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.
PS 2 – Labor and Working Conditions
As of December 31, 2025, Voltalia employed 1,922 employees, of whom c. 71% are men and c. 29% are women. Of these employees, 110 workers had a temporary contract. The Investee currently has three employees.
Voltalia has group-level Human Resources (HR) policies, which are generally aligned with IFC PS2, and cover aspects such as hiring, rights, obligations (including non-discrimination and equal opportunities), freedom of association, collective bargaining, and worker grievances. The principal documents regulating labor-related issues include an Ethics Guide & Code of Conduct, and Group Diversity, Equity & Inclusion Policy. Additionally, Voltalia implements a Human Rights Policy which explicitly makes commitments rejecting child and forced labor, any form of discrimination, harassment, abuse or violence, and respecting equal opportunities. These policies apply to all Voltalia subsidiaries and to all contractors and workers. Per ESAP#7, Voltalia will update its Ethics Guide and Code of Conduct to specifically address risks related to gender-based harassment/violence (GBVH), applicable to all project workers (including their conduct within worker accommodation facilities), and provide ongoing training related to this topic.
As per ESAP#8, Voltalia will develop a ‘Worker Handbook’ specific and adapted to each future sub-project that is applicable to all project workers. The Worker Handbook will include information related to general employment terms and conditions (e.g., working hours, entitlements, social security, H&S obligations), collective agreements, worker associations, non-discrimination and equal treatment of migrant workers, and provide a link or reference to relevant Voltalia policies, plans and procedures.
Voltalia’s human resources processes include a whistleblower channel managed by Voltalia’s Compliance Department, aligned with its Ethics Guide and Code of Conduct. This process is available to all Voltalia employees globally, contractors, subcontractors, and suppliers. As per ESAP#9, Voltalia will update this channel, to implement a project grievance procedure and mechanism which extends to all worker-related grievances, following IFC's PS2 requirements. The grievance mechanism will be made available to all project workers, irrespective of their employer, and will be managed by Voltalia. Voltalia will disseminate information and provide ongoing training about its use to the workforce, including contractors and subcontractors (in a language the workers understand). The mechanism will include specific considerations and adequate channels to handle GBVH grievances and cases. It will consist of multiple entry points to raise and address allegations, including options to report anonymously if preferred. Voltalia will appoint an adequately trained grievance officer (including relevant training on how to handle GBVH-related grievances and referral pathways).
As per ESAP#10, Voltalia will develop a project worker’s accommodation policy establishing the basic requirements that any accommodation implemented as part of their sub-projects (including contractors and subcontractors’ facilities) should comply with, in line with local regulations, IFC PS2 requirements and aligned with IFC's and EBRD's Good Practice Note on Workers' accommodation. The policy should define criteria to identify sub-projects that require the development (and implementation) of project-specific Worker Accommodation Plans.
Voltalia has a corporate Occupational Health and Safety Management System (OHS MS) accredited with ISO 45001, based on a Health, Safety, Environmental and Social Policy, which defines OHS principles and commitments made by senior management and promoted at all organizational levels. At the project level, Voltalia contractually requires its contractors/sub-contractors to adhere to its 'HSE Minimum Requirements' and develop and implement a site-specific OHS MS, including plans and procedures of a scale appropriate to their scope of work. Voltalia assesses the adequacy of their contractors/subcontractors OHS MS and requires any identified deficiencies are addressed before site mobilization. All workers complete basic OHS training, and supervisory staff and employees undertaking high-risk activities complete specific OHS training.
Voltalia’s corporate HSE Contractor Management Procedure provides for a standardized and transparent process for the management of the HSE performance of contractors. As per ESAP#11, Voltalia will update this procedure to define its approach to managing, providing oversight of, and monitoring project contractors' (and subcontractors') compliance with local labor laws, IFC PS2 and be consistent with the general principles described within IFC Good Practice Note: Managing Contractors' Environmental and Social Performance. The updates will include a template for semi-annual independent labor audits, which will be implemented on all sub-projects where IFCs redeemable preference shares will be allocated.
PS 3 - Resources Efficiency and Pollution Prevention
Pollution generated during the construction and operation of solar PV projects is generally minor and readily mitigated through standard pollution prevention and control measures. Voltalia will require its project contractors/subcontractors to comply with environmental license conditions and the requirements of project-specific ESIAs and ESMPs (ESAP#1 and #2), IFC PSs, covering such aspects as fugitive dust from earth-moving activities; noise and exhaust from construction machinery; sanitary effluents from worker facilities, and non-hazardous and hazardous solids wastes (typically disposed of through registered contractors or at the local waste disposal facilities in the case of non-hazardous wastes), as applicable. Noise from construction activities is not expected to be a significant issue for the sub-projects, as there will likely be limited nearby sensitive receptors, and construction activities will be restricted to daylight hours.
Volumes of liquid, solid, and hazardous waste generated by projects during operations are expected to be low. Small quantities of water will be required to clean solar panels during the operational phase. Water will only be sourced from appropriately permitted sources and any potential impacts on such resource will be assessed as part of the sub-project ESIAs. Voltalia will implement systems and controls for projects' operations to comply with national standards and IFC PS.
