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 Assessment and Management System: Mota Engil (‘ME’ or ‘the Group’) and its business units and projects in different countries are bound by a Safety, Health, Environment, Social, and Quality (SHEQ) policy. The general guidelines of the SHEQ policy are developed at the corporate level and adapted at country operations to meet local and project contexts. The SHEQ policy includes a set of requirements (Reglas de Oro or Golden Rules) that set up minimum safety, health, environment, and social criteria applicable to all projects, subcontractors, and the supply chain. Other policies include a Code of Ethics and Business Conduct, a Risk Management Policy, an Anti-Corruption, Bribery and Prevention Policy, a Global Human Resources Policy and a Harassment and Discrimination Policy (to be further described under PS2). The Group is currently finalizing a Sustainability Policy, as well as additional corporate policies for Human Rights, Corporate Security and Transport management (ESAP #1).
An Integrated System Management Manual (ISMM) defines the procedures, general working methods, and organizational framework implemented across the Group and is ISO 9001, 14001, and 45001 certified in all African countries of operation. While the Corporate SHEQ department provides guidance and ensures compliance, in-country SHEQ teams monitor and measure the implementation of the ISMM at the project level and prepare quarterly E&S reports through a centralized platform accessible to the entire organization. ME will ensure that all policies, plans, and procedures are updated on a regular basis and made accessible to relevant staff in an electronic format via an electronic document control system. Relevant provisions of the ISMM will also apply to subcontractors and third-party companies working on relevant projects (ESAP #1).
Identification of Risks and Impacts: The Group has a Risk Management Procedure in place to address potential E&S non-compliance risks against its own SHEQ requirements at three levels: (i) E&S screening and risk identification during the bidding process, (ii) risk management, and (iii) risk monitoring at the project execution level. An Environmental Plan, Social Management Plan (SMP), a Quality Management Plan (QMP), and a Safety & Health Management Plan (SHMP) provide the framework reference documents to guide how ME manages and mitigate E&S aspects during the construction phase.
Going forward, ME will combine the use of these policies into a E&S scoping and compliance register at the onset of each project. The register will be applied to all projects where ME acts as a contractor and will (i) define the E&S risks emanating from ME’s onsite activities; (ii) detail the roles and responsibilities of ME’s activities and footprints against the project’s responsibilities; and (iii) where required, define project/site-specific management measures, action plans, and resources to be implemented by the Group, in line with the Performance Standards requirements (ESAP #2). ME will keep documented evidence of these registers for verification and validation purposes.
Land for the storage of construction material and machinery is either provided by the Project or accessed directly by the Group on a willing buyer- willing seller or willing lessor- willing lessee basis. ME has a Construction Site Yard Manual that includes a sustainability section to ensure a comprehensive application of the SHEQ policy. As per (ESAP #1), ME will include a procedure for land access and permitting in the Construction Site Yard Manual. The procedure will (i) define ME’s role in the land access process, (ii) exclude the risk of physical or economic displacement for these areas including those of informal settlers, (iii) list the necessary steps, engagement efforts, and compensation measures for its execution and permit requirements, (iv) define the required documentation and level of engagement for a negotiated land access process and (iv) set up a livelihood restoration/community benefits framework where applicable or needed.
Organizational Capacity and Competency: At the corporate level, Mota-Engil’s SHEQ department plays a guiding and assurance role, ensuring that the SHEQ policy and the Golden Principles are cascaded down to the countries of operations. Each country has one SHEQ manager who reports to the country director and is responsible for sustainability planning, coordination among projects, and reporting processes.
At the project level, ME is committed to and will deploy additional EHS resources whereas specific E&S responsibilities are identified (ESAP #2) based on the screening and identification of risks. The Group will also develop and implement an EHS training plan, training matrix, and material to ensure the competency of its SHEQ team and will require EHS and OHS awareness training to be delivered to all staff and subcontractors (ESAP #1).
Emergency Preparedness and Response: Mota-Engil has an emergency incident investigation and reporting procedure (EIIRP) at the corporate level, broadly aligned with IFC PS. The procedure is cascaded to project sites for implementation. The basics of life and fire safety were observed at the various sites (Angola and Nigeria) and were adequate for the scope of emergency situations at the site level. ME will update the EIIRP to include: (i)the distinction between a fire drill (requiring staff to move to the assembly point), a security drill (requiring staff lockdown in safe havens); (iii) a procedure for regular inspection of fire drills and extinguishers. (ESAP #1). The implementation of the EIIRP will be informed by the OHS audit that will include a process safety component, as mentioned in the PS2 section below.
