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 1 - Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment and Management System
The LPG project will be implemented by SERIOM through the co-borrowers. The company has an integrated corporate Environmental Health Safety and Security management system (EHSS MS) applicable to group-wide downstream operations with policies, plans and procedures that are aligned with IFC PSs requirements. The integrated EHSS MS is certified to ISO 9001:2015, ISO 14001:2015, and ISO 45001:2018 standards. SERIOM and co-borrowers will develop a site-specific HSSE management system for each facility to identify and manage EHS risks and impacts associated with LPG bulk storage and loading through compliance with applicable national standards and E&S regulatory permits and requirements (ESAP#1). The EHSS MS will adopt relevant sections of the corporate HSSE management system and will be aligned to IFC PS1.
Policies
The group has an HSE policy which (i) defines environmental and social objectives and principles; (ii) complies with applicable laws and regulations and internationally recognised standards; and (iii) is approved and signed by management to demonstrate leadership support and endorsement. As part of the EHSS MS, the HSE policy will be revised to include the new LPG project requirements and indicate responsible parties for its execution (ESAP#2).
Identification of Risks and Impacts
Nigeria – LPG Storage Facility: The Environmental Impact Assessment (EIA), aligned with national regulations, has been submitted to the Federal Ministry of Environment for review and approval and to obtain the EIA Certificate of Conformity. The EIA includes baseline data, risk and cumulative impact identification, mitigation measures, and a stakeholder engagement framework. Consultations were conducted by Lagos State during resettlement and compensation. As included in ESAP#3, SERIOM and the SPV will develop a HAZOP procedure and risk register for construction and operation phases and conduct a Quantitative Risk Assessment (QRA) prior to construction (ESAP #3). Risk and impact assessment will also address OHS, LFS, labor conditions, third-party workers, and community health and safety, in line with national and IFC Performance Standards.
Ghana – LPG Facility at Kpone: EIA has been completed, approved by the national regulator and Fire Department and construction has commenced. As part of ESAP #4, a comprehensive HAZOP and QRA study (already underway) and will be finalized before commercial operations.
Kenya – KPC LPG Tanks and Pipeline: Preliminary ESIA was conducted for 18 bullet mounded LPG tanks and a gas pipeline through KPC’s wayleave. The ESIA identifies construction risks, mitigation measures, and recommends plans for both phases. SERIOM and the relevant co-borrower will review and update the ESIA in line with the final project design and proposed operational structure for managing the project phases and obtain required license and permits before commencement of construction and operation activities (ESAP #5). SERIOM will also commission HAZOP, HAZID and QRA for the pipeline and the storage facilities and implement mitigation plans.
Tanzania – LPG Facility in Dar es Salaam: Two ESIA studies have been completed for sites at Plot 34 and Plot 32 in Vijibweni Industrial Area. Phase 1 includes a pipeline from Kigamboni Oil Jetty and a 5,300 MT LPG tank; future phases will expand capacity to 10,000 MT. Construction and operations risks and mitigation measures have been identified. SERIOM and the relevant co-borrower will review the studies and conduct HAZOP and QRA for the pipeline and the storage facilities and implement mitigation plans (ESAP #6).
Management Programmes
During construction, each project will prepare and implement a construction-phase Environmental and Social Management Plan (ESMP) (ESAP #7) addressing site works, pollution control, waste and hazardous materials management, labor and contractor oversight, and emergency preparedness. The ESMP will also include monitoring, reporting, and compliance requirements for contractors and sub-contractors.
SERIOM has developed a corporate HSE plan, code of conduct and ethics, security policy and an emergency response plan as part of its overarching EHSMS/ESMS. For the operations phase, SERIOM and each co-borrower will adapt and implement site specific EHSMS as part of ESAP#1, with the following plans and procedures at a minimum: identification and assessment of E&S risks and impacts; HAZOP procedures and a risk register; a comprehensive Process Safety Management (PSM) plan (covering all the PSM elements according to good international industry practice); E&S management plans (also covering the ones that relate to EIA findings) and procedures on energy, water, waste and pollution management; life & fire safety (LFS) provisions; stakeholder engagement and community grievance mechanism; hazardous material management plan; a legal register / permitting plan to track all licenses and permits; security management plan; contractor management plan; supplier code of conduct and supply chain due diligence; incident investigation and reporting procedures and E&S / OHS monitoring, including key performance indicators (KPIs).
