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
E&S Policy and management systems. WeLight has a documented E&S policy which outlines the company’s commitments to comply with applicable laws and regulations and international environmental and labor standards; to respect the right of communities and enhance rural development through the promotion of renewable energy, among others. Additional E&S policies and procedures have been developed at a corporate level to complement the E&S policy including occupational health and safety (OHS) policy; supply chain management policy and supplier code of ethics (described in detail in PS2); HR policies and procedures; stakeholder engagement procedure and land acquisition and resettlement procedure. These policies and procedures are broadly consistent with the requirements of PS1, except for the areas of enhancement outlined in the following sections. WeLight has a documented corporate ESMS which is then adapted to the context of the countries of operations. The ESMS is aligned with IFC PSs and includes the E&S policy, an exclusion list as per the European Investment Bank (EIB) requirements, measures to perform early E&S screening on the proposed sites; E&S categorization and appropriate E&S management programs; organizational capacity; emergency and preparedness response plans (EPRPs); and stakeholder engagement and grievance management plans. As part of IFC’s investment, the client shall strengthen the corporate ESMS including: (i) preparation of E&S management plans (ESMPs) before construction; (ii) site-specific EPRPs; (iii) relevant stakeholder engagement over community health and safety risks ; (iv) E&S risk screening identification procedure and (iv) monitoring and review framework. Going forward, WeLight will update its corporate ESMS and roll it out across all new projects in countries of operations. Site-specific environmental and social measures will be implemented to address issues identified during the E&S site screening, in line with local laws, IFC PSs and applicable WBG guidelines (ESAP #1).
Identification of Risks & Impacts and Management Programs: The corporate ESMS incorporates a risk management process that includes the pre-screening of the proposed sites against an E&S checklist and an exclusion list. The risk management process screens out, among others, any risks related to forced and child labor, illegal activities and impact in areas of natural habitats. The screening outcomes inform the E&S categorization in line with the host country process and the level of environmental and social due diligence (ESDD) to be undertaken. The land acquisition aspects are further discussed under the PS5 section. Following this phase, WeLight prepares the required E&S assessments and mitigation plans in accordance with national regulatory requirements—such as the Programme d’Engagement Environnemental in Madagascar and the Plan de Gestion Environnemental et Social in Mali. These are completed by site-specific plans for land access and compensation, health and safety, waste management, and traffic control. Environmental licenses and construction permits are then obtained in line with applicable national procedures. As part of the ESMS enhancement, WeLight will develop a compliance monitoring tool to systematically track the status of environmental permits and land agreements across all current and future sites (ESAP #1).
The current E&S risk identification procedure presents limitations with regards to screening of risks and impacts in line with IFC PSs 5 to 8. WeLight will enhance its E&S screening tool to include: (a) contextual risk screening; (b) a risk categorization aligned with the IFC Performance Standards; (c) specific criteria under PS5 to assess land access and economic-related dependencies on land ; and (d) a checklist to screen out risks associated with IFC PS 6 to 8. Based on the results of the revised E&S screening tool, site-specific ESMPs will be developed and adapted to any site-specific E&S issues (cf. ESAP #1). WeLight contractually requires its contractors to follow the company’s environmental, social, health and safety terms and conditions, including the submission of an E&S report prior to Project final handover. The report summarizes the key E&S indicators, such as the number of employees, grievances, waste, and resource consumption, during the construction phase. As per ESAP #1, WeLight will ensure that the E&S management plans are shared and implemented by contractors prior to the beginning of any future construction activity. E&S indicators will be updated to be monitored in the final E&S report.
Organizational Capacity: Currently, WeLight has two E&S Coordinators, one based in Mali and one in Madagascar, in charge of E&S implementation and monitoring and reporting to a country manager. The E&S coordinator in Madagascar also holds responsibility for ensuring corporate E&S alignment across operations, and is supported by an environmental, health and safety (EHS) intern and a community relations officer. The E&S performance is reviewed at the board level on a monthly basis, and corrective actions are implemented, as needed. As part of the expansion into new countries, WeLight will appoint a new Corporate E&S Manager to strengthen the alignment of country-level E&S processes with corporate policies and international standards (ESAP #2).
