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Environmental & Social Review Summary
Project Number
49581
Company Name
Caspian Sea Azerbaijan Project Company LLC
Date ESRS Disclosed
Oct 27, 2026
Country
Azerbaijan
Region
Europe
Last Updated Date
Oct 27, 2026
Environmental Category
B - Limited
Status
Pending Approval
Sector
Water and Wastewater Utilities
Industry
Infrastructure
Department
Regional Industry INF LAC & EUR
Project Description
The Baku Water Desalination Project (the “Project”) represents part of Azerbaijan’s strategic response to water security and is designed to provide new or improved reliable water access to estimated 1.5 million people. To support this IFC is considering a senior loan towards the construction and operation of a 300,000 m3/day Seawater Reverse Osmosis (SWRO) desalination plant in Sumgayit Chemical Industrial Park, in the Republic of Azerbaijan (the "Project"). The Project is to be developed by Caspian Sea Azerbaijan Project Company LLC (“the Company”), a special purpose vehicle (SPV) established by ACWA (“the Sponsor”), a Saudi-based independent power and desalination company. More information about the Sponsor can be found at www.acwapower.com. The Project is a brownfield development utilizing a former wastewater treatment plant area, and consists of the design, construction, financing, operation and maintenance of a SWRO desalination plant, which will supply potable water to United Water Supply Service of Large Cities (UWSSLC), the off taker.
The Project consists of marine works in the Caspian Sea and an onshore desalination plant. The marine works include a 2 m diameter 3,475 m offshore seawater intake pipelines which will supply water to the desalination plant, and a 1.2 m diameter 2,000 m brine outfall pipeline through which the brine resulting from the desalination will be returned to the Caspian Sea. The desalination plant to be constructed within the Sumgayit Industrial Park comprises a pre-treatment system, reverse osmosis system, post treatment facilities, and product water storage and ancillary facilities. Power for the Project will be delivered from a planned substation to be built by Azerishyg OJSC connected to Azerishyg’s existing adjacent overhead powerline running within 100 m of the Project. Potable water generated by the Project will be delivered to the water distribution system via a 15 km 1.6 m diameter pipeline which will be designed, constructed, operated, and maintained by the Azerbaijan State Water Resources Agency (ADSEA), its owner, and will be installed underground within a legally defined 20 m protection corridor. The alignment has been designed to follow, where practicable, existing infrastructure corridors within the Sumgayit Industrial Park and ADSEA utility corridors, avoiding residential areas and environmentally sensitive receptors. Both the substation, short OHTL, and pipeline are associated facilities (AFs). During Project construction, material will be delivered from external sources, and concrete will be delivered from an offsite facility, any localized areas of contaminated soil resulting from the previous industrial uses of the brownfield site which are required to be removed from the site as part of the construction will be disposed of to local licensed landfills.
The Project consists of marine works in the Caspian Sea and an onshore desalination plant. The marine works include a 2 m diameter 3,475 m offshore seawater intake pipelines which will supply water to the desalination plant, and a 1.2 m diameter 2,000 m brine outfall pipeline through which the brine resulting from the desalination will be returned to the Caspian Sea. The desalination plant to be constructed within the Sumgayit Industrial Park comprises a pre-treatment system, reverse osmosis system, post treatment facilities, and product water storage and ancillary facilities. Power for the Project will be delivered from a planned substation to be built by Azerishyg OJSC connected to Azerishyg’s existing adjacent overhead powerline running within 100 m of the Project. Potable water generated by the Project will be delivered to the water distribution system via a 15 km 1.6 m diameter pipeline which will be designed, constructed, operated, and maintained by the Azerbaijan State Water Resources Agency (ADSEA), its owner, and will be installed underground within a legally defined 20 m protection corridor. The alignment has been designed to follow, where practicable, existing infrastructure corridors within the Sumgayit Industrial Park and ADSEA utility corridors, avoiding residential areas and environmentally sensitive receptors. Both the substation, short OHTL, and pipeline are associated facilities (AFs). During Project construction, material will be delivered from external sources, and concrete will be delivered from an offsite facility, any localized areas of contaminated soil resulting from the previous industrial uses of the brownfield site which are required to be removed from the site as part of the construction will be disposed of to local licensed landfills.
Overview of IFC's Scope of Review
IFC's appraisal of this proposed investment took place from October 2025 to May 2026 and was supported by an Independent Lenders’ Environmental and Social Advisor (“LESC”). The appraisal included: (i) a desktop review of available information; (ii) virtual and face to face meetings with the Project team including technical and Environmental and Social (E&S) staff; (iii) a site visit that included the proposed locations for the marine infrastructure, the desalination plant and the proposed routing of the water conveyance system. Documentation reviewed included an Environmental and Social Impact Assessment (ESIA), a Stakeholder Engagement Plan (SEP), selected draft ESMS documents, and an Environmental and Social Management System Implementation Manual produced by the Company.
E & S Project Categorization and Applicable Standard
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 - Cultural Heritage
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 - Cultural Heritage
This is a Category B Project, as per IFC's Policy on Environmental and Social Sustainability, because potential adverse environmental or social risks and/or impacts are limited, few in number, site-specific, largely reversible, and readily addressed through mitigation measures.
Key environmental and social (E&S) aspects and potential risks with the Project are : i) the Company’s ability to develop and implement IFC PS compliant environmental and social management system (ESMS) and specific management plans; ii) fair & safe labor and working conditions overseeing occupational health and safety of workforce including contract workers and labor contractor management during construction of the facilities; iii) labor influx including presence of a foreign workforce in the area; iv) community health and safety impacts associated with construction traffic, gender based violence and harassment (GBVH) and child protection and safeguarding (CPS); v) marine impacts including brine discharge during operations and seabed disturbance caused by dredging works during construction; vi) biodiversity risks, including potential impacts on the Caspian Seal in the offshore environment.
Key environmental and social (E&S) aspects and potential risks with the Project are : i) the Company’s ability to develop and implement IFC PS compliant environmental and social management system (ESMS) and specific management plans; ii) fair & safe labor and working conditions overseeing occupational health and safety of workforce including contract workers and labor contractor management during construction of the facilities; iii) labor influx including presence of a foreign workforce in the area; iv) community health and safety impacts associated with construction traffic, gender based violence and harassment (GBVH) and child protection and safeguarding (CPS); v) marine impacts including brine discharge during operations and seabed disturbance caused by dredging works during construction; vi) biodiversity risks, including potential impacts on the Caspian Seal in the offshore environment.
Environmental and Social Mitigation Measures
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:
The Company (ACWA) completed a national EIA in 2025 which was approved by the Ministry of Ecology and Natural Resources (MENR). A full ESIA in line with lender requirements was completed in April 2026. Approval of the National ESIA constitutes a statutory prerequisite for the commencement of construction activities. Given the Project’s marine works and seawater abstraction activities, additional regulatory controls apply due to the Caspian Sea’s designation as a specially protected water body under national legislation. Any activity that alters natural marine conditions or involves the discharge of effluents requires specific authorization from MENR. Seawater abstraction is subject to a Special Water Use Permit, administered through ADSEA which will be finalized in conjunction with the execution of the Water Purchase Agreement with ADSEA.
The Project ESMP outlines general requirements for E&S performance and assigns roles to Caspian Sea Azerbaijan Project Company LLC (as Project Company), and the EPC, a consortium led by PowerChina International Group Limited, HDEC Middle East Co DMCC, PowerChina HuaDong Engineering Co. Ltd. company branch in the Republic of Azerbaijan (HDEC) and Water & Environment Technologies Company (WETICO) from Saudi Arabia.
Within the ESMP, responsibility is allocated to the Company, in line with the requirements of the Company’s ESMS Implementation Manual to require the EPC to update and implement an EPC ESMS and ESMP for the construction phase covering the environmental, social and health and safety aspects (ESAP #1). These will include but not be limited to:
• Construction Environmental & Social Management Plan (CESMP);
• Environmental & Social Monitoring Plan, including a Marine Sediments and Seawater Monitoring Plan;
• Stakeholder Engagement Plan (SEP);
• Emergency Response Plan;
• Contractor Management Plan;
• Supply Chain MP;
• Community Grievance Mechanism;
• Local Recruitment Plan;
• Labor and Working Conditions Management Plan, including Worker Grievance Mechanism;
• Marine and Terrestrial Biodiversity Management Plan;
• Cultural Chance Find Procedure;
• H&S Management Plan;
• GBVH Prevention and Response Plan;
• Demobilization Plan;
• Pollution Prevention and Control Plan;
• Dredging Management Plan;
• Soil and Groundwater Management Plan;
• Aggregate Management Plan;
• Hazardous Materials Management Plan;
• Waste and Wastewater Management Plan; and
• Reinstatement Plan.
The Company will include legally binding obligations in its construction contracts (and subcontractor contracts) to aim for compliance with Project standards including IFC’s PSs and national legislation (see ESAP #2).