PS 4 - Community Health, Safety, and Security
Risks and impacts to affected communities of the Investee’s sub-projects will be individually assessed during the ESIA process (as per ESAP#3). Based on the findings, appropriate mitigation measures will be defined and implemented during the design, construction, and operation of each project.
Electrical equipment will be fenced, and cables will be insulated to avoid any electrical hazards. Access to agricultural fields, villages, communities, and their networks will not be disrupted/hindered. The main road traffic risk associated with the projects is related to transporting solar components (PV panels, substation components, etc.) to project sites from vendor facilities. Additional risks relate to transporting other construction materials and the project personnel. Risks associated with this transport will be assessed within the project ESIAs. As per ESAP#3, applicable control measures to protect local community members from road traffic accidents, in line with GIIP, will be defined in each sub-project ESIA and implemented by Voltalia and its contractors/sub-contractors.
Voltalia has a group-level policy focused on Human Rights, which will be adopted by the Investee for the implementation of the project. Additionally, as part of Voltalia’s corporate ESMSs (ESAP#1), Voltalia will develop and implement a Security Management Procedure aligned with IFC PS4 and the Voluntary Principles of Security & Human Rights. Projects will, in turn, develop project-specific Security Management Plans meeting the requirements defined within the Security Management Procedure. The plan will include a Code of Conduct for site security personnel, a security risk assessment and incident reporting, and an investigation process. The project's community grievance mechanism will be available for members of the community or employees in the event of a violation of the code for security personnel or other grievance related to security personnel.
PS5 - Land Acquisition and Involuntary Resettlement
Voltalia's current company E&S policies do not encompass land acquisition and involuntary resettlement. Voltalia will develop and implement a comprehensive set of procedures to manage E&S risks and impacts, including a LARP (ESAP#1). The LARP will specifically address scenarios where government expropriation is a possibility and will be applicable to any new or future project, asset, or acquisition. Prior to project acquisition, an initial screening for legacy land acquisition issues will be conducted. The LARP will provide guidelines for determining a project’s land take requirements and exploring project alternatives to minimize or avoid displacement during the project design phase and before land acquisition. Furthermore, the LARP will include guidelines for identifying, assessing, and managing the risks and impacts of land acquisition and involuntary resettlement, particularly concerning vulnerable individuals, in alignment with PS 5 requirements. The Procedure will also outline requirements for resettlement and livelihood restoration planning and implementation, including establishing eligibility and entitlements for compensation at replacement value, according to principles of transparency and consistency for all affected communities and individuals. Moreover, the LARP will include guidance on stakeholder engagement, disclosure of relevant information, informed consultation and participation, and consulting and incorporating the perspectives of women and vulnerable persons into land acquisition and resettlement planning and implementation. The Procedure will mandate the development of ‘Resettlement Action Plans’ (RAP) or ‘Livelihood Restoration Plans’ (LRP) in cases of physical or economic displacement. The LARP will also address the approach to identifying and documenting previous government-managed resettlement and compensation in projects where land acquisition and resettlement were government responsibilities. It will involve collaboration and, as needed, where government capacity is limited, active participation during the planning, implementation, and monitoring of such plans and measures. As required, if such measures do not meet the relevant requirements of PS 5, the LARP will provide guidance on the preparation of a Supplemental Resettlement Plan. The community grievance mechanism (CGM), as per ESAP#1 and #12, will also be able to address grievances associated with land acquisition and involuntary resettlement.
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
Voltalia’s HSES Policy includes provisions for maintenance of biodiversity and functioning ecosystem services. As per ESAP#1, Voltalia will develop and implement a Biodiversity Screening and Management Procedure as part of its refined corporate ESMS applicable to the project. The Biodiversity Screening and Management Procedure will include guidelines for the identification and management of risks and impacts associated with all sub-projects and their locations in line with PS1 and PS6 requirements. The initial biodiversity screening will be applicable to all assets that may have ongoing impacts on biodiversity values or will determine a new footprint. To inform planning and decision-making processes, the screening procedure will provide guidance on the preparation and use of sensitivity mapping based on spatial data to identify areas that are of high biodiversity value and would be sensitive to project-related impacts. The Biodiversity Screening and Management Procedure will set forth requirements for identification of and engagement with relevant stakeholders, including affected communities, government officials, academic institutions, and conservation organization with respect to identification and management of Legally Protected and Internationally Recognized Areas, Natural and Critical Habitat, and associated priority biodiversity values. The Procedure will also provide guidance on the identification of relevant risks and impacts, and the definition of mitigation measures commensurate with these to inform site-specific surveys and assessments leading to development and implementation of project-level Biodiversity Management Plans (BMPs) as per ESAP#2.
Voltalia’s existing ESRA defines conditions for biodiversity surveys and assessments including a Critical Habitat Assessment (CHA), templates for habitat mapping and categorization, identification of flora and fauna species, Protected Areas and ecosystem services, as well as relevant consultant guidance within the scope of ESIAs conducted at the project-level and sets forth criteria to be used during the risk assessment to identify projects that lack biodiversity baseline data and those that are located within Legally Protected or Internationally Recognized Areas. As per ESAP#3, Voltalia will update its ESRA to incorporate a process, applicable to the project, to identify and exclude high-risk areas for biodiversity, including Alliance for Zero Extinction (AZE) and UNESCO Natural and Mixed World Heritage Sites (WHS).