At the site level, operations are supervised by a Regional Site Manager, along with technical and commercial officers. To support its ongoing expansion, WeLight will: (a) strengthen its E&S team by hiring one E&S Coordinator in each new country of operation with at least 5 sites in a pilot phase and/or operation; and (b) require EPC contractors to appoint an EHS officer for each phase under development (ESAP #2). Each E&S Coordinator will be responsible for monitoring environmental and OHS compliance and conducting inspections/audits during both construction and operations. They will also provide EHS training to operational staff and serve as the primary liaison between the company and surrounding communities. WeLight will assess the need for additional human and E&S resources and mobilize new personnel as required, in line with its evolving operational needs (ESAP #2).
Emergency Preparedness and Response: WeLight has developed a comprehensive corporate EPRP to address emergency situations, such as electrocution, collapse of poles or panels, fires, and other incidents that may affect workers and nearby communities. First aid and emergency response training are provided for all employees, with approximately 20% of corporate staff trained as first responders. In Madagascar, on-site emergency preparedness measures observed included safety cards, clearly marked muster points, installed fire extinguishers, and regular toolbox talks covering EHS topics. In Mali, it was noted that the corporate EPRP is not translated into plans to address site-specific risks such as sandstorms or extreme heat. As per ESAP #1, the EPRP will be further enhanced to include specific emergency scenarios linked to extreme weather and other climate-related events—such as recurring hurricanes and cyclones in Madagascar, and sandstorms, in Mali. In line with the site-specific ESMPs, all construction workers will be trained in emergency response protocols through drills and classroom sessions prior to the construction phase. Furthermore, the Company will ensure that emergency protocols are disclosed to communities in a simplified and accessible format and that these are harmonized with the contractor’s emergency preparedness and response plans (EPRPs) (cf. ESAP #6).
Monitoring and Review: In Madagascar, the E&S team conducts regular internal audits and site inspections during construction and operation as per the E&S monitoring procedure in place. Key Performance Indicators (KPIs) are established as part of the E&S management plans, tracked on a monthly basis and consolidated in a reported produced on a quarterly basis to ensure alignment with the company’s corporate E&S management programs. The KPIs are periodically reviewed by the respective managers and are reviewed at least once a year by a team composed of the chief executive director, the members of the E&S committee and the E&S Coordinators. The E&S performance is reviewed monthly at the board level and further discussed during quarterly business reviews, and corrective actions are implemented, as needed. WeLight will enhance its monitoring procedure to document any instances of non-compliance with the IFC PSs and its corporate ESMPs, assign clear responsibilities for their resolution and to confirm their resolution. The corporate risk register will also be reviewed as needed, and routinely presented to the Board (ESAP #3). In line with ESAP #1, WeLight will enhance its existing supply chain management system (SCMS) by developing a procedure to map and assess risks throughout the solar supply chain, including up to the polysilicon supplier level. The existing SCMS will be extended to apply to primary suppliers. EPC contractors sourcing solar PV modules will be required to provide evidence that these standards are effectively cascaded throughout their supply chain and WeLight will contractually reserve the right to disengage from EPC contractors or main suppliers that fail to meet these requirements.
PS2- Labor and working conditions
WeLight currently employs 101 staff (33 of whom are women) at its corporate offices in Madagascar, and 11 staff (5 women) at its corporate offices in Mali. Approximately 356 additional workers are outsourced to fill positions at site/clusters of sites level such as technical and commercial agents.
HR policies and procedures: The company has developed an HR Manual consistent with the requirements of PS2, tailored to each host country context. The Manual outlines key policies and procedures related to recruitment, performance management, working conditions (including overtime), prohibition of child labor and forced labor, gender equality, anti-corruption, sexual harassment, OHS, internal grievance mechanisms, freedom of association and collective bargaining, and collective dismissal. A code of conduct is also in place and is provided to all employees at the time of hiring. In all new countries of operation, an HR Manual will be developed with policies and employment terms and conditions in line with the national labor law requirements and consistent with IFC PS requirements. As part of onboarding, all employees at new sites will receive training on these policies, with refresher sessions provided as needed. (ESAP #4).
Working conditions and terms of employment: WeLight provides both open-ended and fixed-term employment contracts in accordance with the respective national labor laws. All contracts clearly outline key employment terms, including wages and overtime, annual leave entitlements, allowances, probation and notice periods and statutory deductions. For new developments, staff are recruited either on short-term or long-term contracts, based on operational needs.