In preparation for operational activities, the Company will develop an E&S resourcing plan and develop and implement an Operations Environment and Social Management Plan (OESMP) consistent with IFC PSs, relevant WBG Environmental, Health and Safety (EHS) Guidelines, national requirements, and ESIA commitments (see ESAP #8). The OESMP will include, but not be limited to the following:
• E&S Monitoring;
• Brine Discharge and Marine Water Quality Monitoring
• Occupational Health & Safety;
• Emergency Preparedness and Response;
• Waste and Wastewater Management;
• Hazardous Materials/Material handling and Storage;
• Traffic and Transportation;
• Biodiversity;
• Human resource and Labour and Working Conditions;
• GBVH Prevention and Response;
• Community Health and Safety Management;
• Security;
• Recruitment and Training;
• De-commissioning Plan (although specific to the decommissioning phase);
• Stakeholder Engagement and grievance management;
• Climate resilience and adaptive management.
ESAP #4 requires the finalization of the commitments register to capture all Project E&S commitments from the ESIA and any other permit/agreement of relevance to the Project’s E&S performance and capture all commitments in the relevant E&S management plans.
The electrical substation (one of the two AF) is within the industrial site and under the jurisdiction of the SIA (on government-owned land) and therefore no land take is required. The Product Water Transmission Pipeline (PWTP, the other AF) is largely located within industrial and mixed-use settings. Route selection has taken into account the avoidance of environmentally sensitive receptors and populated areas and, where feasible, follows existing linear infrastructure such as roads and utility corridors. The Company will undertake a risk-based E&S screening of the Associated Facilities once sufficient routing and technical information becomes available. Based on this screening, a management plan will be developed by the Company, to define key environmental and social mitigation measures, and the Company will formally engage with ADSEA and relevant government authorities to, as far as possible, strive for the associated facilities to be developed in alignment with good international industry practice (see ESAP #5).
The Company has appointed a country E&S Manager, HSSE Manager and HR & Social Manager. In addition, it draws on the resources of the sponsor as well as external consultants to manage E&S matters during the design phase of the Project. For construction the Company is required to supplement the E&S Manager and the Social Manager with additional hires including a competent Environmental Consultant, a Biodiversity Consultant, a site-based Social Specialist, and a Labour Specialist from the early stages of Project development. The EPC will recruit a competent E&S Compliance Manager, Community Liaison Officers (CLO) who also have responsibility for the grievance mechanism, and an independent archaeological consultant. The requirement to recruit the competent ESHS individuals as set out in ACWA’s project E&S organigram is an ESAP requirement (see ESAP #6 and #7).
PS2: Labor and Working Condition:
During the 30-month construction phase the Project will employ up to 1,800 workers. This will be a mixture of local, national, and expat workers. Where feasible, the Project intends to prioritize the recruitment of qualified local and national candidates for general construction, logistics and support functions, while relying on international expertise for specialized roles. During operations, the desalination plant will be managed by ACWA Operations, a subsidiary of ACWA, with an estimated permanent workforce of approximately 50 employees focused on management, technical and maintenance roles requiring specialized skills. During the initial limited notice to proceed period, the EPC employs circa 100 people comprising engineers and supervisors and 50-60 nationals undertaking surveys and early preparatory works. The Company has prepared a draft Human Rights Policy that covers both construction and operation phase and is aligned with PS2 requirements. The draft policy articulates a clear Project level commitment to respect internationally recognized human rights and ILO Core Conventions, including zero tolerance for child labor, forced labor, gender based violence and harassment (GBVH), Sexual Exploitation and Abuse (SEA) and Sexual Harassment (SH); respect for freedom of association and collective bargaining; fair and transparent recruitment and employment practices; legally compliant wages and working hours; safe and healthy working conditions; and access to confidential, non-retaliatory grievance mechanisms. This Policy applies to the Caspian Sea Water Desalination Plant LLC and its employees and state that it expects Contractors, Subcontractors and Suppliers to uphold these principles and adopt similar policies within their own operations. The EPC Contractor has adopted a Human Rights (HR) Policy that demonstrates broad alignment in intent and scope with the Company’s Human Rights Policy.
The EPC has issued a Labour and Working Conditions Management Plan (LWCMP) applicable to all Project workers engaged during the construction phase, including direct, subcontracted, local, national, and expatriate workers. The LWCMP states that it has been prepared in accordance with national labor legislation, and IFC PS2, and establishes the Project’s overarching commitments on fair treatment of workers, non-discrimination, prohibition of child and forced labor, and provision of safe and decent working conditions. ESAP #9 requires strengthening the Company LWCMP to: (a) clarify the interface between the EPC Contractor and the Company in relation to labor oversight and compliance monitoring, and the mechanisms through which worker voice is systematically captured and considered within such audits, beyond the use of grievance mechanisms alone. The LWCMP will also need to be updated once quantitative disaggregated workforce data, broken down by nationality, skill level or contractor tier is available and during mobilization planning.
The EPC’s HR Policy applies to EPC personnel and extends to subcontractors, service providers and primary suppliers, and commits to compliance with Azerbaijan labor law and applicable lender/international requirements, applying the higher standard where differences exist.
A Local Recruitment Plan, a Contractor Management Plan, a GBVH Prevention and Response Plan, and a Demobilization Plan, are currently being developed by the EPC Contractor as part of the construction phase management plans (see ESAP #1).
The EPC has also developed a Worker Code of Conduct (Worker CoC, dated 2026) applicable to its direct workforce and to workers employed by subcontractors engaged on the Project. The Worker CoC includes a GBVH CoC, setting out zero tolerance for GBVH, ensuring access to anonymous or protected grievance channels. The EPC is to put in place and disseminate a non-retaliatory Worker's Grievance Mechanism accessible to all contracted workers immediately before the start of early works (see ESAP #1).
Construction workers will be accommodated off-site, away from the immediate Project area, with subcontractors responsible for providing accommodation for their respective workforces. No purpose-built construction camps will be developed for the Project, and the EPC contractor and its subcontractors, including marine works contractors, will utilize existing rented accommodation such as dormitories, hotels, and similar facilities located primarily within Sumgayit and, where necessary, other suitable urban areas such as Baku. The EPC has issued a Worker Accommodation Plan (WAP) which applies to temporary, off-site accommodation facilities provided or arranged by the EPC contractor and its subcontractors for the construction workforce. The WAP explicitly references alignment with applicable international standards, including IFC PS 2 and the IFC/EBRD ‘Workers’ Accommodation: Processes and Standards guidance. The WAP will need to be updated to confirm the specific facilities to be used, their capacity and occupancy arrangements, and set out a clear inspection regime covering pre-occupancy checks, periodic inspections and corrective-action tracking. It also needs to demonstrate how accommodation will be made safe, secure and gender-sensitive, provide culturally appropriate social and prayer facilities, and include a documented GBVH and community risk assessment for each site. It will also include quantitative disaggregated data on the workforce broken down by nationality, skill level or contractor tier once these are available (ESAP #10)
The EPC has adopted an HSE Plan, which is in alignment with the IFC PS and the IFC EHS Guidelines. The detailed HSE Plan applies to Project-related activities performed by the EPC and its subcontractors and provides a robust approach to the management of HSE aspects. The HSE plan includes the following aspects (a) hazard identification and risk assessment for onshore and offshore activities; (b) job safety analyses; (c) training; (d) safe working procedures; (e) prevention, reporting, recording, investigation, analysis of accidents and incidents, and follow up corrective actions; (f) emergency response; (g) provision of medical care, first aid and provision of medical treatment; (h) workplace and health monitoring; (i) measures for prevention of disease spread; (j) fire prevention and fighting system; (k) inspections and audits; (l) performance reporting; and (m) management review and the roles and responsibilities and arrangements regarding OHS. The EPC contractor and the O&M contractor will include Standard Operating Procedures for OHS management in the CESMP (ESAP #1) and OESMP (ESAP#3).
The Company will manage supply chain labor risks through the implementation of the Supply Chain Management System and the establishment of grievance mechanisms accessible to supply chain workers at no cost. Management of environmental, social and labor risks associated with the Project supply chain is governed by the EPC’s Subcontractor and Supplier Management Plan (SSMP). In relation to suppliers, the SSMP establishes screening, selection and monitoring arrangements proportionate to supplier scope and risk. This includes reputational due diligence, contractual requirements to comply with Project E&S and HSSE standards, and the ability for the EPC Contractor to conduct off-site E&S audits where elevated risks are identified. Although through this approach residual supply chain risks are expected to be minor, the approach to selecting suppliers to be audited requires strengthening and will be addressed through the updates to the EPC’s Supply Chain Management Plan including provisions for specifying selection, contractual agreements, auditing, monitoring and supervision requirements for contractors and suppliers as part of the overall construction ESMP update (ESAP #1).
PS3: Resource Efficiency and Pollution Prevention:
The Project has a planned potable water production capacity of approximately 300,000 m³/day which will be generated using electrical power from the Azerbaijan national grid (circa 579,000 kWh/day). The SWRO plant is designed to minimize power consumption through optimization of the RO system power consumption, using energy and pressure recovery devices, and maximizing reject reuse. Scope 1 and 2 GHG emissions during construction and operations will be limited whereas Scope 1 and 2 GHG emissions in Operations will be circa 95,000 t/CO2e/year of which the majority are Scope 2 emissions.
