IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Management System
At the corporate level, Acciona has a comprehensive set of E&S policies outlined in its Policy Book (https://tinyurl.com/53vetu69), aligned with good international industry practices (GIIP). These include, among others, the Sustainability Policy, Environmental Policy, Stakeholder Relations Policy, Human Resources and Occupational Health and Safety (OHS) Policy, Human Rights Policy, and Diversity, Equity, and Inclusion Policy. Additionally, Acciona has a Code of Conduct (https://tinyurl.com/p6pr7th8), Ethical Principles for Suppliers, Contractors and Collaborators (https://tinyurl.com/mww5d6uh), and an integrated E&S Management System (ESMS) that aligns with ISO 14001 (environmental management) and ISO 45001 (OHS management) standards. This system includes corporate-level indicators, targets, and metrics, with senior management actively involved in improvement plans.
At the subproject level, E&S practices follow host country regulations and ISO certifications. For specific subprojects like Metro Line 6, the ESMS also aligns with IFC PS. While Acciona provides guidance and supervision, the respective subsidiaries and subproject units are responsible for subproject-level E&S performance.
E&S Risk Identification and Management
Acciona employs a comprehensive approach to assessing and managing E&S risks throughout subproject development, implementation, and operations phases. During the early development stage, E&S due diligence is conducted to identify potential risks and impacts before moving forward with a subproject. Once a subproject progresses, subsidiaries conduct E&S impact assessments (ESIA), as required by national laws, and develop detailed E&S Management Plans (ESMPs) at the subproject level to ensure compliance and effective E&S management. As they become available, ESIAs for all subprojects utilizing IFC proceeds will be publicly disclosed by IFC via its disclosure website.
The ESIA for Metro Line 6, which is aligned with IFC PS, has been approved by the regulator. Linha Uni’s ESMPs are designed to align with IFC PS, with semi-annual independent audits being conducted to verify compliance.
In Peru, the ESIA for the Tumbes subproject has been approved by the regulators (construction began in April 2024), while the ESIA for RCTL has been submitted and is pending approval. These ESIAs, prepared by specialized E&S consulting firms, and disclosed locally in accordance with local law, mostly align with IFC PS. Considering that the RCTL and Tumbes subprojects cross lands of four communities, per ESAP #1, Acciona will develop supplemental Social Impact Assessments (SIA) and ESMPs for these subprojects to ensure culturally appropriate engagement and social risk management in line with IFC PS. In relation to IPTL, HPTL and HMTL, per ESAP #2, Acciona will ensure that ESIAs in line with IFC PS are in place.
As per ESAP #3, the TL subprojects in Peru will develop ESMPs, commensurate to the scale and impacts of the activities and consistent with applicable legal requirements, the project ESIA (and supplementary SIA, if applicable), the IFC PS and relevant WBG EHS Guidelines. Based on the initial information on the alignment of the subprojects, the TLs will not cross any indigenous territories, but where relevant, as part of ESAP #2, Acciona will include an assessment of potential impacts on Indigenous Peoples as part of the ESIA process, and if impacts are identified, the client will develop and implement mitigation measures in compliance with PS7 requirements.
At the corporate level, Acciona systematically assesses climate change risks and their potential impacts on projects using advanced tools like satellite data, predictive modeling, and scenario analysis.
Organizational Capacity
Acciona’s Global Sustainability Division develops and manages the company’s five-year Sustainability Master Plan (SMP) and reports E&S performance to senior management. Linha Uni has an E&S team overseeing the principal construction contractor, (which has its own E&S team). In Peru, a specialized E&S consulting firm handles the ESIA process, community engagement, and easement negotiations, overseen by Acciona Peru’s General Manager, with support from the Corporate Sustainability Manager in Spain. As per ESAP #4, Acciona will assign a qualified E&S Coordinator in Peru to manage E&S aspects.
Emergency Response Planning
Per the relevant ESIA document and local regulations, each subproject site develops an Emergency Preparedness and Response Plan (EPRP). The EPRPs include emergency plans for scenarios such as fire, medical emergency, spills, and weather events, etc. The EPRPs also include arrangements for emergency equipment, inspections, signage, brigades, training, drills, and exercises. For example, each construction site of the Metro Line 6 project has its trained brigade, and monthly simulations are carried out covering a variety of scenarios. Linha Uni has a dedicated rescue team and dedicated paramedics, with four ambulances shared across the project. As per ESAP #3 Acciona’s ESMPs will include EPRPs in line with IFC PS.
As per ESAP #5, Linha Uni will develop EPRPs for stations of the Metro Line 6 with focus on the safety of the metro users (passengers), consistent with the project ESIA, IFC PS, relevant WBG EHS Guidelines, and applicable legal requirements.