WeLight’s recruitment processes are guided by principles of equal opportunity, transparency, and merit-based selection. These commitments are formalized through the company’s HR Charter and Gender Equity Policy, which include measurable targets for improving female representation and promoting inclusive participation in decision-making roles. To enhance local benefits, WeLight prioritizes local hiring for construction (through the EPC) and for operation activities. In Mali, HR and recruitment responsibilities are managed by the operational coordinator, as the core HR team is based in Madagascar. To strengthen oversight and ensure consistent implementation of labor-related policies, WeLight will recruit dedicated human resource professional responsible, among others, for labor management and grievance resolution. For future operations in new countries, HR staffing will be tailored based on the scale and maturity of the activities. (ESAP#4).
Worker grievance mechanism: WeLight’s HR Manual includes an internal grievance mechanism that provides channels for raising concerns, with a commitment to protect workers against retaliation and discrimination. Several anonymous reporting options (such as grievance boxes around the sites) are available and managed confidentially by the HR department. Ad hoc training on the grievance mechanism is provided to corporate staff. As part of IFC’s investment, awareness among employees will be expanded in parallel with the establishment of dedicated in-country HR teams, as outlined in ESAP #5. WeLight will strengthen its grievance mechanism by establishing a confidential reporting channel for Gender Based Violence and Harassment (GBVH) related complaints, enhancing training and refresher sessions for field staff on grievance procedures, and implementing a clear protocol for the investigation and resolution of GBVH cases. These enhancements will be rolled out across all existing and future mini-grid sites and to all groups of workers (direct and contracted) to ensure more effective and inclusive grievance management at the field level (ESAP #4).
Occupational Health and Safety: The main OHS risks associated with WeLight’s activities are linked to two key phases: the construction and installation phase, which is outsourced to EPC contractors, and the operational and distribution phase, which is overseen by WeLight’s Area Managers and on-site Technical Agents. WeLight has established an OHS Policy that applies to all contractors involved in mini-grid construction through their contractual obligations and are expected to assign an OHS focal point at each site or cluster of sites. Contractors operating in Madagascar are required to comply with WeLight’s EHS principles, including adherence to standard operating procedures, proper use of personal protective equipment (PPE), general safety rules during construction and installation, and mandatory reporting of accidents, incidents, and near-misses. OHS compliance is monitored on a monthly basis using a set of KPIs, overseen by the in-country E&S Coordinator and reviewed periodically by the board. In Madagascar, site inspections planning is often constrained by adverse weather conditions and logistical constraints. Since 2022, no lost-time injuries and a limited number of near misses and OHS-related accidents (including one traffic-related incident) have been recorded since the start of the construction phase in Madagascar. In both Madagascar and Mali, while use of PPE was generally observed during site visits, some deficiencies were noted, including the absence of staircases or ladders in some locations and improper disposal of construction materials.
During the O&M phase, OHS responsibilities are directly managed by the site-based technical agents. The OHS policy outlines the key hazards associated with the company’s activities and requires technical agents to perform a basic risk assessment prior to undertaking any task. The policy addresses risks related to activities such as loading and unloading, welding and cutting, working at height, exposure to heat, and housekeeping. KPIs are in place and monitored by the EHS team at the level of each country of operation. Looking ahead, and in alignment with Good International Industry Practice (GIIP) and IFC PSs, WeLight will enhance its OHS Management System (OHS-MS) to update risk assessment, mitigation and performance monitoring and review procedures to cover risks related to electrical distribution networks, road traffic, and extreme weather events. The company will also develop a community-focused environmental, health, and safety (EHS) communication strategy, with particular attention to the dangers posed by live power lines (cf. ESAP #1).