Organizational Capacity and Competency
There is a centralized, dedicated team overseeing the HSE practices at corporate and subsidiary levels of the Group, headed by QHSSE Manager, responsible for OHS / E&S matters of the projects and supervises QHSSE officers at the company facilities. The company’s Government & Community Relations Manager is responsible for maintaining environmental, regulatory licenses and permits, managing external communications and community grievances, whereas the Risk and Compliance Manager oversees risk assessment and monitors compliance against key performances indicators (KPIs) and report to respective management teams. SERIOM and the respective co-borrowers will strengthen HSE implementation and monitoring capacity by appointing dedicated HSE officers at each LPG terminal with clear roles and responsibilities, to coordinate the HSE activities at each site and support the implementation of the site specific ESMS during construction and operation (ESAP#8).
Emergency Preparedness and Response
The company has a basic corporate emergency preparedness and response plan (EPRP) which covers several potential emergencies, e.g. medical emergencies, chemical/fuel spills, pipeline rupture, and security emergencies. SERIOM will update its corporate emergency preparedness and response plan and together with the co-borrowers develop site specific EPRPs including designated response actions for accidental gas release and explosions, coordination with neighboring facilities and communities that may be potentially impacted by site emergencies such as gas leaks / chemical spills and through conduct of emergency drills for various scenarios (ESAP#9).
Monitoring and Review
During construction, SERIOM and the selected contractor will implement the monitoring and reporting program outlined in the construction ESMPs. As per ESAP #10, prior to the commissioning and start of commercial operations, SERIOM and the respective co-borrower will engage an independent process safety expert to undertake an operational readiness review of the process safety management arrangements for each terminal. The company will develop and implement procedures for annual third-party process safety and HSE audits. The analysis of information from the monitoring and audit programs will inform the periodic management system review process to assess efficacy of the EHSS MS and identify measures to further strengthen the system. A comprehensive monitoring program for the operational phase will be established as part of the terminal’s EHSS MS to comply with regulatory monitoring requirements, IFC’s PS’s and applicable WBG EHS Guidelines. This program will consider the identified risks and impacts, and information requirements of key stakeholders and affected community.
PS 2 – Labor and Working Conditions
Human Resources Policies and Procedures: SERIOM has corporate HR policies and procedures, corporate code of conduct and ethics, diversity equity & inclusion Policy, equal opportunity fair treatment policy which includes principles against child/forced labour, non-discrimination and equal opportunity, sexual exploitation abuse and harassment. Going forward, SERIOM and each co-borrower will develop site-specific employee handbook aligned with respective host country legislation and IFC PS2 requirements covering entitlement to, and payment of, salaries; entitlement to leave for holidays, vacation, illness, injury, maternity, and other reasons; freedom of association and collective bargaining; entitlement to benefits; retrenchment; and disciplinary practices (ESAP #11). The HR policies and procedures will be communicated to all workers including third party contracted workers during onboarding and as a part of regular training.
Working Conditions and Terms of Employment: SERIOM’s form of employee contract is detailed but unclear on performance benchmarks, focusing on termination conditions without specifying benefits. A typical employee contract refers to the company’s HR policies and procedures. For this project, employee contracts shall be elaborated to include provisions for: health insurance and have statutory social security deductions and other HR information such as start date, working hours, renumeration, leave, benefits, and employee rights and obligations, terms and conditions of employment as applicable to respective host country legal requirements including wage regulations and IFC PS2 requirements (ESAP #12).
Workers’ Organizations: As per ESAP #11, SERIOM and the co-borrowers will include explicit reference on freedom of association in the corporate and site-specific HR policies and clearly state zero tolerance for any retaliation on account of participating in union/freedom of association related activities. Awareness training will be carried out for all employees on this aspect.