The Project is expected to generate minor pollution to air, water, and soil, as well as manageable volumes of waste, all of which will be addressed through standard pollution prevention and control measures defined within the Project’s CESMS (ESAP #1) and OESMS (ESAP #3).
During construction the Project will manage the existing localized hotspots of contaminated soils present on the site which have been identified through the baseline studies for the ESIA and early works on the site through the Soil Management Plan. This plan will detail how contaminated soil derived from the previous industrial usage of the site, will be handled, including their temporary storage, reuse or transport, treatment and disposal. The H&S plan will manage any potential worker risks from this contamination. Any contaminated groundwater recovered from the site would either be treated with wastewater onsite or transported offsite for treatment (ESAP #1). Marine construction will temporarily affect seawater quality due to excavation of the intake and outfall pipeline trenches and their backfilling. Baseline sampling of sediments offshore has not identified any contamination of concern, and the modelling of the sediment plume generated by the dredging equipment has shown this to be limited to the nearfield of the marine works and to not affect sensitive habitats. The dredged sediment will be pumped to onshore settlement ponds, and any suitable aggregate in the dredged material utilized in the construction. The management of sediment generated by the dredging and their dewatering will be managed through a dredging management plan, and any contaminated sediments, if encountered, will be managed through the soil management plan covering contamination (ESAP #1)
The current site has no surface water controls, during construction, surface water run-off along with other sources such as equipment and vehicles washing water, concrete washout water will need to be managed through the CESMS waste and wastewater management plan (ESAP #1). In operations the brine reject water from the RO will be discharged back to the Caspian (up to 128,893 m3/day), along with backwash and other wastewater streams which may contain trace concentrations of residual treatment chemicals in compliance with best practice. The brine will be discharged through an outfall system engineered with diffusers set at 45 degrees 1.7 m above the seabed to maximize dispersion of the brine which is 51 PSU (practical salinity unit) compared to the Caspian Sea’s 12-13 PSU. As per the dispersion modeling included in the ESIA and conducted for several meteorological conditions, the impact of the brine discharge is limited with the median increase of 1 PSU is 300 m from the diffusers within the bottom sea layer, and significantly lower in the mid and surface layer. The model indicates that there is no evidence of long-term accumulation of brine. Overall, the brine discharge impacts on the low biomass sandy substrate are localized, predictable and manageable with standard environmental monitoring and operational controls. A Brine Monitoring and Management plan will be developed as part of the OESMS which will define the environmental standards and discharge criteria to be applied to each emission stream, including the ecotoxicological relevance of process chemicals in marine discharges and monitoring regime (ESAP #3).
Noise from construction activities is not expected to be a significant issue for this Project as the Project is within an industrial zone and there are no residential receptors. Onshore noise sources will comprise construction activities, vehicle movements including earth moving equipment, and local power generation. Operational noise is expected to be minimal. A noise management plan will be developed detailing the monitoring to be undertaken during Project construction and operations as part of the CESMS and OESMS (ESAP #1 and ESAP #3). Sources of offshore construction noise will be generated during dredging and associated works, which will be managed through the Dredging Management Plan and potential impacts on the Caspian Sea through the construction phase Biodiversity Management Plan (ESAP #1 and ESAP #14).
Limited volumes of hazardous materials will be used during the Project’s construction (e.g., fuels, lubricants, oils, paints, chemical) and specific chemicals required for operations including fuel storage for the backup generators. The Project will develop a Hazardous Materials Management Plan within the ESMP which will detail the hazardous materials management such as storage in bunded areas with spill response kits and dispose of its hazardous waste at an off-site licenced facility. Construction and operational waste will be segregated on site, stored in secure containers, and removed by licensed contractors in line with national legislation as laid out in the Waste Management Plan within the CESMP and OESMP developed for the Project.
The ESIA includes a comprehensive assessment of potential Project risks associated with climate change or related adaptation measures, including increase temperatures and impacts on personnel and equipment, increased potential for floods and drought. Mitigation measures for these are accounted for in the Project design such as heat-adapted operating procedures or H&S heat stress considerations. With consideration of the potential for climate-driven decreases in Caspian Sea levels a factor informing the potentially flexible seawater intake design.
PS4: Community Health, Safety and Security:
The Project is being developed on an industrial brownfield site within the Sumgayit Chemical Industrial Park, with the nearest communities Kimyachilar and Hajy Zeinalabdin, located approximately 420 m east and 2,750 m west, from the site, respectively. The Project will utilize the existing industrial park roads and public highways to transport material to and from the site, the routes to be used, and the locations of the quarries and landfills which will be used are not currently identified.
A Traffic Management Procedure has been adopted by the EPC, which foresees the appointment of a Traffic Coordinator to manage day-to-day traffic control activities on site and a Marine Coordinator, responsible for coordinating vessel movements, marine lifting operations, and exclusion zones in alignment with onshore traffic controls. According to the procedure, Project-related traffic activities are subject to a documented Traffic Risk Assessment process undertaken by the EPC. Traffic Risk Assessments will address not only internal site-related hazards but also potential risks to public safety, third party road users, and nearby communities where project traffic interacts with public roads or external transport routes. A Logistic and Traffic Management Plan (LTMP) has also been issued for review to coordinate the delivery of critical equipment from Shanghai port by sea to Georgia and overland to the plant. The LTMP provides an overview of logistics management procedures, practices and responsibilities intended to ensure the timely and safe delivery of materials in line with project and regulatory requirements. To strengthen oversight of traffic and transport the Company is to require the EPC to update its Logistics and Traffic Management Plan which is to include information, maps and traffic risks assessments for the potential routes to be used (highlighting potential sensitive receptors such as residential areas, schools, hospitals), anticipated traffic volumes, and daily worker commute. (ESAP #11).
The EPC Contractor is responsible for developing and implementing a Project-specific Emergency Preparedness and Response Plan (EPRP) during construction (ESAP #1), and the O&M Company is responsible for an equivalent plan during operation (ESAP #3).
Workers will be accommodated in the wider Sumgayit area primarily in available student accommodation and hotels. The potential for negative impacts of the presence of the workforce on the local communities is low and will be managed through the worker code of conduct and relevant training and measured under the ESMP through the community grievance mechanism.
The authorities indicated that the marine area within and surrounding the Project site is formally designated as a restricted coastal zone under national legislation, although there is some informal fishing carried out. According to consultations with stakeholders conducted by the company, about 35 fishing operators carry out fishing activities from two piers located at about 1,500 m from the Project area. Based on a participatory mapping exercise, Project construction and operation area and temporary safety or exclusion zones are not expected to overlap with fishing routes and grounds which will be managed under the ESMS (ESAP #1) and measured under the ESMP through the community grievance mechanism.
The EPC Contractor is currently developing a CESMP, an Environmental & Social Monitoring Plan, a Community Health and Safety Plan (ESAP#1). These should include relevant construction phase controls and additional measures such as worker orientation and cultural awareness training, community safety and awareness programmes. Verification of implementation should be undertaken through routine ESMS monitoring.
Risks for community exposure to hazardous materials during the construction phase are considered low due to limited community interaction with the construction sites, and EPC’s commitment to safety measures such as fencing, and warning signs will safeguard the community.
A Security Management Plan developed for the Limited Notice to Proceed period establishes a security framework applicable to mobilization and early works, construction and installation activities, and demobilization and site closure activities. The Plan is intended to ensure protection of Project personnel, assets, facilities, materials, and information, while complying with applicable national laws and Project HSSE requirements. A Project specific Security Risk Assessment will be conducted to identify security threats, vulnerabilities, and potential impacts associated with Project activities and locations (ESAP #12). A Security Management Plan (SMP) (for construction and operations phases) will be developed by the EPC contractor in accordance with IFC good practice handbook. The SMP will include measures to address GBVH risks, ensuring that all security personnel receive appropriate training and adhere to a Code of Conduct that prohibits any form of GBVH. The Human Rights Policy adopted by the Project Company explicitly addresses security and human rights. Security personnel, which are likely to be sourced from the local communities, will be unarmed.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources:
The project is situated in the Azerbaijan shrub desert and steppe ecoregion of the Caspian Sea and Central Asian Deserts sub-realm in the Central Eurasia realm. The coastal and inland project components and associated facilities are in a mix of Natural and Modified Habitat, which include areas of wormwood and saline semi-deserts, sand dunes, flowing and stagnant water bodies, and coastal reed beds. The marine components are in subtidal silt and sand habitat, composed of sandy and rocky substrates with relatively limited benthic diversity. The project does not overlap with Legally Protected areas, but the marine components lie within the Caspian Seal Transitory Migration and Feeding Area Important Marine Mammal Area (IMMA) designated for the feeding areas and migration corridors of the Caspian Seal.
