boreholes that provide non-potable water for accommodations. Since 2023, in alignment with Eramet Group requirements, the company has monitored both water and energy consumption. Between 2022 and 2023, SETRAG reduced water usage by 51%, down to 188,600 m³, by focusing on responsible water use and conservation, incorporating measures such as water-efficient infrastructure design and high-efficiency plumbing fixtures within its housing upgrade program.

GHG Emissions: SETRAG is implementing an energy management system (ISO 50001) and plans to conduct feasibility studies for solar panel installations to reduce its carbon footprint. In 2024, Setrag generated 19,781.7 tCO2e of Scope 1 emissions from use of 7,408.9 m³ of fuel and 2,661.5 tCO2e of Scope 2 emissions from use of 4,612.7 MWh of grid electricity. The railway modernization program is not expected to increase SETRAG’s Scope I and Scope 2 emissions beyond 25,000 tCO2e per year. However, SETRAG will continue to track its resource use and monitor and report its Scope 1 and Scope 2 GHG emissions as part of its ongoing corporate E&S monitoring requirements.

Pollution Prevention and Control: SETRAG developed and is implementing a Pollution Prevention and Remediation Management Plan (PPRMP, 2020) for 23 SETRAG sites that were subject to an assessment along the railway. The plan addresses the management of operational pollution sources, pollution prevention equipment, and contaminated soil and groundwater. Implementation during Phase II works has included developing pollution prevention procedures; upgrading hazardous materials storage and filling station areas; installing oil-water separators and spill prevention equipment at maintenance workshops and filling stations; installing secondary containment at diesel storage locations; and excavating and treating some of the contaminated soils. As part of this IFC financing, SETRAG will update and implement its PPRMP to include (i) the installation of oil/water separators; (ii) the clean-up of contaminated sites and proper elimination of contaminated soils; and (iii) monitoring of groundwater where there is potential for contamination, in accordance with Setrag’s PPRMP and in alignment with IFC PS3 requirements (ESAP #7).

SETRAG has completed a full integrity assessment of the 40-years-old fuel storage and distribution network at Owendo after a spill incident in August 2024. Going forward, SETRAG will revise its EPRP to include post-incident protocols (see ESAP #5) and will complete soil and groundwater sampling to evaluate contamination, followed by further remediation as needed and in accordance with agreed protocols under ESAP #7. Also, SETRAG will: (i) clearly define responsibilities and maintenance program for all hydrocarbon storage and distribution infrastructures along the railway; and (ii) propose a structural remediation plan for buried distribution lines at its Owendo facility, in line with the recommendations of the post incident integrity assessment report (ESAP #8).

In August 2023, a fire incident was reported at the storage facility for used creosote-impregnated wooden sleepers in Booué, leading to soil sampling to evaluate environmental dioxin contamination. In September 2025, another fire incident occurred at the same facility. As part of this IFC financing, SETRAG will conduct additional sampling at the Booué site impacted by fire to assess dioxin contamination risks in cultivated areas and subject to the analyses develop and implement site remediation measures aligned with IFC PS3 requirements and WBG General EHS Guidelines (ESAP #9).

Hazardous Materials Management: Hazardous materials handled at the SETRAG sites include hydrocarbon products like hydraulic oils, used filters, batteries (e.g., lead-acid or lithium-ion), electronic parts (e-waste), as well as paints products. SETRAG has developed and is implementing a Hazardous Materials Management Plan (HMMP) since 2023 including procedures for transportation, storage, handling, spill response consistent with statutory legal requirements and aligned with WBG EHS Guidelines. Going forward, SETRAG will require its Contractors (ref ESAP #1) to adopt and implement procedures consistent with the HMMP and to deploy adequate spill kits and response capability at its worksites and facilities.

Waste Management: SETRAG’s rail refurbishment produces typical construction waste including wood, cardboard, plastic, cables, metal scraps, and domestic refuse as well as hazardous waste such as spent batteries, hydrocarbon-contaminated items, and creosote-treated wooden sleepers. SETRAG’s Waste Management Plan (WMP) covers both general and hazardous waste from all locations, with clear procedures for collection, segregation, storage, and disposal per national regulations. The process prioritizes minimization, reuse, and recycling, and is also applicable to contractors. Hazardous waste is collected separately by authorized providers and sent to Owendo via a "green wagon" for proper processing, while non-hazardous waste is eliminated locally at municipal disposal sites. Also, SETRAG is completing feasibility studies towards the development of a landfill in Booué. As part of this IFC financing, SETRAG will prohibit the use of waste disposal sites with no environmental controls and enhance its waste management strategy by (i) developing a site-specific WMP for Lope NATIONAL Park to meet the Park and UNESCO WHS E&S requirements; and (ii) developing and implementing a regulatory compliant non-hazardous waste management solution aligned with IFC PS 3 requirements for waste generated at Booué; and (iii) confirm disposal strategy for creosote-impregnated waste sleepers including timeline and budget (ESAP #10).

