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 Policy and Management System: PriVida has developed an integrated management policy, approved in April 2024, which incorporate Quality, Health, Safety, Security, Environmental (QHSSE) stewardship, and Social Responsibility into its renewable energy activities in Nigeria. The Policy aims to deliver quality solutions while ensuring health and safety, environmental protection, security, and social responsibility for employees, contractors, and communities and visitors. Additionally, PriVida has developed an E&S Management System (ESMS) and project-specific E&S Management Plan (ESMP) for its solar mini-grid projects in Benue State, Nigeria following guidance from the WB DARES Platform E&S Management Framework ESMF. The WB DARES Platform ESMF together with associated Resettlement Plan Framework and Land Management Plan and Stakeholder Engagement plan provides the backbone from which PriVida ESMS is aligned.
As part of this IFC investment, PriVida will update its existing ESMS for Benue into a Corporate ESMS manual which will document its entire approach to E&S risks management and overseeing contractor’s performance with specific E&S procedures and plans that address; (i) identification and assessment of E&S risks and impacts, considering contractor’s activities; (ii) E&S management plans and procedures on energy, water, waste and pollution management, (iii) E&S organizational capacity; (iv) emergency preparedness and response, including life and fire safety (L&FS) provisions, (v) stakeholder engagement and community grievance mechanism; (vi) Contractor Management Plan; (vii) Traffic and security management plan; (viii) supplier code of conduct and supply chain due diligence; (ix) occupational health and safety management procedures; (x) Chance Finds Procedure, and (xi) E&S monitoring/reporting procedures, including Key Performance Indicators (KPIs). The Company will also update the Land Acquisition and Resettlement Policy Framework (LARPF) to include the requirements that - site screening and land acquisition processes will operationalize the PS5 avoidance principle; only sites with no physical or economic activities that do not trigger involuntary displacement as defined in IFC PS 5 will be selected; and add requirements for monitoring of land related social risks (ESAP #1).
Identification and Management of Risks and Impacts: PriVida has established an E&S risk identification procedure that enables early-stage risk assessment during planning to ensure risks are addressed prior to design finalization. The company has also developed state-specific ESMPs to satisfy regulatory compliance requirements under the DARES program. All potential sites are screened for E&S risks and impacts and any sites that fall within the exclusion criteria are not selected. The DARES ESMF mini grid site exclusion list includes sites located in legally protected areas (e.g., national parks, conservation areas, forests), in internationally recognized areas, in critical natural habitats and where mini grid construction and operation will cause significant degradation of natural habitats (e.g., mangroves); hosts cultural heritage or sacred sites; sites under active dispute or litigation; sites with environmentally high-risk (flood-prone, erosion-prone); sites that belong to vulnerable groups; and sites that serve as a primary source of livelihood. Once sites are selected, environmental and construction permits are obtained in batches for several sites prior to the start of the construction activities, as guided by the regulatory authorities. The low voltage distribution lines are designed to run along the village roads, and their design is compliant with the national technical requirements, hence pose low E&S risk. Moving forward, PriVida will broaden its risk assessment framework to encompass climate and social vulnerabilities; project alternatives analysis; for the Project sites, the Company will conduct the E&S Assessments and prepare the ESMPs in line with IFC PS 1 and national regulatory requirements; and obtain the environmental permits prior to project commencement.
Site Selection and Land Acquisition: PriVida implements the LARPF to ensure its mini-grid site acquisition is technically, economically, and socially viable. The company has already completed the purchase of 30 of its mini-grid sites from private owners via willing buyer-willing seller agreements. No physical or economic displacement occurred during the acquisition of these sites and no outstanding community grievances were reported related to the land purchase process. There will be no additional land purchase for the distribution lines, which will be laid along existing road servitudes. Similarly, for all future sites to be considered for the mini-grid Project, PriVida will apply site selection criteria that avoid physical or economic displacement, as defined in IFC Performance Standard 5. Should a negotiated acquisition not be achieved, the client will consider alternative sites and not resort to any form of eminent domain. These commitments will be implemented through the updated LARPF in ESAP #1 above.