Terrestrial surveys for the project were conducted in 2024 and 2025. Terrestrial priority biodiversity values include areas of wormwood and saline semi-desert, sand dune and coastal reed bed habitats, Astragalus albanicus (IUCN Red List – Endangered), Wedge-leaved Meadow Saxifrage and Coastal Bastard Toad-flax, Common Tortoise (all IUCN Red List – Vulnerable), European Pond Turtle (IUCN Red List – Near Threatened), Caspian Bent-toed Gecko, Central Asian Race Runner, Dice Snake, Greater Horseshoe Bat, Lesser Mouse-eared Bat, European Hare, Small Five-toed Jerboa, Libyan Jird, Golden Jackal, Red Fox (all IUCN Red List – Least Concern). Baseline surveys also identified several migratory bird species, including threatened waterbirds, mainly recorded in flight during Spring and Autumn migration. Marine surveys were conducted in 2024, which included environmental-DNA sampling for fish species and additional input from local fishermen. Marine priority biodiversity values are threatened and range-restricted fish species, including sturgeons, and the Caspian Seal (IUCN Red List – Endangered). Based on available data and information, most of the Critical Habitat and priority biodiversity values do not overlap with the project’s Area of Influence (AoI) but do occur in the broader area of the project footprint. The project is in Critical Habitat (CH) for the Caspian Seal, for which IFC Net Gain (NG) requirements will apply. IFC Natural Habitat (NH) No Net Loss (NNL) requirements will apply to all other priority biodiversity values.
Per ESAP #13, the Company will update biodiversity assessments, including the residual impact assessment for the Caspian Seal and priority biodiversity values. The updated assessments will rely on available quantitative data and additional information to be obtained through stakeholder engagement. The update will define further survey requirements for sturgeon species as appropriate, and will also include identification and mapping of areas associated with Critical Habitat and priority biodiversity values, where avoidance, minimization and restoration measures will be implemented in line with the project’s mitigation strategy.
The Company will develop and implement terrestrial and marine construction-phase Biodiversity Management Plans (BMPs) to set forth mitigation measures to avoid and minimize impacts on Critical Habitat, Natural Habitat and priority biodiversity values (ESAP #14). The construction-phase BMPs will incorporate all related procedures that will be implemented during the project’s terrestrial and marine activities, which at the minimum, will include procedures for baseline surveys along the product water pipeline, pre-construction checks across all sites, vegetation removal, topsoil and invasive alien species management. For the marine construction activities, to minimize impacts on the Caspian Seal and priority fish species, as applicable, construction activities will be designed around species' migration periods and routes, with the mitigation actions to be confirmed with local specialists. PS6 requirements will be achieved through implementation of GIIP to be also outlined in the project’s CESMP, Dredging Management Plan and related procedures to be implemented as part of the dredging contractor’s management plans (ESAP #1). Underwater noise and vibration that are expected to occur due to filling, and dredging activities will be managed through implementation of low noise/vibration methods. Mitigation measures will include but not limited to (i) using low noise/vibration methods e.g., during filling and dredging, (ii) defining routes to be taken by construction vessels to avoid potential encounters with the individuals of the species, (iii) continuous observation of Caspian Seal presence during construction, and (iv) ceasing activities that generate percussive marine noise if seals are present within 1,000 meters of the project and any other underwater construction when seals are present within 500 meters. The company will appoint a marine mammal biodiversity expert, who will be responsible for implementation and reporting of mitigation measures.
For the post-construction and operations-phase of the project, the Company will develop terrestrial and marine operations-phase BMPs to implement measures to reach NNL objectives (ESAP #15). These measures will include recommendations for restoration in areas of Natural Habitat, as applicable. The marine operations-phase BMP will be aligned with the project’s brine discharge management strategies, which will be developed to mitigate impacts on the Caspian Seal and priority marine species through implementing relevant measures for volume reduction, treatment and discharge minimization. The Company will contract qualified experts with international experience to develop and implement terrestrial and marine operations-phase BMPs.
Per ESAP #16, the Company will develop and implement a Biodiversity Action Plan (BAP), which will be informed by updated biodiversity assessments and commensurate with residual impacts resulting from the project. In addition to measures in the BMPs aimed to achieve NNL, the BAP will define actions for the Caspian Seal to reach NG objectives. In line with IFC PS6, these will include development of additional conservation actions in the IMMA, which will be identified and implemented in coordination with relevant stakeholders to ACWA’s best efforts. ACWA has been consulting with the Department of Fisheries and Aquaculture Center of the Ministry of Agriculture to obtain data and information on the Caspian Seal and sturgeon species that occur in the wider area. Further consultation will be undertaken with the national/regional authorities and institutions, species experts, the Marine Mammal Protected Areas Task Force (MMATF) and IUCN Species Survival Commission (SSC) Sturgeon Specialist Group to identify to inform updated assessments, project’s mitigation strategy and additional conservation actions.
The Company will develop and implement a Biodiversity Monitoring and Evaluation Plan (BMEP), which will include; (i) monitoring and evaluation plans with targeted methodologies and monitoring locations, and (ii) indicators and thresholds for adaptive management, and actions to be implemented when thresholds are exceeded. The monitoring program will be undertaken for a minimum of 2 years but may be extended based on the outcomes (ESAP #17).
PS8: Cultural Heritage:
The onshore Project site is located within the Sumgayit Industrial Park, a heavily disturbed brownfield area. The site has been subject to significant anthropogenic disturbance, including excavations, industrial use, demolition works, and informal dumping of industrial solid wastes. Sumgayit is described as a relatively young city, and no surviving historical monuments have been identified within the city or the Project’s AoI. This has been confirmed by the State Service for the Protection, Development and Restoration of Cultural Heritage under the Ministry of Culture of the Republic of Azerbaijan. Offshore the ESIA does not clarify whether pre-construction marine surveys can also be relied upon to inform the screening of potential unregistered underwater cultural heritage assets. The Cultural Heritage MP developed by the EPC should include a Chance Finds Procedure for offshore and onshore (ESAP #18).
PS1: Assessment and Management of Environmental and Social Risks and Impacts:
The Company (ACWA) completed a national EIA in 2025 which was approved by the Ministry of Ecology and Natural Resources (MENR). A full ESIA in line with lender requirements was completed in April 2026. Approval of the National ESIA constitutes a statutory prerequisite for the commencement of construction activities. Given the Project’s marine works and seawater abstraction activities, additional regulatory controls apply due to the Caspian Sea’s designation as a specially protected water body under national legislation. Any activity that alters natural marine conditions or involves the discharge of effluents requires specific authorization from MENR. Seawater abstraction is subject to a Special Water Use Permit, administered through ADSEA which will be finalized in conjunction with the execution of the Water Purchase Agreement with ADSEA.
The Project ESMP outlines general requirements for E&S performance and assigns roles to Caspian Sea Azerbaijan Project Company LLC (as Project Company), and the EPC, a consortium led by PowerChina International Group Limited, HDEC Middle East Co DMCC, PowerChina HuaDong Engineering Co. Ltd. company branch in the Republic of Azerbaijan (HDEC) and Water & Environment Technologies Company (WETICO) from Saudi Arabia.
Within the ESMP, responsibility is allocated to the Company, in line with the requirements of the Company’s ESMS Implementation Manual to require the EPC to update and implement an EPC ESMS and ESMP for the construction phase covering the environmental, social and health and safety aspects (ESAP #1). These will include but not be limited to:
• Construction Environmental & Social Management Plan (CESMP);
• Environmental & Social Monitoring Plan, including a Marine Sediments and Seawater Monitoring Plan;
• Stakeholder Engagement Plan (SEP);
• Emergency Response Plan;
• Contractor Management Plan;
• Supply Chain MP;
• Community Grievance Mechanism;
• Local Recruitment Plan;
• Labor and Working Conditions Management Plan, including Worker Grievance Mechanism;
• Marine and Terrestrial Biodiversity Management Plan;
• Cultural Chance Find Procedure;
• H&S Management Plan;
• GBVH Prevention and Response Plan;
• Demobilization Plan;
• Pollution Prevention and Control Plan;
• Dredging Management Plan;
• Soil and Groundwater Management Plan;
• Aggregate Management Plan;
• Hazardous Materials Management Plan;
• Waste and Wastewater Management Plan; and
• Reinstatement Plan.
The Company will include legally binding obligations in its construction contracts (and subcontractor contracts) to aim for compliance with Project standards including IFC’s PSs and national legislation (see ESAP #2).
In preparation for operational activities, the Company will develop an E&S resourcing plan and develop and implement an Operations Environment and Social Management Plan (OESMP) consistent with IFC PSs, relevant WBG Environmental, Health and Safety (EHS) Guidelines, national requirements, and ESIA commitments (see ESAP #8). The OESMP will include, but not be limited to the following:
• E&S Monitoring;
• Brine Discharge and Marine Water Quality Monitoring
• Occupational Health & Safety;
• Emergency Preparedness and Response;
• Waste and Wastewater Management;
• Hazardous Materials/Material handling and Storage;
• Traffic and Transportation;
• Biodiversity;
• Human resource and Labour and Working Conditions;
• GBVH Prevention and Response;
• Community Health and Safety Management;
• Security;
• Recruitment and Training;
• De-commissioning Plan (although specific to the decommissioning phase);
• Stakeholder Engagement and grievance management;
• Climate resilience and adaptive management.