Workers engaged by third-party: WeLight currently engages two EPC contractors—Sagemcom and NEA—for the construction and operation of solar plants and rural low-voltage distribution networks. The company also manages “last-mile” customer connections. Site construction typically takes approximately four months and may extend up to six months in certain areas of Madagascar due to seasonal weather conditions and site accessibility challenges. Typically, around 20 locally sourced workers are hired by the EPC contractor for each mini-grid and transmission line site to carry out tasks such as site clearing, construction, housekeeping, and asset security. The EPC contractors’ HR policies were noted to be aligned with the labor laws and explicitly include provisions prohibiting forced and child labor. They also include commitments to maintaining a safe and healthy working environment. A Contractor Management Framework guides the selection of suppliers, defines contractual obligations, and sets out protocols related to employee working conditions. For each project, WeLight has developed dedicated Health, Safety, Security, Environmental, and Social (HSSES) procedures that are applicable to both contractors and subcontractors. Compliance is monitored through monthly reports produced by the contractors and validated by WeLight through site inspections or regular coordination meetings, and ongoing engagement with the E&S team. WeLight will also update its existing contractor management procedure to revise the E&S checklist to be used in the selection of EPC contractors, strengthening requirements related to occupational health and safety (OHS) capacity, existing procedures, track record, use of subcontractors, and supply chain management. The E&S (including labor and OHS) performance of EPC contractors will be reviewed periodically, and corrective actions will be implemented as necessary (cf. ESAP #1).
As part of ESAP #1, WeLight will enhance its contractor management system to verify the statutory compliance of all contracted workers with national labor regulations. This system will include, but not be limited to, the verification of worker identification documents at the time of hiring, review of wage payments, safety measures, and contractual arrangements. Furthermore, in line with ESAP #4, WeLight’s internal grievance mechanism will be extended to third party workers to raise concerns or complaints confidentially and without fear of retaliation .
Supply Chain: WeLight has a documented supply chain management policy that governs the general conditions of procurement—including purchasing, importing, service provision, and local sourcing—for all Tier 1 suppliers. Supplier selection is based on defined criteria, and all Tier I suppliers are required to sign a supplier code of conduct (SCC), which is annexed to their contracts. This code outlines expectations regarding business integrity, fair labor practices, including the prohibition of child labor and forced labor—and environmental responsibility. In both Madagascar and Mali, solar photovoltaic (PV) modules are sourced by engineering, procurement and construction (EPC) contractors who apply ethical pre-contractual requirements in their supplier selection processes, explicitly prohibiting child labor and forced labor. These contractors also conduct both desktop reviews and regular on-site audits to verify supplier compliance.
PS3-Resource Efficiency and Pollution Prevention
Resource Efficiency: WeLight relies on technologies to improve energy efficiency and reduce emissions throughout its operations. This involves the adoption of smart meters and remote monitoring systems for real-time tracking of energy consumption and production. The sites are connected to the national water system and water use during construction and operations is limited to domestic needs and for cleaning of panels, mainly sources from local communities with ad hoc agreements signed with the communes before accessing the sites. Due to the small size of the solar plants, the volume of water requirement for existing sites is small and do not affect community water supplies.
Greenhouse Gases (GHG): GHG emissions primarily stem from fuel combustion from the back-up generator sets. GHG emissions from the project during construction are predominantly associated with the transport of project components and on-site equipment and machinery and are expected to be less than 25,000 tons CO2 equivalent per year.
Pollution Prevention: Dust and noise are expected during construction phase and management of these aspects are addressed through the project construction ESMPs. Similar approach is expected for the sites to be developed, as aligned with PS1 requirements. Wastewater is expected to be minimal, from the washing of the panels (water only is used most of the time). Some sites include pit latrines, and their use is minimal as no personnel is permanently assigned to the sites.
Waste Management: Non-hazardous and hazardous waste generated includes construction and demolition waste, used lithium batteries and potentially damaged PV modules and electronics. The overall volumes of both types of waste generated by each mini-grid during construction and operations phases are expected to be low. WeLight has a waste management plan, and a waste register is maintained on-site, recording essential information including site, production date, type of waste, quantity, storage mode, and tracking slips for waste treated by external and licensed service providers (e.g. hazardous materials such as used oils, filters, lead acid batteries, PV panels and other electronic waste). Hazardous waste, including damaged panels, is managed by accredited third parties, ensuring traceability and regulatory compliance. It was observed that in Madagascar, lithium batteries are collected by WeLight team, transported by road and stored temporarily in a warehouse as there are no licensed e-waste disposal companies in country. No procedures to handle disposed e-waste were observed on site. In Mali, where fuel is used to operate generators during battery shortfall or outages, it was observed that fuel tanks require further enhancement such as installation of secondary containment.
As part of the ESMS update (cf. ESAP 1) WeLight will (i) expand its road safety and traffic management plan to the transport of e-waste and (ii) enhance its waste management plan by clarifying traceability and change of custody requirements, enhancing measures to address fuel contamination and developing an e-waste management procedure for collection and disposal of batteries in all existing and future countries of operations.