Management Programs: PriVida has developed ESMPs to address E&S risks and impacts related to both the construction and operations of mini grid sites in each State. The ESMPs identify potential E&S risks, such as land acquisition, community health and safety, labor influx, waste generation, disruption of biodiversity, and construction-phase concerns including dust, noise, and occupational hazards. Also, the ESMP include a mitigation and monitoring matrix specifying responsible parties, relevant indicators, and monitoring frequency. Furthermore, PriVida implements a Health, Safety, and Environment (HSE) Plan, along with an Occupational Health and Safety (OHS) plan, to assess and control safety risks. These plans are supported by related subplans and procedures including: (i) a Contractor Environmental and Social Management Framework, which outlines environmental and social expectations for contractors; (ii) a Waste Management Plan, describing protocols for on-site waste handling, storage, and disposal; and (iii) a Grievance Redress Mechanism (GRM) and stakeholder engagement materials, forming part of the social management framework. As part of IFC financing, PriVida will update its core E&S plans (ref. ESAP #1) as part of an overall ESMS update to align with IFC PSs requirements. Also, PriVida will develop a Site E&S Pre-clearance Procedure as a management tool signed-off by a competent authority to ensure that all E&S processes are completed before commencement of work at each mini-grid project site and which includes site-specific templates for a) preconstruction E&S assessment, b) safety risk assessment c) security risk assessment d) site specific transport risk assessment, e) stakeholder engagement plan, and f) construction kick-off checklist (ESAP#2).
Organizational Capacity and Competency: PriVida currently employs two experienced E&S professionals dedicated to managing E&S aspects within its operations. The ESMP delineates critical roles including Project Manager, Community Liaison Officer, and E&S Officer, each tasked with leading or supporting E&S performance management activities. To accommodate the expected increase in number of construction sites and increase in volume of work, PriVida will enhance its organizational framework by clearly defining roles, responsibilities, and reporting structures, and by appointing appropriately qualified individuals to the positions specified in the ESMP. Additionally, PriVida will ensure that an experienced HSE Officer is incorporated into each main Contractor’s team. Finally, PriVida will provide capacity enhancement training to its E&S staff and those of its Contractors, as well as awareness for supervisory personnel, covering all plans and procedures developed as part of the updated ESMS. (ESAP #3).
Emergency Preparedness and Response: PriVida’s OHS management system requires the development of site-specific Emergency Response Plans (ERPs) and quarterly emergency drills. It emphasizes collaboration with local emergency services. As part of the ESMS update (ref. ESAP #1) PriVida will develop and implement a EPRP that will set out principles and approach to planning and managing emergency response, including: (i) roles and responsibilities; (ii) structure of emergency response organization; (iii) legal and company requirements; (iv) emergency equipment; (v) Emergency procedures; (vi) emergency procedures including in case of climate related events like heatwaves, heavy rains, flooding; (vii) resources required; and (viii) drills, monitoring, maintenance and inspection of emergency equipment, reporting and performance assessment.
Supply Chain: PriVida procures solar panels, batteries, and associated equipment from ‘Tier 1 (directly or through distributors) suppliers and plans to order all the equipment (in bulk) upfront. For this IFC investment, PriVida is considering procuring PV modules through known international suppliers some of whom have been covered in an industry wide solar supply chain due diligence. PriVida has developed a Procurement and Supply Chain Policy and Supplier Code of Conduct which together provide a foundational framework and broadly aligns with IFC PSs requirements, particularly principles from IFC PS1, which focuses on the assessment and management of E&S risks and impacts, and IFC PS2, which addresses labor and working conditions including prohibition of child labor and force labor practices. As per ESAP #1, PriVida will (i) strengthen the Supplier Code of Conduct prohibiting child and forced labor and containing other relevant E&S requirements, including a supplier registration and evaluation sheet that includes these labor and HSE provisions; (ii) develop a process for verifying supplier adherence to the E&S requirements in the Code of Conduct, and; iii) in the PV solar equipment supply contracts, require the supplier to contractually commit to E&S policies that are consistent with core international standards and compliance with Nigerian and international laws and regulations. These provisions will be applied for all solar PV equipment procurement for the Project.
Monitoring and Review: The ESMP outlines monitoring responsibilities, primarily assigned to PriVida and its contractors, and indicates that monitoring activities will be conducted during both construction and operational phases. Indicators include the frequency of inspections, environmental performance checks, and compliance with safety procedures. These are essential for consistent and adequate monitoring of each mini-grid site and at the corporate level, and for appropriate resources allocation. Going forward, as required in ESAP #1 above, the E&S Monitoring and Reporting Procedure will include key E&S indicators to be monitored, levels of E&S monitoring and a clear reporting structure from the mini grid site to the Board of Directors. The E&S monitoring will also include issues related to land acquisition and use (per ESAP#1 above), both from internal monitoring and external stakeholders (including external grievances raised) and the monitoring framework will also support continuous improvement of the system and risk responses. The Procedure will be implemented at all Project sites.