Waste creosote-impregnated wooden sleepers generated by the railway refurbishment program are collected and stored by SETRAG pending proper elimination. It is estimated that approximately 1 million contaminated sleepers will be replaced with concrete sleepers. Pyrolysis has been confirmed as the preferred option for waste wooden sleepers disposal following a feasibility study conducted in 2024. Furthermore, a disposal pilot will be completed in 2026. SETRAG will confirm its used wooden sleepers disposal option (ref. ESAP #10) ensuring that resulting emissions meet applicable standards.

Wastewaters: Domestic wastewater from workers accommodation estates are mainly treated via septic systems. Industrial wastewater from equipment maintenance activities and hydrocarbons storage areas are treated via oil water separators. Installation of oil water separators is complete at the main stations (Owendo, Franceville, Booué, Ndjolé) but ongoing at intermediate and small stations, in accordance with the PPRMP. The Booué cite, which is the principal accommodation estate with about 300 housing units, is connected to a dysfunctional wastewater treatment plant. SETRAG is undertaking a survey of all wastewater systems in place for both industrial and domestic sources and refurbishment needs. Going forward, SETRAG will enhance its wastewater management program to comprehensively address all wastewater, including both industrial and domestic effluents and encompassing: (i) mapping of all discharge points and existing treatment systems; (ii) upgrading or replacing non-functional sewage treatment systems at its facilities including in Booué; (iii) developing and implementing a wastewater monitoring plan compliant with IFC PSs (ESAP #11).

PS4: Community Health, Safety and Security

Community Safety: Railway safety and security topics are managed by the DHSRFS Direction. SETRAG has conducted several audits of its rail operational safety management system since 2021, with emphasis placed on general rail operations safety, transport of dangerous goods, level crossing safety, and pedestrian safety. A corrective action plan was developed and is more than 90% implemented. Procedures are in place for incident management, including collisions and emergency response, and the company collaborates with authorities for crisis management. Furthermore, SETRAG has established a comprehensive maintenance and inspection program for wagons and locomotives, with routine preventive checks to ensure operational safety and ongoing modernization of its rolling stock.

During construction, contractors implement various measures to safeguard community health and safety during rail refurbishment projects. These include risk assessments, safety awareness for residents, installation of safety signs and barriers, emergency response plans, and traffic risk management. During operations, key operational safety concerns involve pedestrian access, unauthorized crossings, breaches of perimeter walls, encroachment by informal settlers and businesses, and the risk of train accidents or collisions involving the community. Under the PRN program SETRAG has implemented railway safety improvements including erection of walls between PK00 and PK02, installation of six pedestrian bridges, out of 15 planned and is currently securing 28 level crossings with automated gates and signage. Also, SETRAG is revising its overall railway safety strategy for the entire railway, with a particular focus on addressing the complexity of the KP 02 – KP 17 area specifically and in consultation with an interministerial commission created as part of amendment 4 of the concession and in charge of infrastructure development in the vicinity of the railway between KP 00 – KP 34. Finally, SETRAG has implemented railway safety awareness campaigns including the rollout of a “Zero collision” communication campaign in schools and markets and training sessions with community leaders and municipal agents. Public awareness campaigns dropped in 2024 compared to 2023. As part of this IFC financing, SETRAG will develop a railway safety strategy implementation plan that includes; (i) an E&S risk assessment to cover the safety strategy implementation program; (ii) a communication plan for PAPs, focusing on managing unmet expectations as well as a dedicated stakeholders engagement plan that strengthens collaborations with the national authorities, municipalities and utility companies; and (iii) an updated community railway safety awareness program with a detailed annual schedule of continuous sensitization across the critical areas along the entire railway. and (iv) interim community safety measures for the PK2–PK17 railway corridor pending implementation of the final railway safety strategy (ESAP #12).