PS4-Community Health, Safety and Security
The construction period for each project is expected to be around four months. In Madagascar, most of the mini-grid facilities are at safety distance (from to 50 to 100 m) from residential areas. All visited sites in Madagascar and Mali were already operational at the time of the appraisal.
Community Health and Safety: Since 2022, WeLight has registered two fatalities involving community members who were electrocuted after coming into contact with the distribution lines. In response to these incidents, WeLight has intensified its safety protocols. The company has introduced enhanced inspections of electrical connections, including a second-level assessment conducted by office-based technicians using a customized mobile application. Public awareness campaigns on electrical safety have been reinforced at the village level, and additional supervision visits have been carried out to ensure strict compliance with safety procedures by both staff and community members. The company will develop a community-focused EHS communication strategy, with particular attention to the dangers posed by live power lines (cf. ESAP #1).
No worker accommodation camps exist or are expected to be established and most of the construction workers usually sourced from local communities, therefore no significant worker influx is expected. However, there can be construction related impacts due to traffic, dust and noise. WeLight has an overarching community health and safety management plan implemented during operational phase, and to avoid or minimise the impacts associated with construction, specific measures which are outlined in the construction ESMPs.
Road Safety and Traffic: The primary risk posed to the community health and safety relates to the transportation of the mini-grid components and equipment, and staff movement to and from the sites. Transportation is managed by the EPCs. In Madagascar, most of the sites visited, as part of IFC due diligence, are located in remote areas. WeLight has a traffic management plan which however does not include measures related to avoidance of dangerous routes and conditions including weather conditions, and times of day to reduce accident risk and interactions between pedestrian vehicles near sensitive areas. As part of its ESMS enhancements, WeLight will update its existing plan into a road safety and traffic management plan, aligned with PS4 requirements. Prior to the start of construction phase and during operations, WeLight will require the EPC contractors to complete traffic safety risk analysis, undertake journey management plan and implement a driver safety program, all reviewed and approved by WeLight (ESAP #5).
Security: No security personnel are assigned at the mini-grid sites as they are mostly located within the communities. The sites are fenced off with a single access point. WeLight has developed a security management plan applicable to construction and operation phases. As WeLight is considering expansion in countries which have contextual security challenges (e.g. Mali, Nigeria), prior to start of construction phase, the company will undertake a security risk assessment for all its clusters of operations and develop site-specific security management procedure, in line with IFC PS4 requirements and relevant international standards (cf. ESAP # 1).
PS5-Land Acquisition and Involuntary Resettlement
In Madagascar, WeLight establishes mini-grids on communal land owned by communities. The company follows a land acquisition and resettlement procedure (LARP), which involves screening three potential sites for each mini-grid based on environmental, social (i.e. no physical displacement allowed) and technical criteria. Key principles of the LARP are disclosed and presented to communities in the proposed sites. For mini-grid sites, three sites are identified for each location and are screened for their socio-economic criteria, involving members of the proposed villages. Once a preferred site is selected, the land is made available to the Company by the community as a result of public consultations managed by the community leader. A convention agreement is signed between WeLight and the leader of each commune including a series of community development projects and CSR activities to be delivered by WeLight to communities prior to construction and during operations. In cases where there is evidence of economic activity or economic dependence on the proposed site, WeLight ensures that sufficient time is allowed for harvesting or completing activities before beginning construction and compensation is provided to the project affected people (PAPs) aligned with PS5 requirements. In the event that local authorities cannot provide free public land, consultation would take place to identify a suitable land plot whose owner voluntarily agrees to sell and the acquisition would be finalized on a willing buyer-willing owner basis. For the low voltage transmission and distribution (T&D) lines, when electricity poles are planned to be installed in private land, WeLight will enter in negotiated agreements with private owners and compensate any crops at full replacement value. Structures are avoided as part of the screening criteria in the LARP. Encroachment risks are monitored by the technical agents during operations and awareness is created for the affected communities. The LARP does not include a process to address any past land dependencies and ownership on the existing sites. As part of its ongoing improvements outlined in ESAP #1, WeLight will strengthen its LARP by including specific screening questions on past land ownership and economic dependencies. Additionally, WeLight will update requirements and a monitoring framework for the implementation of land access and compensation plans, including measures to address post-project land restoration and use aligned with IFC PS 5.