Contractor Management and Supply Chain Management: To work with ME, all contractors, subcontractors, or other third parties must apply and qualify to enter a digitalized and centralized database. A set of comprehensive SHEQ criteria included in the Contract General Conditions and are legally binding for subcontractors. Additionally, all third parties shall demonstrate compliance with the Code of Ethics and Business Conduct and the Golden Rules throughout the project cycle. Sub-contractors’ HSE performance is supervised by the site HSE manager. The Supplier/subcontractor performance rating is subdivided into 3 levels and is issued annually, including specific HSE criteria for subcontractors. For the lowest level, suppliers/subcontractors are automatically blocked by the system and assigned corrective actions, at the completion of which the supplier/subcontractor will be readmitted by the system.
ME has developed a digitalized supply chain management system that allows for tracking the performance of suppliers globally, with over 14,000 suppliers were registered in 2023. The Group is currently updating its supplier assessment process, including ESG requirements to be included in the supplier onboarding program. A Supplier Code of Conduct and Ethics is communicated as part of the Manage Subcontractor and Supplier Procedure and will be aligned with IFC PS and WBG EHS requirements. The Procedure will also include a training on the SHEQ policy and the Suppliers Code of Conduct and Ethics to all selected suppliers (ESAP #1).
Monitoring and Review: ME undertakes annual internal and external audits for the implementation of the SHEQ policy and requirements at a global level. All ME’s companies and Projects regarding Engineering and Construction are currently certified on ISO 9001, 14001 and 45001. ME will develop a Training Performance Management and Monitoring Plan that will include an internal and external SHEQ compliance review schedule. The plan will track SHEQ performance by including Key Performance Indicators (KPIs) with agreed control and mitigation measures as well as observations and actions from internal and external monitoring. KPIs will be linked to specific targets at the Group level and will also cover sub-contractor and third-party service providers.
SHEQ committees at Corporate, Company’s and Project’s level monitor the implementation of the Risk Management Procedure at project operation level, ensuring that E&S risks are identified, managed and communicated. Project operations are required to prepare monthly EHS performance reports detailing adherence and progresses to identified EHS criteria. The Corporate team also perform regular and spot-check inspections assessing the effectiveness of the SHEQ policy on site and recommend corrective measures.
Information on subcontractor and third-party workforce providers is not regularly shared with the Group. Going forward, ME will expand the Training Performance Management and Monitoring Plan to all its subcontractors and third-party service providers. The project operation team will also set up a program of regular meetings with subcontractors on site to review its E&S performance, discuss any non-compliance issues and promptly address them with corrective actions (ESAP #1).
PS2 – Labor and Working Conditions
ME has 53,132 direct employees: 86% are male, and 14% are female. The majority of the direct and contracted workforce is located in global operations in Africa. Around 20,000 workers are employed through subcontractors, including truck drivers, security personnel, and camp management and services personnel.
Human Resources Policies and Procedures: ME has an HR Global Policy that sets the group governance model and key people process applicable to all different business units. Other relevant HR policies include the Code of Business Ethics, the Social Management Policy, a Gender Equality Plan, and the Harassment and Discrimination Policy. The Corporate HR department sets up a series of online refresher training in various languages on the company’s Golden Rules and HR Global Policy. Furthermore, in-person training is delivered periodically at the country level. Annual internal and external audits are set up to assess the level of accomplishment of the global HR standards at the country level.
At the country level, HR policies and contracts all comply with specific country labor requirements and include provisions addressing equal opportunities, freedom of association, child and forced labor, remuneration and working hours, leave, and employee benefits. The implementation of these policies is overseen by an HR team at the country level, headed by an HR manager. The HR unit also includes at least one HR administrative officer. All policies and procedures will be included in an HR handbook and will be applied to all countries of operations. (ESAP #3).
Non-discrimination and Equal Opportunities: The Global HR Policy does not condone any form of discrimination based on race, religion, gender, origin, age, disability, or nationality. The policy is applicable during hiring, compensation, promotion, termination, and retirement. The Group also has an Anti-Harassment Policy, which promotes a zero-tolerance approach to any form of harassment, abuse, or bullying, including sexual harassment. The policy provides a detailed description of the process for reporting and addressing incidents of sexual harassment. A dedicated mechanism, such as a committee and the use of Discrimination and Harassment Counsellors (DHCs), is in place for effective prevention and resolution. The Group reaffirmed its commitment to gender equality and enhancement at the workplace through a Gender Equality Plan (GEP), which establishes a series of initiatives and KPIs to increase women’s participation in the workplace. As a result of ESAP #2, for all projects where ME acts as a contractor, a GBVH risk Assessment and Preventive Action procedure will be developed to address risks during construction and operations.