Life and Fire Safety. Setrag completed a fire safety assessment of its stations and facilities and has been implementing corrective measures to mitigate risks across various railway stations and accommodation estates. SETRAG will augment its L&FS emergency response arsenal (ref. ESAP#5) by; (i) procuring four fire trucks and related resources; (ii) securing onboard medical service providers and response teams for passenger trains; and (iii) implementing interim fire prevention and firefighting measures prior to fire trucks commissioning.

Following a fire that occurred in August 2023, the Booue wooden sleepers storage area has been fenced to prevent intrusion and fire risks and protected by security agents. In September 2025, another fire incident occurred at the same facility. Going forward, SETRAG will collect all the used wooden sleepers along the segments of railway where repair works have been completed and fully implement the defined storage plan and fire prevention and control measures at the Booué used sleepers storage area (and any other storage areas), including deploying interim firefighting measures pending the procurement and commissioning of a fire truck (ESAP #13).

Security Personnel: SETRAG’s railway police department has over 60 sworn agents, trained in technical and legal aspects, as well as engagement with the communities. The railway police are responsible for safety and security of trains and stations. Also, SETRAG employs over 190 security agents from private security providers for the protection of its infrastructure, as well as for manning some manually operated level crossings. SETRAG applies Eramet Group’s procedure on Security and Human Rights (2023). In 2023, all agents of the railway police and security agents were trained on the Voluntary Principles on Security and Human Rights (VPSHR). Finally, SETRAG is considering collaboration and help from state security in dealing with some of the ongoing third-party activities within the safety corridor of the railway especially in the KP 00 – KP 17 section and will discuss the roles of engagement within the railway safety supervisory committee (ref. ESAP #12) commissioned as per amendment 4 of the concession agreement.

PS5: Land Acquisition and Involuntary Resettlement

Potential physical and/or economic displacement will be associated with (i) securing the railway corridor as part of the PRN programs (building of barriers and pedestrian overpasses); (ii) replacement of railway track in unstable areas; and, (iii) extension of bypasses and installation of new bypasses in some stations. These activities will require the relocation of structures (houses, sheds, farms/gardens, bar/restaurants and other small businesses) within the safety zone and the economic and / or physical displacements of informal users within the existing railway safety corridor which has been heavily encroached over the years. The potential economic and physical displacement required during SETRAG III is estimated at about 500 people, and this number may vary on the basis of the railway safety strategy to be approved as per ESAP#15. The most significant displacements initially forecasted in the PK2-PK17 corridor to ensure operational and also pedestrian safety is expected to reduce once the railway safety strategy is revised.

SETRAG has developed a Resettlement Policy Framework (RPF) (2015) that was finalized in 2022 aligned with IFC PS5 requirements, requiring the planning and implementation of a plan in the event of economic and/or physical displacement, guided by clear eligibility criteria, compensation framework and consultations with the PAPs. SETRAG develops and implements Resettlement Action Plans and Livelihoods Restoration Plans (RAPs/LRPs) prior to commencing each sub-project on a rolling basis aligned with its approved RPF. SETRAG will: (i) provide the schedule for new and ongoing RAPs or LRPs for sub-projects requiring displacements including associated budgets for IFC approval; and, (ii) provide the schedule for the conduct of mid-term and completion audits for each RAP/LRP project in accordance with IFC PS5 requirements (ESAP #14).

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

Biodiversity Conservation. The railway traverses several ecologically significant areas, including Lopé National Park (a UNESCO World Heritage Site (WHS), designated 20 years after the construction of the railway) and Ramsar wetlands of Bas Ogooue, Chutes et Rapides sur Ivindo and Rapides de Mboungou, Badouma et Dome. Outside suburban areas, the project is situated in largely Natural habitat. The project area of influence is situated in Critical Habitat for values including African forest elephant, western gorilla, and central chimpanzee, amongst others. SETRAG’s railway modernization project is restricted to refurbishing existing infrastructure within the current railway footprint, except in relation to emergency slope stabilization. The additional footprint in Natural habitat related to these activities is not significant. There will be no significant increase in rail traffic although the improved railway will support longer trains; as such, significant impacts to biodiversity values are not expected from operation activities.

SETRAG drafted a Biodiversity Action Plan (BAP) as part of the project impact identification process in consultation with the Gabonese National Park Agency, the Ministry of Water and Forests responsible for anti-poaching patrolling, and WWF. Although no significant impacts on Critical Habitat values are anticipated, the BAP has been updated, and a Biodiversity Monitoring and Evaluation Plan (BMEP) has been developed. The BAP addresses residual impacts on Natural Habitat, outlines mitigation strategies, and includes additional conservation actions. Initial consultation with the IUCN Species Survival Commission (SSC) Primate Specialist Group (PSG) Section on Great Apes (SGA) (known as the ARRC Task Force), has guided the inclusion of key mitigation measures into the BAP such as prevention of disease transmission to wildlife.