ESAP #4 requires the finalization of the commitments register to capture all Project E&S commitments from the ESIA and any other permit/agreement of relevance to the Project’s E&S performance and capture all commitments in the relevant E&S management plans.
The electrical substation (one of the two AF) is within the industrial site and under the jurisdiction of the SIA (on government-owned land) and therefore no land take is required. The Product Water Transmission Pipeline (PWTP, the other AF) is largely located within industrial and mixed-use settings. Route selection has taken into account the avoidance of environmentally sensitive receptors and populated areas and, where feasible, follows existing linear infrastructure such as roads and utility corridors. The Company will undertake a risk-based E&S screening of the Associated Facilities once sufficient routing and technical information becomes available. Based on this screening, a management plan will be developed by the Company, to define key environmental and social mitigation measures, and the Company will formally engage with ADSEA and relevant government authorities to, as far as possible, strive for the associated facilities to be developed in alignment with good international industry practice (see ESAP #5).
The Company has appointed a country E&S Manager, HSSE Manager and HR & Social Manager. In addition, it draws on the resources of the sponsor as well as external consultants to manage E&S matters during the design phase of the Project. For construction the Company is required to supplement the E&S Manager and the Social Manager with additional hires including a competent Environmental Consultant, a Biodiversity Consultant, a site-based Social Specialist, and a Labour Specialist from the early stages of Project development. The EPC will recruit a competent E&S Compliance Manager, Community Liaison Officers (CLO) who also have responsibility for the grievance mechanism, and an independent archaeological consultant. The requirement to recruit the competent ESHS individuals as set out in ACWA’s project E&S organigram is an ESAP requirement (see ESAP #6 and #7).
PS2: Labor and Working Condition:
During the 30-month construction phase the Project will employ up to 1,800 workers. This will be a mixture of local, national, and expat workers. Where feasible, the Project intends to prioritize the recruitment of qualified local and national candidates for general construction, logistics and support functions, while relying on international expertise for specialized roles. During operations, the desalination plant will be managed by ACWA Operations, a subsidiary of ACWA, with an estimated permanent workforce of approximately 50 employees focused on management, technical and maintenance roles requiring specialized skills. During the initial limited notice to proceed period, the EPC employs circa 100 people comprising engineers and supervisors and 50-60 nationals undertaking surveys and early preparatory works. The Company has prepared a draft Human Rights Policy that covers both construction and operation phase and is aligned with PS2 requirements. The draft policy articulates a clear Project level commitment to respect internationally recognized human rights and ILO Core Conventions, including zero tolerance for child labor, forced labor, gender based violence and harassment (GBVH), Sexual Exploitation and Abuse (SEA) and Sexual Harassment (SH); respect for freedom of association and collective bargaining; fair and transparent recruitment and employment practices; legally compliant wages and working hours; safe and healthy working conditions; and access to confidential, non-retaliatory grievance mechanisms. This Policy applies to the Caspian Sea Water Desalination Plant LLC and its employees and state that it expects Contractors, Subcontractors and Suppliers to uphold these principles and adopt similar policies within their own operations. The EPC Contractor has adopted a Human Rights (HR) Policy that demonstrates broad alignment in intent and scope with the Company’s Human Rights Policy.
The EPC has issued a Labour and Working Conditions Management Plan (LWCMP) applicable to all Project workers engaged during the construction phase, including direct, subcontracted, local, national, and expatriate workers. The LWCMP states that it has been prepared in accordance with national labor legislation, and IFC PS2, and establishes the Project’s overarching commitments on fair treatment of workers, non-discrimination, prohibition of child and forced labor, and provision of safe and decent working conditions. ESAP #9 requires strengthening the Company LWCMP to: (a) clarify the interface between the EPC Contractor and the Company in relation to labor oversight and compliance monitoring, and the mechanisms through which worker voice is systematically captured and considered within such audits, beyond the use of grievance mechanisms alone. The LWCMP will also need to be updated once quantitative disaggregated workforce data, broken down by nationality, skill level or contractor tier is available and during mobilization planning.
The EPC’s HR Policy applies to EPC personnel and extends to subcontractors, service providers and primary suppliers, and commits to compliance with Azerbaijan labor law and applicable lender/international requirements, applying the higher standard where differences exist.
A Local Recruitment Plan, a Contractor Management Plan, a GBVH Prevention and Response Plan, and a Demobilization Plan, are currently being developed by the EPC Contractor as part of the construction phase management plans (see ESAP #1).
The EPC has also developed a Worker Code of Conduct (Worker CoC, dated 2026) applicable to its direct workforce and to workers employed by subcontractors engaged on the Project. The Worker CoC includes a GBVH CoC, setting out zero tolerance for GBVH, ensuring access to anonymous or protected grievance channels. The EPC is to put in place and disseminate a non-retaliatory Worker's Grievance Mechanism accessible to all contracted workers immediately before the start of early works (see ESAP #1).
Construction workers will be accommodated off-site, away from the immediate Project area, with subcontractors responsible for providing accommodation for their respective workforces. No purpose-built construction camps will be developed for the Project, and the EPC contractor and its subcontractors, including marine works contractors, will utilize existing rented accommodation such as dormitories, hotels, and similar facilities located primarily within Sumgayit and, where necessary, other suitable urban areas such as Baku. The EPC has issued a Worker Accommodation Plan (WAP) which applies to temporary, off-site accommodation facilities provided or arranged by the EPC contractor and its subcontractors for the construction workforce. The WAP explicitly references alignment with applicable international standards, including IFC PS 2 and the IFC/EBRD ‘Workers’ Accommodation: Processes and Standards guidance. The WAP will need to be updated to confirm the specific facilities to be used, their capacity and occupancy arrangements, and set out a clear inspection regime covering pre-occupancy checks, periodic inspections and corrective-action tracking. It also needs to demonstrate how accommodation will be made safe, secure and gender-sensitive, provide culturally appropriate social and prayer facilities, and include a documented GBVH and community risk assessment for each site. It will also include quantitative disaggregated data on the workforce broken down by nationality, skill level or contractor tier once these are available (ESAP #10)
The EPC has adopted an HSE Plan, which is in alignment with the IFC PS and the IFC EHS Guidelines. The detailed HSE Plan applies to Project-related activities performed by the EPC and its subcontractors and provides a robust approach to the management of HSE aspects. The HSE plan includes the following aspects (a) hazard identification and risk assessment for onshore and offshore activities; (b) job safety analyses; (c) training; (d) safe working procedures; (e) prevention, reporting, recording, investigation, analysis of accidents and incidents, and follow up corrective actions; (f) emergency response; (g) provision of medical care, first aid and provision of medical treatment; (h) workplace and health monitoring; (i) measures for prevention of disease spread; (j) fire prevention and fighting system; (k) inspections and audits; (l) performance reporting; and (m) management review and the roles and responsibilities and arrangements regarding OHS. The EPC contractor and the O&M contractor will include Standard Operating Procedures for OHS management in the CESMP (ESAP #1) and OESMP (ESAP#3).
The Company will manage supply chain labor risks through the implementation of the Supply Chain Management System and the establishment of grievance mechanisms accessible to supply chain workers at no cost. Management of environmental, social and labor risks associated with the Project supply chain is governed by the EPC’s Subcontractor and Supplier Management Plan (SSMP). In relation to suppliers, the SSMP establishes screening, selection and monitoring arrangements proportionate to supplier scope and risk. This includes reputational due diligence, contractual requirements to comply with Project E&S and HSSE standards, and the ability for the EPC Contractor to conduct off-site E&S audits where elevated risks are identified. Although through this approach residual supply chain risks are expected to be minor, the approach to selecting suppliers to be audited requires strengthening and will be addressed through the updates to the EPC’s Supply Chain Management Plan including provisions for specifying selection, contractual agreements, auditing, monitoring and supervision requirements for contractors and suppliers as part of the overall construction ESMP update (ESAP #1).
PS3: Resource Efficiency and Pollution Prevention:
The Project has a planned potable water production capacity of approximately 300,000 m³/day which will be generated using electrical power from the Azerbaijan national grid (circa 579,000 kWh/day). The SWRO plant is designed to minimize power consumption through optimization of the RO system power consumption, using energy and pressure recovery devices, and maximizing reject reuse. Scope 1 and 2 GHG emissions during construction and operations will be limited whereas Scope 1 and 2 GHG emissions in Operations will be circa 95,000 t/CO2e/year of which the majority are Scope 2 emissions.
The Project is expected to generate minor pollution to air, water, and soil, as well as manageable volumes of waste, all of which will be addressed through standard pollution prevention and control measures defined within the Project’s CESMS (ESAP #1) and OESMS (ESAP #3).