Grievance Management: There is a corporate grievance procedure and whistleblowing policy, which defines timelines for action, but it does not include a mechanism for anonymous submission of complaints. As part of ESAP #13, SERIOM will update its grievance mechanism aligned with IFC PS and ensure that each co-borrower adapts the mechanism for their operations. This update will include provisions for addressing sexual exploitation and harassment (SEAH) cases, allow confidential and anonymous reporting, include an anti-retaliation statement, extend coverage to workers employed by third parties, and establish a system to log, track, and report grievances and their status. The grievance mechanism will cover all categories of workforce (direct and indirect employees/workers).
Occupational Health and Safety: As noted above SERIOM has a corporate HSE plan and procedure with provisions for the QHSSE team to carry out periodic HSE and risk assessment reports, daily walkthroughs, job safety analysis (JSA), toolbox talks for contractors and employees alike as well as the use of a permit-to-work (PTW) system. This plan provides both leading and lagging indicators. There is no centralized incidents/accidents register at the corporate level. However, incidents are investigated and reported despite the absence of a documented incident investigation and reporting procedure. As per ESAP #14, SERIOM will develop and implement a corporate and site-specific procedure for incident investigation and reporting. Further as per ESAP #15 a HSE plan for each site will be developed and implemented to include hazard identification and risk assessment covering both construction and operations phases of the project. The HSE plan will include L&FS, PSM, crisis management, electrical safety, implementation of heat stress management protocols, provision of drinking water to workers, alternative work schedules during high temperatures, and the provision of shaded/cooled breaks and training for all workers. SERIOM and the respective co-borrowers will constitute an HSE committee, according to relevant local law, at each site which will meet regularly to discuss health and safety matters. Additionally, as per ESAP#16, SERIOM and the co-borrowers will develop and implement a clearly defined OHS training program to include evaluation of training effectiveness and competency-based assessment for safety critical roles for both employees and contractors. OHS components will be included in all site-specific initial onboarding and refresher trainings.
Third party workers and Sub-Contractor Management: For the construction phase, SERIOM and the co-borrowers will engage contractors. SERIOM will develop and implement a contractor management manual, in line with IFC PSs, applicable to all contractors working on construction, operation and maintenance activities of the project, and maintain oversight on contractors’ performance (ESAP #17). The contractor management manual will include clauses on commitment to compliance with labour and HSE standards aligned to SERIOM policies, the right for SERIOM and the respective co-borrowers to audit the contractor’s labour practices and set up regular meetings with contractors to review EHS performance as well as labour aspects, discuss non-compliance issues and promptly address them with corrective actions.
SERIOM and the respective co-borrowers will undertake due diligence audits on contractors to check their compliance with host country labour law, IFC PS2 and the company Procurement Policy, and document improvement and corrective actions in contractual agreements and corrective action plans / statements per audit findings as appropriate. The audits will, as a minimum, cover identified risks in third party policies and procedures under working terms & conditions, staff induction and sensitization on workers’ rights, freedom of association and worker’s representation, non-discrimination and equal opportunity, grievance mechanisms, harassment and sexual harassment in the workplace, code of ethics/conduct and disciplinary measures, occupational health and safety, mechanisms for protections against unlawful child labor and mechanisms for prevention of forced labor. SERIOM and the co-borrowers will extend its grievance mechanism to contractor and third-party workers allowing these employees to report any grievances anonymously (ESAP #18).
Supply Chain: As part of ESAP #1 SERIOM and the co-borrowers will establish a supplier code of conduct articulating its commitment to prohibit forced, or child labour, SEAH and significant occupational health and safety risks; and a procedure to assess supply chain EHS risks applicable to the project. SERIOM will monitor its primary supply chain on an ongoing basis during operations and if new risks or incidents of SEAH child and/or forced labour are identified, SERIOM will work with the supplier to develop procedures to prevent and remedy such practices including termination of contracts if risks are not adequately addressed within an agreed period.