As examples of conservation actions, SETRAG enforces an anti-poaching policy, collaborates with conservation organizations, prohibits bushmeat consumption and has workshopped efforts to reduce train collisions with wildlife, particularly with elephants. Two BAP implementation conventions have been established between the state regulatory authority (Ministry of Water, Forest and Fauna) for the implementation of the anti-poaching and anti-collisions actions stemming from the BAP. SETRAG has hired a biodiversity manager to oversee implementation of the BAP and BMEP and contracts an independent consulting firm for biodiversity support. Going forward, SETRAG will i) provide a budget and resourcing plan for the implementation of the BAP conventions and ii) deploy a biodiversity specialist / an independent biodiversity consulting firm to supervise contractors performing upgrade works inside Lopé National Park (ESAP #15).

Engagement with relevant conservation stakeholders associated with legally protected areas and internationally recognized areas is ongoing. SETRAG has assessed risks and impacts to ensure the Outstanding Universal Values (OUVs) of the WHS are protected, with findings documented in the NIES for KP 287 stabilization works reviewed by ANPN and UNESCO. The NIES covering further works at KP 307 and stations within the Lope National Park are being processed and SETRAG will secure necessary approvals and non-objections before commencing works within Lopé National Park as per regulatory requirements.

SETRAG updated its Stakeholder Engagement Plan (SEP) in 2024 to cover engagement with both communities and authorities and further align it with IFC PS1 requirements. The SEP emphasizes the importance of launching stakeholder engagement activities at the early stages of a project aiming to consult, inform, and involve stakeholders, to develop partnership. Also, SETRAG has made strides in community consultation by establishing 28 Community Level Committees (nine of which are along the PK 00 – PK 17 railway segment), each managed by a local chief, to facilitate regular exchanges on railway projects, safety concerns, displacement issues, and grievances management. Meetings are held several times each quarter, with documentation and reports transmitted to SETRAG. The committees serve as vital relays between SETRAG and the affected communities, supporting safety awareness initiatives and enabling swift sharing of information.

SETRAG has developed an external grievance mechanism (2023) in line with PS1 requirements, which has been disseminated to staff and communities along the railway. This mechanism allows anyone who feels affected by SETRAG’s projects or activities to express their concerns by submitting a complaint form. Several channels for reporting complaints exist: community leaders, local authorities, complaint boxes at stations and direct contact with SETRAG stakeholder engagement team. All complaints are registered in the SAFEE tool. The anonymous complaint pathway via mailboxes at each station further supports confidentiality and inclusivity. Complaints are primarily centered around illegal occupation of corridors, noise nuisance, and safety concerns.

SETRAG’s structured approach to grievance management and the integration of community committees highlight its commitment to fostering constructive dialogue and addressing external concerns in its railway modernization project. SETRAG has also been engaging with ANPN/UNESCO and ARCC with regards to activities and works in Lopé Park. Going forward, SETRAG will update and implement its Stakeholder Engagement Plan to include new stakeholders (ref ESAP #12) associated with new work areas and newly adopted strategies.