During construction the Project will manage the existing localized hotspots of contaminated soils present on the site which have been identified through the baseline studies for the ESIA and early works on the site through the Soil Management Plan. This plan will detail how contaminated soil derived from the previous industrial usage of the site, will be handled, including their temporary storage, reuse or transport, treatment and disposal. The H&S plan will manage any potential worker risks from this contamination. Any contaminated groundwater recovered from the site would either be treated with wastewater onsite or transported offsite for treatment (ESAP #1). Marine construction will temporarily affect seawater quality due to excavation of the intake and outfall pipeline trenches and their backfilling. Baseline sampling of sediments offshore has not identified any contamination of concern, and the modelling of the sediment plume generated by the dredging equipment has shown this to be limited to the nearfield of the marine works and to not affect sensitive habitats. The dredged sediment will be pumped to onshore settlement ponds, and any suitable aggregate in the dredged material utilized in the construction. The management of sediment generated by the dredging and their dewatering will be managed through a dredging management plan, and any contaminated sediments, if encountered, will be managed through the soil management plan covering contamination (ESAP #1)
The current site has no surface water controls, during construction, surface water run-off along with other sources such as equipment and vehicles washing water, concrete washout water will need to be managed through the CESMS waste and wastewater management plan (ESAP #1). In operations the brine reject water from the RO will be discharged back to the Caspian (up to 128,893 m3/day), along with backwash and other wastewater streams which may contain trace concentrations of residual treatment chemicals in compliance with best practice. The brine will be discharged through an outfall system engineered with diffusers set at 45 degrees 1.7 m above the seabed to maximize dispersion of the brine which is 51 PSU (practical salinity unit) compared to the Caspian Sea’s 12-13 PSU. As per the dispersion modeling included in the ESIA and conducted for several meteorological conditions, the impact of the brine discharge is limited with the median increase of 1 PSU is 300 m from the diffusers within the bottom sea layer, and significantly lower in the mid and surface layer. The model indicates that there is no evidence of long-term accumulation of brine. Overall, the brine discharge impacts on the low biomass sandy substrate are localized, predictable and manageable with standard environmental monitoring and operational controls. A Brine Monitoring and Management plan will be developed as part of the OESMS which will define the environmental standards and discharge criteria to be applied to each emission stream, including the ecotoxicological relevance of process chemicals in marine discharges and monitoring regime (ESAP #3).
Noise from construction activities is not expected to be a significant issue for this Project as the Project is within an industrial zone and there are no residential receptors. Onshore noise sources will comprise construction activities, vehicle movements including earth moving equipment, and local power generation. Operational noise is expected to be minimal. A noise management plan will be developed detailing the monitoring to be undertaken during Project construction and operations as part of the CESMS and OESMS (ESAP #1 and ESAP #3). Sources of offshore construction noise will be generated during dredging and associated works, which will be managed through the Dredging Management Plan and potential impacts on the Caspian Sea through the construction phase Biodiversity Management Plan (ESAP #1 and ESAP #14).
Limited volumes of hazardous materials will be used during the Project’s construction (e.g., fuels, lubricants, oils, paints, chemical) and specific chemicals required for operations including fuel storage for the backup generators. The Project will develop a Hazardous Materials Management Plan within the ESMP which will detail the hazardous materials management such as storage in bunded areas with spill response kits and dispose of its hazardous waste at an off-site licenced facility. Construction and operational waste will be segregated on site, stored in secure containers, and removed by licensed contractors in line with national legislation as laid out in the Waste Management Plan within the CESMP and OESMP developed for the Project.
The ESIA includes a comprehensive assessment of potential Project risks associated with climate change or related adaptation measures, including increase temperatures and impacts on personnel and equipment, increased potential for floods and drought. Mitigation measures for these are accounted for in the Project design such as heat-adapted operating procedures or H&S heat stress considerations. With consideration of the potential for climate-driven decreases in Caspian Sea levels a factor informing the potentially flexible seawater intake design.
PS4: Community Health, Safety and Security:
The Project is being developed on an industrial brownfield site within the Sumgayit Chemical Industrial Park, with the nearest communities Kimyachilar and Hajy Zeinalabdin, located approximately 420 m east and 2,750 m west, from the site, respectively. The Project will utilize the existing industrial park roads and public highways to transport material to and from the site, the routes to be used, and the locations of the quarries and landfills which will be used are not currently identified.
A Traffic Management Procedure has been adopted by the EPC, which foresees the appointment of a Traffic Coordinator to manage day-to-day traffic control activities on site and a Marine Coordinator, responsible for coordinating vessel movements, marine lifting operations, and exclusion zones in alignment with onshore traffic controls. According to the procedure, Project-related traffic activities are subject to a documented Traffic Risk Assessment process undertaken by the EPC. Traffic Risk Assessments will address not only internal site-related hazards but also potential risks to public safety, third party road users, and nearby communities where project traffic interacts with public roads or external transport routes. A Logistic and Traffic Management Plan (LTMP) has also been issued for review to coordinate the delivery of critical equipment from Shanghai port by sea to Georgia and overland to the plant. The LTMP provides an overview of logistics management procedures, practices and responsibilities intended to ensure the timely and safe delivery of materials in line with project and regulatory requirements. To strengthen oversight of traffic and transport the Company is to require the EPC to update its Logistics and Traffic Management Plan which is to include information, maps and traffic risks assessments for the potential routes to be used (highlighting potential sensitive receptors such as residential areas, schools, hospitals), anticipated traffic volumes, and daily worker commute. (ESAP #11).
The EPC Contractor is responsible for developing and implementing a Project-specific Emergency Preparedness and Response Plan (EPRP) during construction (ESAP #1), and the O&M Company is responsible for an equivalent plan during operation (ESAP #3).
Workers will be accommodated in the wider Sumgayit area primarily in available student accommodation and hotels. The potential for negative impacts of the presence of the workforce on the local communities is low and will be managed through the worker code of conduct and relevant training and measured under the ESMP through the community grievance mechanism.
The authorities indicated that the marine area within and surrounding the Project site is formally designated as a restricted coastal zone under national legislation, although there is some informal fishing carried out. According to consultations with stakeholders conducted by the company, about 35 fishing operators carry out fishing activities from two piers located at about 1,500 m from the Project area. Based on a participatory mapping exercise, Project construction and operation area and temporary safety or exclusion zones are not expected to overlap with fishing routes and grounds which will be managed under the ESMS (ESAP #1) and measured under the ESMP through the community grievance mechanism.
The EPC Contractor is currently developing a CESMP, an Environmental & Social Monitoring Plan, a Community Health and Safety Plan (ESAP#1). These should include relevant construction phase controls and additional measures such as worker orientation and cultural awareness training, community safety and awareness programmes. Verification of implementation should be undertaken through routine ESMS monitoring.
Risks for community exposure to hazardous materials during the construction phase are considered low due to limited community interaction with the construction sites, and EPC’s commitment to safety measures such as fencing, and warning signs will safeguard the community.
A Security Management Plan developed for the Limited Notice to Proceed period establishes a security framework applicable to mobilization and early works, construction and installation activities, and demobilization and site closure activities. The Plan is intended to ensure protection of Project personnel, assets, facilities, materials, and information, while complying with applicable national laws and Project HSSE requirements. A Project specific Security Risk Assessment will be conducted to identify security threats, vulnerabilities, and potential impacts associated with Project activities and locations (ESAP #12). A Security Management Plan (SMP) (for construction and operations phases) will be developed by the EPC contractor in accordance with IFC good practice handbook. The SMP will include measures to address GBVH risks, ensuring that all security personnel receive appropriate training and adhere to a Code of Conduct that prohibits any form of GBVH. The Human Rights Policy adopted by the Project Company explicitly addresses security and human rights. Security personnel, which are likely to be sourced from the local communities, will be unarmed.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources:
The project is situated in the Azerbaijan shrub desert and steppe ecoregion of the Caspian Sea and Central Asian Deserts sub-realm in the Central Eurasia realm. The coastal and inland project components and associated facilities are in a mix of Natural and Modified Habitat, which include areas of wormwood and saline semi-deserts, sand dunes, flowing and stagnant water bodies, and coastal reed beds. The marine components are in subtidal silt and sand habitat, composed of sandy and rocky substrates with relatively limited benthic diversity. The project does not overlap with Legally Protected areas, but the marine components lie within the Caspian Seal Transitory Migration and Feeding Area Important Marine Mammal Area (IMMA) designated for the feeding areas and migration corridors of the Caspian Seal.