PS 3 Resource Efficiency and Pollution Prevention
Resource Efficiency: SERIOM and the co-borrowers activities will focus on LPG import, storage and filling trucks for offtakers. Resource consumption is limited to water (approximately 2000 litres per day during construction and 1000 litres per day during operation – per site. Electricity will be supplied from the national grid or backup generators at each location should the grid supply be interrupted. Water at each site will be supplied by the local water company or boreholes on site. Firewater for the terminals shall be sourced from seawater for facilities adjacent to the sea.
Greenhouse Gas Emissions: The Project aligns with Nationally Determined Contributions (NDCs) of Nigeria, Kenya, Tanzania, and Ghana by promoting LPG as a cleaner-burning fuel that reduces greenhouse gas (GHG) emissions and indoor air pollution. By providing an alternative to kerosene, wood and charcoal, the project improves energy access for underserved populations, advancing sustainable development goals and addressing key priorities under the Paris Agreement. As part of ESAP #1, SERIOM will define a GHG monitoring and reporting protocol covering both scope 1 and 2 emissions, as per the requirements of the internationally recognized methodologies and good practice.
Pollution Prevention: SERIOM corporate procedure covers monitoring of air emissions (SOX, volatile organic compounds (VOC) and particulate matter) and effluents from oil/water separators. The construction phase involves the construction of site facilities such as truck loading gantry, access roads on site, office buildings, as well as facilities for water supply and drainage, and fire-fighting facilities. The main pollution sources consist of mechanical noise, dust, wastewater and solid waste. Ambient air pollution by construction activities include dust from surface levelling at the construction site, movements of trucks and other vehicles, (un)loading of construction materials, earthwork and temporary piling of spoils. Engineering dust may increase Particular Matter (PM) content in the air around the project site and may also be transported to neighboring areas by wind, thus affecting livelihood and working of employees of adjacent entities. These issues will be managed via implementation of the contractor’s ESMP as will other aspects such as water pollution (via installation of sediment traps to reduce sediment in runoff generated during land clearing/filling), solid and liquid waste management. The operational phase of the project is expected to include air emissions, noise, waste and wastewater and will be managed via the operational EHSS MS.
Wastewater: During construction, the contractor at each site will assess the suitability of use and integrity of the septic tanks or mobile toilets for workers and thereafter deactivate the facilities after construction is completed. Cleaning of the septic tanks and the collection of the sludge retained shall be the responsibility of a licensed operators for this purpose and shall be cleaned when necessary; this requirement will be defined in each site ESMP. For operations, SERIOM and each co-borrower will install an on-site effluent treatment plant (ETP) for terminal operations and truck parking sites to ensure treatment of wastewater as per local standards and WBG EHS Guidelines (ESAP #19). Regular monitoring of the discharge will be undertaken as to be defined in the EHSMS.
Waste Management: During normal operation and maintenance of the LPG terminals, no residues are expected to be produced which will require disposal. Solid wastes produced during the operation of the terminals are expected to be generally domestic in nature with minimal industrial waste. The waste is likely to comprise plastic wrappings, food waste, paper, cardboards, miscellaneous workshop and office waste. Such waste will be limited and be stored in on-site waste bins for collection and disposal through accredited waste recycling and disposal companies and management thereof will be defined in the EHSMS.
Hazardous Materials Management: SERIOM operations involve hazardous chemicals such as petroleum naphtha, degreasers, and quaternary ammonium compounds. Although safe practices are followed, there are no documented procedures for chemical management. As per ESAP#1 and as part of ESMS improvement, SERIOM and the co-borrowers will develop specific procedures and work instructions for managing hazardous materials including storage, handling and use of the chemicals as well as response to chemical and hydrocarbon spills. Training on these procedures will be provided to all employees at all facilities during the workers’ induction session and on regular basis thereafter.