Working Conditions and Terms of Employment: The Global HR policy provides guidelines on recruitment, compensation, labor relation, annual performance, promotion, flexible work, and disciplinary policies. In each country, ME develops country- specific HR policies aligned with relevant national and ILO labor requirements, including prohibitions against sexual harassment and child labor. The current policy only applies to its direct workers, and there is no formal process for monitoring subcontractors’ employment practices.
ME currently uses a considerable number of subcontractors for the provision of services, including those related to private security, trucking, and camp services. Apart from private security forces, the majority of contracted workers are hired through registered workforce providers and labor broker. Country level HR administrators keep a database of registered labor service providers and brokers who signed a Code of Conduct, with provisions against the collection of fees and document retention. ME does not currently assess the E&S capacity of these third-party providers before contracting their services and no verification is performed on terms of employment, application of minimum wages, issuance of pay slips, maximum overtime of third-party workers.
ME will develop a Workforce Management Procedure, including (i) specific provisions in contacts for the recruitment and demobilization of direct, subcontractors and third-party workers; (ii) measures to screen, audit and monitor the E&S capacity of sub-contractors and services providers; (iii) where applicable, developing requirements for accommodations in line with the IFC/ EBRD guidance note; (iv) provision for PPE for all workers; (v) issuance of an HR handbook to workers; (v) training and monitoring plan, including a schedule for audits; (vi) workers grievance mechanism, ensuring confidential reporting and effective grievance management, managed by trained personnel and accessible to all direct, indirect and third party employees. (ESAP #4).
Grievance Management: Workers can communicate and submit complaints (i) at the local level via ad hoc email, telephone number, or social media; and (ii) at the corporate level via an established procedure in the Integrity and Compliance Procedure. A Whistleblowing Management Procedure, open to all key stakeholders, guarantees confidentiality, anonymity, and non-retaliation across the organization. ME will combine the above-mentioned procedures and plan Employee Complaint Management Mechanism (ECMM), whereby concerns can be and managed. The ECMM will also include a series of training and refresher sessions to inform workers and will be applicable to subcontractors and third-party workers (ESAP #5).
Occupational Health and Safety: The Golden Rules set the framework for the OHS management system at the corporate level to be cascaded down to country operations. ME has a procedure to record, classify, and process accidents and incidents (near misses) for its corporate and global operations, which is extended in some instances to its subcontractors. Similarly, a formal and systematic approach for identifying hazards and risks is in place, as well as a Permit to Work system.
The use of personal protective equipment and collective protection measures was observed at the visited sites. There are health facilities on-sites with a full-time nurse and doctor. All staff, including subcontractors, undergo pre-employment examinations, annual fitness- to- work training, and other health promotion activities. Recently, ME broadened the scope of its health promotion activities to include mental health issues. In each country of operation, the SHEQ unit monitors lost time, first-aid incidents, accidents and near misses. Incidents are categorized and reported to the corporate SHEQ department for assessment and follow up. Creation of OHS committees is linked to Sponsor’s requirements and OHS performance of contractors and service providers is not constantly recorded.
Over the last three years, ME has experienced 20 fatalities, the vast majority occurring in African projects with low E&S oversight from the asset owner. An Independent Safety Investigation Committee, led by the SHEQ function and including the participation of various departments, was established to investigate root causes and identify corrective actions. Root causes included the insufficient implementation of hazard identification processes on-site and unsafe driving practices.
ME will engage a qualified OHS consulting firm to undertake a comprehensive and detailed OHS audit, focusing on existing projects where ME is engaged as a contractor. The audit will assess the effective level of implementation of the Golden Rules, define roles and responsibilities, and evaluate measures to address the asset owner’s E&S performance in line with PS2, including hazard identification, correct and safe use of equipment, and control measures. Time bound corrective actions will be agreed and implemented where necessary, including additional resources for the management of the risks and monitoring (ESAP #6).
The audit will also serve as the basis upon which ME will enhance its own corporate OHS management system and site-specific procedures, including updated Golden Rules, a Group OHS management plan, a permit to work system, and incident management and investigation. A specific focus will also target the duration and quality of the training provided by certified professionals in charge of the training delivery. Going forward, the updated OHS system will apply to all projects where ME is engaged as a contractor, be applicable to all subcontractors, and be aligned with PS requirements and WBG EHS guidelines (ESAP #6).