Monitoring and Review
At the corporate level, Senior Management review progress annually against the five-year SMP, as well as E&S key performance indicators (KPI), including: (i) internal and external audits, (ii) compliance with legal requirements, (iii) analysis of environmental incidents, (iv) work related accident frequency and severity rates, (v) significant EHS and social impacts, (vi) corrective action tracking, and (vii) contractor performance. The Audit and Sustainability Committee reviews Acciona's ESG Risk Management System on a regular basis, ensuring that risks are identified, managed, and communicated effectively.
At the subproject level, an independent audit is conducted of Metro Line 6 on a semi-annual basis to review the ESMS against the IFC PS and legal requirements. While these audits are carried out on behalf of lenders, the results are also used by Linha Uni to monitor contractor E&S performance. Independent surveillance and certification audits against ISO 14001 and 45001 are also carried out. Project KPIs for energy use, water consumption, waste generation, etc. are also tracked. As per ESAP #3, subproject ESMPs will include an E&S Monitoring Framework (ESMF) in line with IFC PS.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures
Acciona’s Policy Book includes a comprehensive HR and OHS Policy that addresses HR commitments and principles. Linha Uni’s Code of Ethics and HR Policy align with local regulations and PS2 requirements. The Metro Line 6 semi-annual independent audits indicate adequate implementation of HR policies and procedures. The TL subprojects will develop their own HR policies in line with corporate and legal standards. Acciona’s Ethical Channel allows for anonymous reporting of breaches, and Linha Uni has an online mechanism for addressing workers’ concerns. Each contractor has its own grievance mechanism. Both Acciona and Linha Uni prohibit harassment and discrimination, with a focus on diversity, equity, and inclusion. Linha Uni has set gender diversity goals and trains local women for construction jobs. As per ESAP #6, Acciona will develop a Workforce Management Procedure (WMP) including a Workers Grievance Redress Procedure (WGRP) managed by trained personnel, that covers Gender-Based Violence and Harassment (GBVH) risks, applicable to the subprojects, ensuring appropriate working conditions, and mitigating negative impacts on workers and communities.
Occupational Health and Safety
Acciona’s top priority per its five-year SMP is its zero-accident target. The Company has a well-structured OHS management system and most sub-divisions are certified to ISO 45001, (including Metro Line 6). The TL subprojects will become certified once operational. Between January 2023 and July 2024, Metro Line 6 has an accumulated lost time injury frequency rate of 1.25. As per ESAP #3, Acciona’s ESMPs will include subproject specific OHS Plans, consistent with local requirements, the IFC PS and the WBG General EHS Guidelines. As per ESAP #7, Linha Uni will include in the scope of the semi-annual independent E&S audit reports, a section that tabulates the work-related accidents, illnesses and near misses during the reporting period, assesses the adequacy of incident investigations and resulting corrective actions, and analyses relevant OHS KPI trends since project inception, including the lost time injury frequency rate.
Supply Chain and Workers Engaged by Third Parties
The Company’s supply chain approach aligns with PS2 requirements, guided by Acciona’s Ethical Principles, which prohibit child and forced labor. The company conducts formal E&S screening of suppliers, requiring them to adopt Acciona’s Code of Conduct and meet OHS standards, with the right to terminate contracts for breaches. For subprojects, Acciona forms concessionaire companies that contract with Acciona Construction, which then subcontracts local contractors. Each concessionaire’s ESMS aligns with Acciona Construction’s global model, ensuring supervision, inspections, and audits of all contractors, with similar arrangements for the operations phase.
PS3: Resource Efficiency and Pollution Prevention
Waste management and pollution prevention plans are developed for each site, with hazardous waste handled by authorized third parties. The Metro Line 6 project includes a comprehensive waste and fluids management program, and noise and vibration monitoring are conducted regularly. As per ESAP #3, Acciona’s ESMPs will include subproject specific waste management plans, pollution prevention plans, and hazardous materials management plans, consistent with local requirements, the IFC PS and the WBG General EHS Guidelines.
Acciona measures its Scopes 1, 2, and 3 GHG emissions and aims for Net Zero by 2040 for Scopes 1 and 2, and by 2050 for Scope 3, with significant reductions by 2030. In 2023, Acciona’s direct emissions were 181,819 tCO2e, and indirect emissions were 20,670 tCO2e. Subprojects identified for IFC financing are expected to emit 27,329 tCO2e annually, with efficiency features incorporated into designs. The Company also focuses on water efficiency, achieving a 15% reduction in water-stressed countries.
PS4: Community Health, Safety and Security
Acciona uses contracted security personnel for asset surveillance and access control. Linha Uni has a Traffic Control Program to manage disruptions around construction sites, including safety measures and traffic control. Linha Uni also has a monitoring and prevention plan to avoid structural damage to buildings bordering construction sites, as well as a procedure to address complaints related to alleged structural damages. As part of ESAP #13, Linha Uni will include in its Stakeholder Engagement Plan (SEP) arrangements to ensure stakeholders are aware of the reporting mechanism.