PS4 Community Health, Safety, and Security
The LPG facility in Ghana is located in a heavy industrial zone hosting other oil and gas installations. No residential area or no natural/historically protected areas are found around the facility. In Kenya and Tanzania, the project sites are located within the industrial zones for oil and gas installations. Although the facility in Nigeria is located in a heavy industrial zone, there are some communities within a few hundred meters of the facility. A HAZOP study for Nigeria Plant has been conducted, identifying all credible process hazards and operability issues for the LPG terminal, including storage, transfer, blending, and loading systems. The study applied systematic risk ranking (severity and likelihood) to prioritize hazards and ensure risks are reduced to ALARP (As Low As Reasonably Practicable). The QRA study for Nigeria is under development as per ESAP #3. The HAZOP and QRA studies for Ghana, Kenya and Tanzania will be conducted in line with each host country requirements and international standards and completed prior to construction with required mitigations implemented as per ESAP #4, #5 and #6.
Infrastructure and Equipment Design and Safety: The HAZOP study and facility design for Nigeria comply with Nigerian Midstream and Downstream Petroleum Regulatory Authority (NMDPRA) and international standards - BS EN IEC 61882, ISO 17776. The conceptual design includes a number of instrumented systems which shall provide real time process and operational status monitoring and information including control and safeguarding functions. As per ESAP #20, SERIOM and respective co-borrowers will install, operate and maintain an integrated safety instrumented system of appropriate reliability and integrity to avoid delays in mitigating the risks associated with major accident events. These shall include, but not limited to, fire and gas detection system, audible alarms, automated emergency shutdown systems and firefighting systems. The systems shall be complemented by SERIOM establishing a functional safety management plan covering each stage of the functional safety lifecycle for safety instrumented systems and related safety functions as well as defining and implementing both on-site and off-site emergency response plans, including communicating and delivering trainings on emergency response measures to its employees, third-party truck drivers and the communities neighboring the facilities.
The facilities designs also includes measures to prevent loss of containment, such as robust piping, rated hoses, and containment systems to minimize environmental impact. Vapour handling and recovery systems minimize emissions and reduce the risk of vapour cloud formation, protecting both the environment and surrounding communities. Firewater systems are designed for emergency response, and the facilities are designed for rapid isolation and evacuation if needed. As per respective ESAP #3, 4, 5 and 6, all HAZOP recommendations for each facility will be tracked in an action register, with responsible parties assigned to ensure timely close-out and continuous improvement. In addition, the Safety Integrity Level and QRA studies will be completed as part of the detailed engineering designs. As per ESAP #21, SERIOM and respective co-borrowers will develop and implement detailed operational readiness and process start-up programs prior to commissioning and before start of operations phase.
Traffic Management: LPG imports will be managed through SERIOM’s dedicated fleet of LPG vessels, ensuring control over logistics, product integrity, and timely delivery. Operations will be carried out in line with each host country regulations. Distribution of LPG from each of the storage facility will be handled by third-party transporters owned and operated by the customers. The Ghana and Tanzania sites include dedicated truck parking facilities to avoid congestion and roadside parking around the depot. As per ESAP #22, SERIOM and the co-borrowers will develop and implement a traffic management plan for each site. As part of the plan, each co-borrower will implement dispatch schedules to avoid peak congestion, and access control measures requiring drivers to show their driver’s license for verification before entering the depots. The vehicles’ roadworthiness certificate will also be presented for verification with physical inspection carried out.
Security Personnel: Security at the project sites is provided by unarmed third-party licensed security agencies. SERIOM has no chief security officer / manager to supervise the security personnel.. As per ESAP #23, SEROM and the co-borrowers will conduct security risk assessments for each site and develop security management plans that align with IFC PS. Each site plan will incorporate a clear protocol with due diligence in hiring, and training processes for security personnel. Additionally, SERIOM and the co-borrowers will provide site security personnel training on the UN Voluntary Principles on Security and Human Rights, including SEAH; life and fire safety emergency training; and engagement practices with surrounding communities. SERIOM and the co-borrowers will also provide a community and staff grievance mechanism commensurate with the level of risk identified during the security assessment, to handle complaints on the acts of security personnel undertaken on company premises or on behalf of the company.
