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:
EECL applies the sponsor’s corporate policies alongside its own E&S policies across all operations in Chile, including the projects proposed under this financing. These policies are broadly consistent with the IFC PSs and are cascaded to EECL’s contractors and subcontractors. EECL also operates an integrated management system (IMS) aligned with ISO 9001, ISO 14001, ISO 45001, and ISO 55001, which covers all of its activities in Chile. IFC’s E&S appraisal and ongoing supervision under IFC’s existing investment confirmed that the IMS is mature, fully implemented, and aligned with the IFC PSs.
EECL submitted environmental and social (E&S) project summary documents for the Tocopilla BESS, Tocopilla Synchronous Condenser, and Lile BESS projects to the Antofagasta Regional Environmental Assessment Service, seeking confirmation on whether an Environmental Impact Assessment (EIA) was required under national regulations. Based on the information provided and the responses from the regional authorities, the projects were determined not to trigger the mandatory EIA requirement. All supporting information submitted by EECL is available through the regulator’s approval platform at HYPERLINK "http://www.sea.gob.cl/" \t "_blank" www.sea.gob.cl.
In the early development phase of the BESS and synchronous condenser projects, EECL undertook an initial screening of potential risks and impacts, including climate-related risks, using its Corporate Social Responsibility (CSR) Checklist and Matrix tool, which is aligned with the EU taxonomy. EECL also developed a site-specific Matrix for the Identification and Assessment of Environmental Aspects to evaluate potential construction-phase E&S risks and impacts and is currently updating it to cover operational risks. In addition, EECL completed a series of technical studies addressing fire and explosion hazards, thermal runaway, and related risks.
As the BESS and synchronous condenser projects are fully located within existing industrial facility boundaries, construction and operational E&S risks and impacts are expected to be low, localized, and temporary, with the main issues relating to fire risk, hazardous materials management, and waste generation. Through its IMS, EECL has developed and is implementing site-specific Environmental Management Plans (EMPs) that describe how E&S impacts will be identified, avoided, minimized, and managed across the project lifecycle. The EMPs set out roles and responsibilities, mitigation measures, legal compliance obligations, and monitoring arrangements. EECL has also prepared a site-specific Matrix of E&S Legal Requirements that consolidates applicable legal obligations. Contractors are contractually required to comply with the EMP requirements.
EECL has prepared site-specific Emergency, Catastrophe, and Disaster Risk Reduction Management Plans to manage risks to workers, the environment, and local communities arising from emergency events, including battery unit fires, explosions, and climatic hazards such as climate-related extreme weather. These plans are tailored to each site and cover all phases of the projects.
EECL has corporate-level environmental and social (E&S) resources that provide project oversight and support to site teams. In addition, EECL has engaged adequate project-level E&S personnel, including environmental, community liaison, and health and safety specialists, to oversee construction and operational activities. EECL’s contractors have also appointed Health & Safety Officers to provide effective oversight of their workforce and project activities.
PS2: Labor and Working Condition:
During the construction of BESS Tocopilla and Lile BESS, the workforce peaked at approximately 186 and 233 personnel, respectively. For the Tocopilla Synchronous Condenser, peak construction staffing is expected to be around 140 workers. The workforce is predominantly composed of Chilean nationals, largely recruited from the local region. During operations, the average workforce is expected to be approximately 1 per shift at BESS Tocopilla, 1 per shift at Lile BESS, and 3 per shift at the Tocopilla Synchronous Condenser.
EECL’s Human Resources Policy and Code of Ethics are aligned with applicable local regulations and are consistent with IFC PS2 requirements and relevant ILO conventions. They address labor and working conditions, nondiscrimination, equal opportunity, equal pay for men and women, respect for freedom of association, inclusion of workers with disabilities, and the prohibition of child and forced labor.
Employees receive written contracts outlining their terms and conditions of employment and, through the induction program, are informed of the corporate policies and Code of Ethics, which are also available on the Company’s website. E&S provisions in contractor agreements require all contractors to comply with the Company’s Human Resources policies and Code of Ethics.
EECL has a workers' grievance mechanism that complies with national law and aligns with IFC PSs. It is communicated through the induction program and enables complaints to be submitted online or by phone, via unions, and through EECL’s intranet. The mechanism allows for confidential and anonymous reporting and is accessible to project contractors and subcontractors. EECL also maintains a Sexual Harassment Procedure and provides training to all managers, including those responsible for contractor audits. Allegations of sexual harassment or assault are investigated and addressed either internally, with support from external counsel where appropriate, or through the government Labor Department for investigation and resolution.
EECL has a corporate occupational health and safety (OHS) management system that is ISO 45001-certified and has developed site-specific OHS Plans and procedures, aligned with Chilean OHS and technical regulatory standards, which define project OHS obligations that are applicable to all project workers.
EECL applies a procurement policy across all projects, including the BESS and synchronous condenser projects, supported by a Supplier Code of Conduct that addresses and prohibits labor abuses such as child and forced labor. EECL also includes contractual provisions in agreements with primary suppliers requiring them, and their sub-suppliers, to comply with the Supplier Code of Conduct, which prohibits child and forced labor and sets occupational health and safety expectations for suppliers’ own operations. Where non-compliance is identified, EECL reserves the right to terminate the supplier contract. EECL also engages specialists, including external firms with supply chain audit expertise, to verify implementation and compliance with these requirements.
PS3: Resource Efficiency and Pollution Prevention:
The project is expected to deliver a net reduction of ~77,500 (BESS Tocopilla) and ~91,500 (BESS Lile) tons of carbon dioxide equivalent (CO2e) annually. During operations, minor indirect emissions are generated through the charging and discharging processes. In line with the sponsor’s corporate policies, EECL is committed to monitoring and reporting GHG emissions. Water usage during construction and operations is expected to be negligible.
Given the project’s nature and its siting within existing industrial complexes, impacts on surrounding communities are not anticipated. During construction, the project is expected to generate minor air, water, and soil pollution and produce waste volumes that can be effectively managed through standard pollution prevention and control measures set out in the project EMP(s). Routine operations are not expected to generate significant waste or emissions. The main pollution risks relate to construction and decommissioning activities, battery waste from maintenance and endoflife management, and potential accidental or emergency events. These risks will be managed through a combination of design controls, operating procedures, monitoring, and emergency response measures, as defined in the EMPs, hazardous materials handling procedures, and sitespecific Emergency, Catastrophe, and Disaster Risk Reduction Management Plans. Project waste will be managed using the existing waste management systems established for the industrial complexes.
As per ESAP#1, EECL will prepare a BESS Battery EndofLife Management and Disposal Plan that addresses decommissioning, reuse/second-life evaluation, and the identification of recycling and disposal pathways for battery modules/cells and associated hazardous waste. Given that Chile’s BESS industry is still emerging, the Plan will be reviewed and updated periodically to reflect evolving industry practices and options.