As per ESAP #3, Acciona’s ESMPs will include subproject specific Road and Traffic Management Plans, and Security Management Procedures, consistent with local requirements, the IFC PS and the WBG General EHS Guidelines. As per ESAP #6, Acciona will include within the WMP, a GBVH Risk Assessment and Preventive Action Procedure to address risks associated with a large influx of workers during construction, and GBVH risks to users of the metro during operations.
Linha Uni has developed schematic designs for stations which consider Life and Fire Safety (L&FS) and Accessibility features. As per ESAP #5, Linha Uni will prepare a L&FS and Accessibility Master Plan. A certified professional will confirm that the planned design of L&FS systems along the metro line and at each station adheres to the WBG General EHS Guidelines' L&FS Section, specifically including the description (or rational analysis) of the Smoke Management System (required for large underground stations), and evacuation modeling and smoke management modeling (CFD or similar).
Linha Uni will also engage a suitably qualified L&FS professional acceptable to IFC to conduct a review, as part of project commissioning, to certify that the construction of the L&FS systems has been carried out in accordance with the accepted design. The design will provide features of universal design and accessibility based on the Brazilian accessibility regulations.
PS5: Land Acquisition and Involuntary Resettlement
Acciona’s Corporate Human Rights Policy emphasizes avoiding involuntary resettlements and minimizing impacts through fair compensation. For Metro Line 6, 369 expropriations were conducted by the Grantor before Linha Uni’s concession, with an additional 21 expropriations since then. Compensation values were court-defined and deposited in escrow accounts. The Grantor also acquired 24 public areas without existing structures. Expropriations followed national and Sao Paulo State regulations, with ongoing processes for two additional sites.
As per ESAP #13, Linha Uni will update the existing SEP to include a process to assess grievances related to residual impacts from past land acquisition, determine eligibility, and if found eligible, targeted benefits should be made available to the grievant. Per ESAP #8, Linha Uni will also develop a Resettlement and Livelihood Restoration Framework (RLRF) to bridge gaps between PS5 and regulatory frameworks, including a Terms of Reference (ToR) for a PS5-aligned Resettlement and Livelihood Restoration Plan (RAP/LRP) if future resettlements are required. The RAP/LRP will include processes that allows Linha to 6 conduct land acquisition and resettlement achieving outcomes consistent with the objectives of PS5.
In Peru, land easements for TL subprojects involve private, government, and community lands, with permanent restrictions on certain activities within easement sections. No physical displacement has been identified. However, Peruvian law allows for involuntary resettlement for public interest reasons if market-based agreements fail. In such cases, Acciona relies on a specialized consultant to provide market values for direct negotiations with landowners. If agreements are not reached, a judicial process led by the relevant government agency is initiated. As per ESAP #9, Acciona will develop a Resettlement and Livelihood Restoration Framework (RLRF) to bridge gaps between PS5 and regulatory frameworks, including terms of reference and guidance for developing PS5-aligned Resettlement and/or Livelihood Restoration Action Plans (RAP and/or LRP) prior to the construction of subprojects in Peru if any economic or physical displacement is required. Considering that construction at Tumbes has begun and is imminent for RCTL, and that only economic displacement is expected, as per ESAP #10 Acciona, will prepare PS5-aligned LRPs for those subprojects.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Metro Line 6 is located in an urban area. The client complies with Brazilian legislation that requires compensation in permanent preservation areas (APP).
The three TLs of the first tranche cross different ecoregions: Tumbes is located within the South American Pacific mangroves, RCTL stretches across the Sechura desert and the Tumbes-Piura dry forests, and IPTL is located in the Sechura desert. The desert and the dry forests areas are largely Natural, whereas the landscapes within the South American Pacific mangroves are altered due to agricultural activities. The new Tumbes substation and associated distribution line will be located in Modified Habitat. Risks related to bird collisions are considered low in the ESIA and will be further mitigated by the Client through the installation of flight diverters, as required by authorities. As per ESAP #11, the Tumbes subproject will develop and implement a Bird Fatality Monitoring Program aligned with GIIP.
RCTL is composed of a main TL (~86 km), three variants (~3 km in total), a new substation and the expansion of an existing substation. Natural habitat conversion will be ~50 ha (~38 ha of dry mountain forest, ~2 ha of dry savanna forest, ~2 ha of coastal desert, and ~8 ha of arid shrub thicket). These land cover types support several priority biodiversity values, among these: seven plant species, including the Mosquera (Croton pavonis, IUCN Red List Endangered) and three nationally threatened fauna species, such as the Long-snouted Bat (Platalina genovensium) and Boa constrictor ortonii, (both nationally listed as Endangered), and the range restricted Western Worm Lizard (Amphisbaena occidentalis, IUCN Red List Least Concern). As per their national permitting requirements, the Client will relocate sensitive species and install bird flight diverters. As per ESAP #12, the RCTL subproject will develop a Biodiversity Management Plan (BMP) that will include all measures to be implemented to achieve No Net Loss of the priority biodiversity values (species and habitats) and define the adequate monitoring program.