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	SETRAG will enhance its existing ESMS to account for the new project by including a Phase III Contractors Management Framework that (i) guides the development and implementation of a Construction E&S Management Plan (CESMP) and other sub-plans and standard operating procedures commensurate to their respective scope of work and aligned with SETRAG’s policies, ESMS and IFC PSs and (ii) incorporates standard clauses in contracts requiring E&S and HR staff to be mobilized as well as legally binding provisions for Contractors to comply with IFC PSs.	08/27/2026
2	SETRAG will enhance its E&S scoping procedure to include a requirement for future ESIAs/NIES to meet IFC PSs requirements especially as it relates to analysis of project alternatives, biodiversity and ecosystem services baselines and impact assessment.	08/27/2026
3	SETRAG will integrate climate-related safety and operational risks into existing OHS and emergency response systems. This includes: (i) finalizing and implementing the adverse weather procedure; (ii) incorporating measures for extreme heat (e.g., working hours, rest/hydration protocols); (iii) strengthening flood response and drainage maintenance in high-risk areas; and (iv) formalizing wildfire prevention and response protocols	02/23/2027
4	SETRAG will develop a Site E&S Pre-clearance Procedure that includes coordination requirement ahead of site-specific activities for a) pre-construction E&S assessment including socio-economic inventories, b) safety risk assessment, c) security risk assessment d) site specific transport risk assessment covering the movement of personnel and materials, e) stakeholder engagement schedule, and f) construction kick-off coordination process for relevant departments. This procedure will be used as a management tool for Contractors and SETRAG to ensure that all E&S pre-requisites are met before commencement of work at each specific project site.	08/27/2026
5	SETRAG will extend its EPRP to cover; (i) accommodations (cités); (ii) revised hazard studies including risks related to hydrocarbon storage facilities; (iii) hydrocarbon spill scenarios including protocols for continuing operations or restarting operations after an incident; (iv) post-incident E&S management procedure; (v) emergencies related to accidents involving passenger trains; and, (vi) revised emergency response tiering, including conventions with external support services and combined drills for Tier III response (worst case scenario) and (vi) procure four fire trucks for its main stations as well as secure onboard medical service providers and response teams on passenger trains.	05/28/2028
6	SETRAG will update its accommodation or housing strategy defining minimum standards for third party accommodations under its management and detailing the roles and responsibility as well as accountability for maintenance of accommodation ceded to third party as well as ensuring that all project housing units including contractor accommodations align with IFC PS2 requirements (IFC and EBRD Guidance Note on Worker Accommodation) and are monitored and maintained regularly.	11/25/2026
7	SETRAG will update and implement its PPRMP to include (i) the installation of oil/water separators; (ii) the clean-up of contaminated sites and proper elimination of contaminated soils; and (iii) monitoring of groundwater where there is potential for contamination, in accordance with Setrag’s PPRMP and in alignment with IFC PS3 requirements.	02/23/2027
8	SETRAG will: (i) clearly define responsibilities and maintenance program for all hydrocarbon storage and distribution infrastructures along the railway; and (ii) propose a structural remediation plan for buried distribution lines at its Owendo facility, in line with the recommendations of the post incident integrity assessment report.	11/25/2026
9	SETRAG will conduct additional sampling at the Booué site impacted by fire to assess dioxin contamination risks in cultivated areas and subject to the analyses develop and implement site remediation measures aligned with IFC PS3 requirements.	02/23/2027
10	SETRAG will consider alternative disposal options for non-hazardous waste where municipal disposal sites are not operated to acceptable standards and will update its waste strategy to include: (i) developing a site-specific WMP for Lope National Park to meet the Park and UNESCO WHS E&S requirements; (ii) developing and implementing a regulatory compliant non-hazardous waste management solution aligned with IFC PS 3 requirements for waste generated at Booué; and, (iii) confirm its disposal strategy for creosote-impregnated waste sleepers including timeline and budget.	05/29/2027
11	SETRAG will enhance its wastewater management program to comprehensively address all wastewater, including both industrial and domestic effluents and encompassing: (i) mapping of all discharge points and existing treatment systems; (ii) upgrading or replacing non-functional sewage treatment systems at its facilities including in Booué; (iii) developing and implementing a wastewater monitoring plan compliant with IFC PSs.	11/25/2026
12	SETRAG will develop a railway safety strategy implementation plan that includes; (i) an E&S risk assessment to cover the safety strategy implementation program; (ii) a communication plan for PAPs, focusing on managing unmet expectations as well as a dedicated stakeholders engagement plan that strengthens collaborations with the national authorities, municipalities and utility companies; and (iii) an updated community railway safety awareness program with a detailed annual schedule of continuous sensitization across the critical areas along the entire railway. and (iv) interim community safety measures for the PK2–PK17 railway corridor pending implementation of the final railway safety strategy	05/29/2027
13	SETRAG will collect all the used wooden sleepers along the segments of railway where repair works have been completed and fully implement the defined storage plan and fire prevention and control measures at the Booué used sleepers storage area (and any other storage areas), including deploying interim firefighting measures pending the procurement and commissioning of a fire truck.	05/29/2026
14	SETRAG will: (i) provide the schedule for new and ongoing RAPs or LRPs for sub-projects requiring displacements including associated budgets for IFC approval; and, (ii) provide the schedule for the conduct of mid-term and completion audits for each RAP/LRP project in accordance with IFC PS5 requirements.	03/31/2026
15	SETRAG will i) provide a budget and resourcing plan for the implementation of the BAP conventions and ii) deploy a biodiversity specialist / an independent biodiversity consulting firm to supervise contractors performing upgrade works inside Lopé National Park.	05/29/2027