PS 2: Labor and Working Conditions
PriVida currently employs 55 individuals, comprising 25 direct employees (45.5%) and 30 contracted workers (54.5%). At peak construction, with up to 25 active sites, the contractor workforce is projected to increase to 300. During the construction of mini-grid sites, contractors will recruit workers from local communities, with staffing levels determined according to the specific requirements of each construction phase. For each new site, the anticipated workforce will consist of 15 personnel: 10 direct employees and 5 contractor workers.
HR Policies and Procedures. PriVida’s HR process is documented in its Employee Handbook, with managers responsible for ensuring compliance with policies on ethical conduct, systems use, training and benefits. As part of this IFC financing, PriVida will update the Handbook to address both direct employees and contractors, with concise HR policies and procedures that reflect the national labor code; update the grievance redress mechanism, and; include clear provisions on; (i) freedom of association and collective bargaining, (ii) retrenchment policy; (iii) worker accommodations; (iv) force and child labor and (v) sexual harassment policy, c) protection of workforce and workers engaged by third parties (ESAP #4).
Working Conditions and Terms of Employment. PriVida employs staff under permanent or term contracts that outline their entitlements and obligations, including working hours, probationary periods, remuneration packages, and leave. Employees are insured in the national insurance scheme. There are no workers' organizations within PriVida and no evidence of forced labor within its operations. Given that most workers are locally recruited, no company accommodation is provided. Each employee is provided a signed contract with clear provisions on salary, working hours, probation, and benefits.
Workers Grievance Mechanism: PriVida's has developed a grievance redress policy which entails some of the requirements of IFC PS 2 regarding worker grievance. Also, the Employee Handbook outlines a grievance mechanism for employees, ensuring that workplace concerns are addressed fairly, promptly, and confidentially. As per ESAP #above, PriVida will update the grievance redress mechanism to comply with with IFC PS2 requirements by; (i) making it accessible to all workers, including third-party workers, (ii) providing channels to submit grievances (including separate channels for grievances related to GBV-SEAH, and for confidential and anonymous complaints); (iii) indicate roles and responsibilities for treating and responding to grievances; (iv) provide timelines for addressing grievances; and (v) provide mechanisms to log, track and report grievances and their status.
Occupational Health and Safety; PriVida’s Occupational Health and Safety (OHS) management system covers all employees, contractors, suppliers, and visitors. The system emphasizes hazard identification, risk assessment, strict compliance with legislation, ongoing training, open communication, and emergency preparedness. Incident reporting protocols, PPE provision, contractor oversight, and regular performance monitoring ensure continual improvement and program effectiveness. PriVida’s OHS management system offers a framework for proactive safety improvement. As part of its ESMS update and implementation (ref ESAP #1), PriVida will mandate HSE induction training for all workers, site inductions or safety awareness for all visitors, provision of adequate PPE, specific safe system of work training, and daily toolbox talks before commencement of activities to institute or enhance its safety culture. The workers are aware of the management system and the key OHS risks related to their primary activities.
Workers Engaged by Third-Party: PriVida's Procurement and Supply Chain Policy includes a commitment to respecting workers' rights and ensuring fair labor practices throughout its supply chain, largely aligning with the core principles and specific requirements of IFC PS 2. During the construction phase, Contractors will directly hire construction workers from nearby communities. All service providers are required to adhere to PriVida's policies and standards especially on fair recruitment and compliance with the Nigerian Labor Code. The Contractor Management Framework requires that contractors are inducted as per the provisions of the HSE management system and are provided with E&S requirements to be implemented. Going forward, as part of the ESMS implementation the Contractor Management Procedure (ref. ESAP #1) will be implemented at all the Project sites and PriVida shall extend its Workers Grievance Mechanism to cover third party workers (ref. ESAP #4) through provided awareness and accessible pathways to Contractor workers.
PS 3: Resources Efficiency and Pollution Prevention
Solar mini grid projects do not consume significant amounts of key resources such as water and energy especially given the size of the projects. The projects also cause minimal environmental pollution especially during the operations phase. The main risks occur during project construction where generators are used for energy production and water can be used for both construction and dust suppression.