PS3 Resource Efficiency and Pollution Prevention
ME has a centralized indicator reporting platform, known as Cority, to collect and report environmental data, including GHG emissions from all its projects. The carbonic intensity in 2023 was 0.8t CO2e for Scopes 1, 2, and 3, resulting in a 28% reduction compared to 2022. The Group has an action plan for decarbonization with several energy efficiency initiatives, such as LED lighting upgrades in camps, and plans to install and use of solar energy at some project sites to reduce GHG emissions.
The main sources of dust and particulate matter are from transportation activities along the access roads and the on-site storage of spoil. Access roads to camps or yards are regularly watered to control dust. Air quality monitoring is conducted by a third- party -licensed contractor at various points along the main transportation routes and at sensitive receptors within the communities.
ME generated a total of 657,492 tons of solid waste in 2023, of which 73% was recycled. The waste is usually segregated on-site, collected and disposed either by the Sponsor or through an identified licensed contractor. For some projects in remote areas, the waste may be stored in a warehouse until a contractor and a viable solution are found. The Group is currently developing a corporate initiative to promote circularity by identifying ways of waste avoidance, and enhance recycling/reuse (objective: zero waste target at project sites) (ESAP #1).
ME’s total water consumption for 2023 was 8,385,798 m³ mainly used for dust suppression, preparation of surface layers during construction, and camp operations. The Group’s Construction Site Yard manual includes a series of measures and initiatives to minimize, promote, and ensure a more efficient use of water in line with the industry best practices. As part of its circularity initiative, ME is piloting projects for wastewater recycling and reuse, as was observed at wash- down areas of batching plants.
Wastewater is characterized by effluents from wastewater treatment plants, stormwater, and wash water from process equipment cleaning. The wastewater from these processes is collected in tanks and transported to offsite treatment plants by licensed contractors.
As per ESAP #2, where risks related to air emissions, solid and hazardous waste, and wastewater have been identified, ME will prepare and implement site-specific procedures on (i) waste management; (ii) pollution prevention; and (iii) hazardous material management consistent with local requirements and the WBG General EHS guidelines. ME will set up a training programs for the implementation of these procedures, including for both direct and indirect workforce members.
PS4 Community Health, Safety, and Security
The proximity of the communities to the construction sites could expose them to potential health, noise, and safety risks, including those associated with emissions (dust and particulate matter) and road safety. As per ESAP #2, where ME identifies risks associated with the community health and safety, associated impacts will be managed through an -hoc community safety plan.
More than 450 mining machineries and vehicles (including heavy trucks, excavators and cranes) will be deployed on site. All logistics, driver management, and trainings are managed by the Operations manager at the project level. Drivers include both direct ME staff and those recruited by licensed brokers. Most of the equipment have an in-vehicle monitoring system (IVMS) and all trucks have real-time GPS tracking. The use of Journey Management Plans for trucks and vehicle transport on site varies based on the Sponsor requirements.
ME will undertake a full review of road traffic practice, incidents and fatalities, including (i) a comprehensive assessment of the approach to journey management; (ii) a complete assessment of driver and worker/workers competency and training; (iii) a review of the risk assessment of transport routes; (iv) corrective actions based on the findings, including an enhanced training program; and (v) leading and lagging indicators. The review will form the basis for developing and implementing a driving and equipment use programs for all its activities, that will include driver safety/ equipment use training, vehicle checks, safe loading practices among others (ESAP #7).
ME primarily uses private security guards, provided by third-party contractors, to control access and protect equipment in the laydown areas and construction yards. A Senior Security Officer and security guards are employed generally in shifts and are monitored by ME’s contracted security manager. Depending on the security scenario, public armed security provides additional support to the asset protection on site. One security fatality and five incidents involving security forces have been reported in the last two years, that prompted a revision of the Corporate Security Plan which is currently underway.
Going forward, ME will undertake a risk assessment for all its operations that will form the basis for developing a Corporate Security Plan. This would include (i) guidelines for guards’ selections; (ii) rules of engagements – including the use of minimum force; (iii) enhanced training including on the UN Voluntary Principles on Security and Human Rights; (iv) ways to monitor the implementation at operations level; (v) engagement practices with surrounding communities and (vi) grievance management. The implementation of the Plan will be performed by a professional security director at corporate level (ESAP #1).