Terrestrial surveys for the project were conducted in 2024 and 2025. Terrestrial priority biodiversity values include areas of wormwood and saline semi-desert, sand dune and coastal reed bed habitats, Astragalus albanicus (IUCN Red List – Endangered), Wedge-leaved Meadow Saxifrage and Coastal Bastard Toad-flax, Common Tortoise (all IUCN Red List – Vulnerable), European Pond Turtle (IUCN Red List – Near Threatened), Caspian Bent-toed Gecko, Central Asian Race Runner, Dice Snake, Greater Horseshoe Bat, Lesser Mouse-eared Bat, European Hare, Small Five-toed Jerboa, Libyan Jird, Golden Jackal, Red Fox (all IUCN Red List – Least Concern). Baseline surveys also identified several migratory bird species, including threatened waterbirds, mainly recorded in flight during Spring and Autumn migration. Marine surveys were conducted in 2024, which included environmental-DNA sampling for fish species and additional input from local fishermen. Marine priority biodiversity values are threatened and range-restricted fish species, including sturgeons, and the Caspian Seal (IUCN Red List – Endangered). Based on available data and information, most of the Critical Habitat and priority biodiversity values do not overlap with the project’s Area of Influence (AoI) but do occur in the broader area of the project footprint. The project is in Critical Habitat (CH) for the Caspian Seal, for which IFC Net Gain (NG) requirements will apply. IFC Natural Habitat (NH) No Net Loss (NNL) requirements will apply to all other priority biodiversity values.
Per ESAP #13, the Company will update biodiversity assessments, including the residual impact assessment for the Caspian Seal and priority biodiversity values. The updated assessments will rely on available quantitative data and additional information to be obtained through stakeholder engagement. The update will define further survey requirements for sturgeon species as appropriate, and will also include identification and mapping of areas associated with Critical Habitat and priority biodiversity values, where avoidance, minimization and restoration measures will be implemented in line with the project’s mitigation strategy.
The Company will develop and implement terrestrial and marine construction-phase Biodiversity Management Plans (BMPs) to set forth mitigation measures to avoid and minimize impacts on Critical Habitat, Natural Habitat and priority biodiversity values (ESAP #14). The construction-phase BMPs will incorporate all related procedures that will be implemented during the project’s terrestrial and marine activities, which at the minimum, will include procedures for baseline surveys along the product water pipeline, pre-construction checks across all sites, vegetation removal, topsoil and invasive alien species management. For the marine construction activities, to minimize impacts on the Caspian Seal and priority fish species, as applicable, construction activities will be designed around species' migration periods and routes, with the mitigation actions to be confirmed with local specialists. PS6 requirements will be achieved through implementation of GIIP to be also outlined in the project’s CESMP, Dredging Management Plan and related procedures to be implemented as part of the dredging contractor’s management plans (ESAP #1). Underwater noise and vibration that are expected to occur due to filling, and dredging activities will be managed through implementation of low noise/vibration methods. Mitigation measures will include but not limited to (i) using low noise/vibration methods e.g., during filling and dredging, (ii) defining routes to be taken by construction vessels to avoid potential encounters with the individuals of the species, (iii) continuous observation of Caspian Seal presence during construction, and (iv) ceasing activities that generate percussive marine noise if seals are present within 1,000 meters of the project and any other underwater construction when seals are present within 500 meters. The company will appoint a marine mammal biodiversity expert, who will be responsible for implementation and reporting of mitigation measures.
For the post-construction and operations-phase of the project, the Company will develop terrestrial and marine operations-phase BMPs to implement measures to reach NNL objectives (ESAP #15). These measures will include recommendations for restoration in areas of Natural Habitat, as applicable. The marine operations-phase BMP will be aligned with the project’s brine discharge management strategies, which will be developed to mitigate impacts on the Caspian Seal and priority marine species through implementing relevant measures for volume reduction, treatment and discharge minimization. The Company will contract qualified experts with international experience to develop and implement terrestrial and marine operations-phase BMPs.
Per ESAP #16, the Company will develop and implement a Biodiversity Action Plan (BAP), which will be informed by updated biodiversity assessments and commensurate with residual impacts resulting from the project. In addition to measures in the BMPs aimed to achieve NNL, the BAP will define actions for the Caspian Seal to reach NG objectives. In line with IFC PS6, these will include development of additional conservation actions in the IMMA, which will be identified and implemented in coordination with relevant stakeholders to ACWA’s best efforts. ACWA has been consulting with the Department of Fisheries and Aquaculture Center of the Ministry of Agriculture to obtain data and information on the Caspian Seal and sturgeon species that occur in the wider area. Further consultation will be undertaken with the national/regional authorities and institutions, species experts, the Marine Mammal Protected Areas Task Force (MMATF) and IUCN Species Survival Commission (SSC) Sturgeon Specialist Group to identify to inform updated assessments, project’s mitigation strategy and additional conservation actions.
The Company will develop and implement a Biodiversity Monitoring and Evaluation Plan (BMEP), which will include; (i) monitoring and evaluation plans with targeted methodologies and monitoring locations, and (ii) indicators and thresholds for adaptive management, and actions to be implemented when thresholds are exceeded. The monitoring program will be undertaken for a minimum of 2 years but may be extended based on the outcomes (ESAP #17).
PS8: Cultural Heritage:
The onshore Project site is located within the Sumgayit Industrial Park, a heavily disturbed brownfield area. The site has been subject to significant anthropogenic disturbance, including excavations, industrial use, demolition works, and informal dumping of industrial solid wastes. Sumgayit is described as a relatively young city, and no surviving historical monuments have been identified within the city or the Project’s AoI. This has been confirmed by the State Service for the Protection, Development and Restoration of Cultural Heritage under the Ministry of Culture of the Republic of Azerbaijan. Offshore the ESIA does not clarify whether pre-construction marine surveys can also be relied upon to inform the screening of potential unregistered underwater cultural heritage assets. The Cultural Heritage MP developed by the EPC should include a Chance Finds Procedure for offshore and onshore (ESAP #18).
Stakeholder Engagement
The Company has developed a Stakeholder Engagement Plan (SEP) that includes a well-developed stakeholder identification and analysis section. Vulnerable groups are also identified. The SEP describes the disclosure commitments during construction, commissioning and operations and presents the Company’s External Grievance Redress Mechanism (GRM) accessible to all stakeholders. The system permits submissions through multiple channels, including anonymous submissions. The GRM refers to a Project Gender Management Plan that addresses risks related to Gender-Based Violence and Harassment (GBVH) and provides resources and support mechanisms for victims. The SEP defines activities that are partly the responsibility of the Project Company and partly of the EPC (which is also preparing its own SEP and GRM). The SEP currently contains certain gaps, particularly with respect to Grievance Mechanism contact details and the identification of responsible people, as these have not yet been defined. An update of the SEP is required by ESAP #8, and development of an EPC SEP and GRM is required as ESAP #1. These SEPs will include a dedicated section to engagement with fishermen, including (i) additional consultations with local fishermen once the Project specifications and method statements for the offshore components have been finalized and prior to the commencement of construction; (ii) provision of clear maps and notices indicating the location of offshore intake and outfall infrastructure, and any temporary safety areas; and (iii) monitoring of fishing activities during construction and early operation to identify any unforeseen impacts. Where impacts on fishing livelihoods are identified, appropriate adaptive management measures will be applied in line with IFC requirements to avoid, minimize, or mitigate such impacts.
Broad Community Support
Broad Community Support is not applicable for this project.