IPTL is composed of a main TL (~141 km), one variant (~4 km), the expansion of two substations and a new substation. Two segments are located within the eastern and north-eastern buffer zone of Legally Protected Area San Fernando National Reserve (SFNR) (IUCN Cat VI), (specifically T-217 to T-260 (~18 km), and T-298 to T-324 (~12 km)). In the SFNR buffer zone and surrounding areas, there are numerous priority biodiversity values which are also identified in the SFNR Management Plan, including the Andean Condor (Vultur gryphus, IUCN Red List Vulnerable, and nationally listed as Endangered).
HPTL of the second tranche is composed of a main TL (~93 km) and two new substations, while HMTL is composed of a four TLs (total distance ~156 km), three new substations, and expansion of two existing substations. Both subprojects are located in the Sechura Desert ecoregion, where the predominant land cover is coastal desert, which is largely Natural. Similar to IPTL, HPTL will overlap the SFNR buffer zone by ~21 km, (two segments of the 500 kV Poroma – Colectora TL).
HMTL will intersect with the Chala Key Biodiversity Area (KBA) for ~6.5 km (~3 km of the San Isidro – Pampa TL and ~3.5 km of the Pampa – Chala TL). Additionally, the Pampa 2 substation will be located within the KBA, covering an area of ~2.1 ha. The Chala KBA is designated due to the presence of Pygmaeocereus bylesianus (IUCN Red List Critically Endangered), a cactus species that meets the Critical Habitat criteria within the KBA.
While ESIAs for IPTL, HPTL and HMTL were not yet developed at the time of IFC’s appraisal, available information indicates the potential presence of several priority biodiversity values within the Sechura Desert ecoregion, including individuals of threatened species, migratory birds, and restricted range species. Through careful micro-routing of the lines and siting of infrastructure (e.g. substations and temporary access roads) it will be possible to minimize impacts on habitats and species. This will be fully assessed in each subproject’s ESIA.
As part of ESAP #2, Acciona will conduct an IFC PS-compliant ESIA for IPTL, HMTL, and HPTL, where necessary mitigation measures to meet PS6 requirements will be defined. For IPTL and HPTL, this will include characterizing the presence of priority biodiversity values within the relevant areas of the SFNR buffer zone, to ensure a better understanding and assessment of potential impacts, including the potential for bird collisions and/or electrocutions, and to determine the necessary mitigation and monitoring measures in line with GIIP. As part of the ESIA process, Acciona will consult with the SFNR managers and stakeholders and implement additional conservation programs to promote and enhance the conservation aims and effective management of the area.
The ESIA process for HMTL will include an equivalent consultation for the Chala KBA, as well as corresponding additional conservation programs. Furthermore, since the Chala KBA is designated for P. bylesianus, which meets the threshold for Critical Habitat, HMTL will need to achieve Net Gain. However, since the project footprint will not affect the species once mitigations are implemented, this can be achieved through additional conservation programs and therefore an offset is not anticipated. In line with IUCN Guidelines for Reintroductions and Other Conservation Translocations, a rescue and relocation protocol for P. bylesianus will be included in the ESIA and implemented, if necessary, prior to any construction activities in the KBA.
As part of the ESAP #12, Acciona will develop BMPs for IPTL, HMTL and HPTL, (derived from each subproject’s ESIA), which will include the measures to be implemented to achieve No Net Loss of priority biodiversity values (species and habitats) and define the adequate monitoring programs. The BMP for HMTL will also include the measures to be implemented to achieve Net Gain for P. bylesianus.
PS8: Cultural Heritage
Cultural heritage assessments are part of the ESIA process in Peru, following local regulations for chance finds management that includes procedures to report chance finds to authorities and realign the project if necessary. Linha Uni has a Cultural Heritage Management Program, including a chance finds procedure aligned with IFC PS8, monitored by municipal, state, and national authorities. In the Metro Line 6 project, artefacts indicating afro-descendant settlements were found at one site (14 Bis Station). A local advocacy group is campaigning for the new station to help preserve the memory of the site’s history, and the Grantor has formed a committee with representatives from heritage institutes and civil society to engage with the group. As part of ESAP #13, Linha Uni will include in SEP a set of suggestions on how to recognize the history of afro-descendants at 14 Bis Station, which will then be shared with the Grantor for their consideration.