Water Use: PriVida Source its water from onsite boreholes installed with pumps and overhead reservoirs. Water resource needs during construction and operations will be limited to domestic use and for cleaning of panels. PriVida has developed a water use monitoring policy which establishes a framework for monitoring, recording, and reporting water usage across all PriVida assets, including offices, project sites, and accommodations. As per ESAP #1, PriVida will include the KPI from the water use monitoring policy into the overall E&S monitoring and report on water consumption from all its sites.
Air emissions and Greenhouse Gases: The activities at the solar mini-grid sites are expected to produce minimal air emissions during the operational phase. However, site construction activities and transportation associated with the projects may generate dust and vehicle emissions. The ESMP includes mitigation measures to control dust generation, such as regular watering of exposed surfaces, controlled vehicle speed, and covering of loose materials. Greenhouse gas emissions (“GHG”) from the project during construction are predominantly associated with the transport of project components and on-site equipment and machinery including stand-by generators. During operations, annual GHG emissions from occasionally used back-up generators are expected to be well below 25,000 tons of carbon dioxide equivalence.
Wastewater: Wastewater from the washing of solar panels using biodegradable soaps drains into the soils on-site. The project sites have ventilated improved pit (VIP) latrines which can be emptied by a sewerage contractor when required, for offsite disposal. As per the accepted standard, the latrines are sited at least 30 meters from known water sources and do not reach the groundwater table to avoid microbial contamination. Given that these are standard and generally approved latrines that are generally only used by the few staff retained per site, soil and ground water pollution related to their usage is not expected.
Hazardous materials handling, and Waste: The project will generate typical non-hazardous waste streams like packaging materials, paper, plastics, organic waste from workers, and construction debris (e.g., wood, concrete, scrap metal). Also, Hazardous waste and materials handled at the solar mini-grid sites include batteries (e.g., lead-acid or lithium-ion), electronic parts (e-waste), battery chemicals, lubricants, cleaning agents and diesel. PriVida’s has annexed a waste management procedure to its ESMP for the Benue mini-grid projects, and it details procedures for handling, segregating, storing, and disposing of non-hazardous solid waste from construction and operation. The plan emphasizes waste segregation, with recyclable materials separated from general waste, and encourages reuse. It also mandates each construction site to have a designated area for collection and temporary storage while disposal is coordinated with local government-approved facilities or municipal authorities. Significant waste quantities are not expected to be generated per site. As part of the ESMS update (ref. ESAP #1), PriVida will update its waste management procedure to include waste management hierarchy and identification of authorized waste service providers. Also, a waste tracking document that governs waste transfer and disposal process and record keeping that guarantees compliance with national regulatory requirements and IFC PS 3 requirements will be included in the updated waste management plan. Finally, the updated waste management plan will address handling hazardous materials at site level including mitigation measures for spill emergencies.
PS 4: Community Health, Safety and Security
Road Safety & Traffic Management: The transportation of mini-grid components and equipment to the site and staff movements to and from site represents the key safety risk in relation to the other road users and communities adjacent to the roads being used. PriVida’s OHS management system covers traffic and road safety under the broader frameworks of hazard control, safe work procedures, and emergency preparedness. PriVida will implement as part of its ESMS update (ref. ESAP #1) a traffic management plan applicable to its own transport fleet and that of its suppliers. The plan will address driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards. Also, the E&S Site Pre-Clearance Procedure (ref. ESAP #2) to be implemented prior to commencement of works at each mini-grid site includes a template for site specific transport risk assessment.
Security Management: Each existing mini-grid site has a perimeter fence with a single-controlled access point and access control and security is provided by two unarmed agents. The security agents are locally recruited and are selected with the help of the Community Power Committee. PriVida has developed a Security Code of Conduct which outlines clear expectations for the behavior and responsibilities of security personnel on project sites, emphasizing respect for human dignity, non-violent methods, and the prohibition of abuse, discrimination, and bribery. The code aligns broadly with IFC PS4 requirements regarding human rights, use of force, training, and grievance mechanisms. As part of the ESMS update (ref ESAP #1) PriVida will develop a formal Security Management Plan that provides the framework for the site-specific security risk assessment template and enhance community engagement and oversight mechanisms to fully meet IFC PSs requirements.