Environmental & Social Action Plan
| S.no | Description | Anticipated Completion Date |
|---|---|---|
| 1 | Company to require the EPC to update and implement an EPC ESMS and ESMP for the construction phase in line with the requirements of ACWA’s ESMS Implementation Manual, Bankable ESIA ESMS framework and risks and measures identified in the Bankable ESIA, as well as reference to the IFC PS and ADB/AIIB ESF. All management plans must be updated as operational documents, with clearly defined monitoring, reporting, and accountability requirements for the Company, EPC contractor, and subcontractors. The plans to be updated, developed, and implemented shall include, but not be limited to, the following[MM2.1][AG2.2]:• Construction Environmental & Social Management Plan (CESMP);• Environmental & Social Monitoring Plan, including a Marine Sediments and Seawater Monitoring Plan;• Stakeholder Engagement Plan;• Marine and terrestrial Biodiversity Management Plans;• Emergency Response Plan;• Contractor Management Plan;• Supply Chain MP;• Community Grievance Mechanism;• Local Recruitment Plan;• Labour and Working Conditions Management Plan, including Worker Grievance Mechanism;• Cultural Heritage Chance Find Procedure;• H&S Management Plan;• GBVH Prevention and Response Plan;• Demobilization Plan;• Pollution Prevention and Control Plan;• Dredging Management Plan;• Soil and Groundwater Management Plan;• Aggregate Management Plan;• Hazardous Materials Management Plan;• Waste and Wastewater Management Plan; and• Reinstatement Plan. | 12/18/2026 |
| 2 | The Company will include legally binding obligations in its construction contracts (and subcontractor contracts) to aim for compliance with Project standards, including IFC’s PSs, and national legislation. | 01/15/2027 |
| 3 | In preparation for operational activities, the Company will develop an E&S resourcing plan and develop, maintain and implement an Operations Environmental and Social Management Plan (OESMP) consistent with IFC PSs, ADB ESF, AIIB ESF, relevant WBG Environmental, Health and Safety (EHS) Guidelines, national requirements, and ESIA, SEP and ESAP commitments. The OESMP and applicable supporting plans and procedures will include, as relevant:• E&S Monitoring;• Brine Discharge and Marine Water Quality Monitoring• Health and Safety;• Emergency Preparedness and Response;• Waste and Wastewater Management;• Hazardous Materials/Material Handling and Storage;• Traffic and Transportation;• Biodiversity;• Human Resources and Labour and Working Conditions;• Community Health and Safety;• Security;• Recruitment and Training;• Decommissioning; • Stakeholder Engagement and grievance management;• Climate resilience and adaptive management; and• GBVH Prevention and Response. | 09/15/2028 |
| 4 | The Company will finalise the commitments register to capture all Project E&S commitments from the ESIA and any other permit/agreement of relevance to the Project’s E&S performance and confirm that all commitments are captured in the E&S management plans. | 01/15/2027 |
| 5 | Complete the E&S assessment of the associated product water transmission pipeline and other relevant associated facilities once the final design/alignment is sufficiently defined, in accordance with the TOR agreed with the Lenders and applicable ADB/ AIIB ESF and IFC PS requirements. Incorporate required mitigation and management measures into the responsible entity's design, construction and management arrangements. Where land acquisition, restrictions on land use or economic displacement are identified, prepare and implement measures consistent with ADB ESS5/ IFC PS5, including livelihood restoration where required, before the relevant impacts occur. Apply appropriate stakeholder engagement, grievance and chance-find arrangements to affected stakeholders and works. The Project Company will coordinate with ADSEA/other responsible entity in relation to implementation of these requirements | 08/06/2027 |
| 6 | The Company will appoint competent Environment and Biodiversity Consultants, and a Labor Specialist from the early stages of Project development. | 02/12/2027 |
| 7 | Company to require the EPC to recruit a competent E&S Compliance Manager, H&S Expert, Community Liaison Officers (CLO) who also have responsibility for the grievance mechanism, and an independent archaeological consultant. | 02/12/2027 |
| 8 | Company to require the EPC to add clear timelines and milestones to the stakeholder engagement program included in the SEP and include contact details and the identification of responsible persons for its implementation as soon as available. The EPC SEP will include a dedicated section to engagement with fishermen, including (i) additional consultations with local fishermen once the Project designs have been finalized and prior to the commencement of construction; (ii) provision of clear maps and notices indicating the location of offshore intake and outfall infrastructure, and any temporary safety areas; and (iii) monitoring of fishing activities during construction and early operation to identify any unforeseen impacts. Where impacts on fishing livelihoods are identified, appropriate adaptive management measures will be applied in line with Lenders’ requirements to avoid, minimize, or mitigate such impacts. | 12/11/2026 |
| 9 | Company to require the EPC to update the Labour and Working Conditions MP (LWCMP) to: (a) clarify the interface between the EPC Contractor and the Project Company in relation to labour oversight and compliance monitoring, including roles, responsibilities and information flows for review of labour related performance, inspection and audit findings, reporting of non compliances and reporting to lenders; (b) further articulate labour oversight arrangements under the Project ESMS, including the scope, focus and cadence of labour related audits (distinct from general E&S inspections), the criteria for triggering risk-based audits of subcontractors and labour supplying entities, and the mechanisms through which worker voice is systematically captured and considered within such audits, beyond the use of grievance mechanisms alone, and corrective actions are developed and implemented; and(c) clarify in the LWCMP (or in the Subcontractor and Supplier Management Plan), the audit program of the EPC towards subcontractors. Clarifying topics/aspects to be audited, frequency, and reporting requirements with regard to labour and working conditions. | 12/18/2026 |
| 10 | Company to require the EPC to update the Worker Accommodation Plan (WAP) to confirm the specific facilities to be used, their capacity and occupancy arrangements. It also needs to demonstrate how accommodation will be made safe, secure and gender-sensitive, provide culturally appropriate social facilities, and include a documented GBVH risk assessment for each site. It will also include quantitative disaggregated data on the workforce broken down by nationality, skill level or contractor tier once these are available. | 12/18/2026 |
| 11 | The Company to require the EPC to update the Traffic and Transportation Management Plan to include information, maps, and traffic risk assessments on potential routes to be used (highlighting potential sensitive receptors such as residential areas, schools, hospitals) and traffic volumes (e.g. trucks per day) due to Project related construction phase material/waste transport and daily worker commute. It should also include the route to reach the identified quarry/ies, concrete batching plants (if to be located outside the Project site) and the identified hazardous/non-hazardous waste facilities. The TMP to include the offshore works, covering the installation of navigation aids and buoys (including diffuser marking) and issuance of Notices to Mariners with particular care to avoid incidents and nuisances with small boats, informal fishermen, and touristic sea activities through adapted communication. | 11/20/2026 |
| 12 | The Company to conduct a Project specific Security Risk Assessment to identify security threats, vulnerabilities, and potential impacts associated with Project activities and locations. Depending on the results, develop and implement a construction phase Security Management Plan to explicitly address security personnel screening, use of force principles, human rights specific training (including Gender Based Violence and Harassment, GBVH), and community facing grievance arrangements. | 12/18/2026 |
| 13 | Company to update and verify the residual-impact assessment for Caspian seal and other relevant priority biodiversity values against the final marine works footprint, using available ecological and geophysical information, quantitative data, the Caspian seal specialist opinion and relevant information obtained through stakeholder engagement. Confirm the spatial relationship between the final marine works footprint and relevant Critical Habitat and priority biodiversity values and the corresponding avoidance, minimization and restoration measures. Additional field investigation, including for sturgeon where relevant, shall be undertaken where required to resolve material uncertainty affecting the residual-impact assessment or mitigation measures. Incorporate the findings into the final BMP, BAP, Caspian Seal Protection Procedure and associated biodiversity monitoring and adaptive-management measures | 06/25/2027 |
| 14 | Develop and implement terrestrial and marine construction-phase Biodiversity Management Plans (BMPs) to set forth mitigation measures to avoid and minimize impacts on Critical Habitat, Natural Habitat and priority biodiversity values. The construction-phase BMPs will incorporate all related procedures that will be implemented during the project’s terrestrial and marine activities, which at the minimum, will include procedures for baseline surveys along the product water pipeline, pre-construction checks across all sites, vegetation removal, topsoil and invasive alien species management. For the marine construction activities, to minimize impacts on the Caspian Seal and priority fish species, as applicable, construction activities will be designed around species' migration periods and routes, with the mitigation actions to be confirmed with local specialists. IFC PS6 requirements will be achieved through implementation of GIIP to be also outlined in the project’s CESMP, Dredging Management Plan and related procedures to be implemented as part of the dredging contractor’s management plans. Mitigation measures will include but not limited to (i) using low noise/vibration methods e.g., during filling and dredging, (ii) defining routes to be taken by construction vessels to avoid potential encounters with the individuals of the species, (iii) continuous observation of Caspian Seal presence during construction, and (iv) ceasing activities that generate percussive marine noise if marine mammals are present within 1,000 meters of the project and any other underwater construction when mammals are present within 500 meters. The company will appoint a marine mammal biodiversity expert, who will be responsible for implementation and reporting of mitigation measures. | 08/20/2027 |
| 15 | The company will develop and implement terrestrial and marine operations-phase BMPs to implement measures to reach NNL objectives. These measures will include recommendations for restoration in areas of Natural Habitat, as applicable. The marine operations-phase BMP will be aligned with the project’s brine discharge management strategies, which will be developed to mitigate impacts on the Caspian Seal and priority marine species through implementing relevant measures for volume reduction, treatment and discharge minimization. The Company will contract qualified experts with international experience to develop and implement terrestrial and marine operations-phase BMPs. | 10/13/2028 |
| 16 | The Company will develop and implement a Biodiversity Action Plan (BAP), which will be informed by updated biodiversity assessments and commensurate with residual impacts resulting from the project. In addition to measures in the BMPs aimed to achieve NNL, the BAP will define actions for the Caspian Seal to reach NG objectives, which will include development of additional conservation actions in the IMMA to be identified and implemented in coordination with relevant stakeholders (i.e. national/regional authorities and institutions, species experts, Marine Mammal Protected Areas Task Force (MMATF) and IUCN Species Survival Commission (SSC) Sturgeon Specialist Group) to ACWA’s best efforts. | 01/15/2027 |
| 17 | Develop and implement a Biodiversity Monitoring and Evaluation Plan (BMEP), which will include; (i) monitoring and evaluation plans with targeted methodologies and monitoring locations, and (ii) indicators and thresholds for adaptive management, and actions to be implemented when thresholds are exceeded. The monitoring program will be undertaken for a minimum of 2 years and monitoring shall continue thereafter as necessary to warrant the results of the BMP/BAP. | 01/15/2027 |
| 18 | EPC to update the Cultural Heritage Chance Find Procedure to include clear instructions on how to secure, delineate and mark the discovered area in case it is located offshore/nearshore. | 12/18/2026 |
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**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.