While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security

Key risks and issues associated with this Category-B project will include: (a) adequacy of EHS management systems and E&S and OHS staffing to manage EHS risks and impacts with a particular focus on process safety; (b) fire and explosion risks; (c) emissions, effluents and waste management during construction and operation phases in line with WBG EHS Guidelines; (d) adequacy of firefighting and emergency response; (e) labour and working conditions associated to this change.

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

Contour Global has a corporate Health, Safety, and Environmental (HSE) policy and an Environmental and Social Management System (ESMS) aligned with IFC Performance Standards (PS) requirements. These frameworks reflect the company’s commitment to providing a safe and healthy working environment, with a strong emphasis on environmental protection, sustainability, and safeguarding communities. CdB has adopted and adheres to ContourGlobal’s HSE policy, while implementing the corporate ESMS. An Environmental and Social Impact Assessment (ESIA) was conducted in 2015 for the facility’s construction, and a new study was completed in 2025 for the gas conversion project and its associated facility. Both ESIAs covered all aspects of the project, including construction and operational phases.

Given the conversion to LNG as fuel and the resulting changes in risk significance and impact zones, the company also carried out a Quantitative Risk Assessment (QRA) to evaluate safety risks from both the existing HFO storage and the proposed LNG engines. The QRA was conducted in line with good international industry practice and included hazard identification, frequency assessment, consequence analysis, and risk evaluation using iso-risk contours/impact zones and significance levels (e.g., fatality, serious injury, or damage).
The QRA concluded that the overall risk level for both plant workers and the surrounding community falls within the tolerability limit—i.e., the “as low as reasonably practicable” (ALARP) region. It also identifies several recommendations to further improve plant safety. As per ESAP #1, CdB will develop an action plan with agreed timelines to implement these recommendations. Additionally, before operations begin, CdB will conduct a Hazard and Operability (HAZOP) and Safety Integrity Level (SIL) study for the LNG conversion project (ESAP #1).

E&S responsibilities are shared between the Plant Manager and the HSE Officer. They are responsible for overseeing the implementation of HSE plans and procedures across the facility and for supervising the development and implementation of site-specific procedures when required. CdB currently implements the Environmental and Social Management Plan (ESMP) developed under the 2015 ESIA, along with the corporate HSE management plan. The 2025 ESIA includes a detailed ESMP for both construction and operation phases, reflecting changes to the facility. As part of ESAP #2, CdB will require the EPC contractor to develop and implement a comprehensive Construction Environmental and Social Management Plan (CESMP) based on the findings of the ESIA and ESMP, along with sub-plans as needed. The CESMP will serve as the guiding framework for E&S risk management during construction, and CdB will contractually require the construction contractor to implement it. CdB will also require the EPC contractor to recruit qualified personnel for HSE risk management for this period.

CdB has dedicated Emergency Preparedness and Response Plans (EPRP) for the plant. The EPRP outlines roles and responsibilities for implementing the plan, major emergencies such as fire, workplace accidents, and confined space rescue, among others. It also details the procedures to follow in each situation, the resources required (e.g., spill kits and extinguishers), drills to be conducted, and communication protocols with external stakeholders. The EPRP will be updated based on findings from various process safety studies and a detailed Occupational Health and Safety (OHS) risk assessment as part of ESAP#3. The updated EPRP will also address climate-related risks, such as heat waves.


PS2- Labor and working conditions

At the time of appraisal, the Company employed approximately 55 direct full-time staff, of which 14% were female. In addition, around 20 third-party contracted workers were engaged for cleaning and security services. The unionization rate was roughly 76% at the time of appraisal. For the conversion project, the EPC is estimated to employ around 80 workers at peak of the construction activities. Most of the workers will be recruited from the nearby communities or Greater Dakar region, thus on-site accommodation is not expected. The project is not expected to recruit additional employees during operation.

CdB has documented Human Resource (HR) policies and procedures that comply with national law and apply to all direct employees. Each worker receives a written contract outlining working conditions and terms of employment. Employees work 40 hours per week, and the plant operates 24/7 in two shifts of twelve hours each; four day ON DUTY/ four day OFF. Any hours beyond this are treated as overtime and compensated in accordance with national legislation. CdB maintains a documented grievance mechanism for workers, including third party workers. Grievances can be submitted through department heads or the HR manager and are investigated by the HR team. All grievances are recorded, and periodic reports are provided to management. Anonymous grievances can also be submitted via the EthicsLine online platform. Posters promoting EthicsLine for confidential and anonymous reporting are displayed prominently throughout the plant premises. The HR policies further include right to freedom of association, collective bargaining, anti-harassment and anti-discrimination commitments, prohibiting engagement of child, forced or bonded labor practices including in the supply chain consistent with national labor laws and IFC PS2 requirements.

CdB has an OHS program based on ISO 45001 principles. It covers all operational and construction activities, aiming to ensure a safe and healthy work environment. The program includes risk management, legal compliance, training, communication, emergency preparedness, and continuous improvement, with responsibilities shared across all organizational levels. OHS performance is measured using KPIs documented in OHS scorecards, monitored quarterly, and reviewed monthly by both the country-level and corporate Health & Safety committees. Workplace OHS risk assessments have been completed for all operations and are regularly reviewed and updated. With the upcoming conversion, CdB will update the OHS risk assessment to account for the use of LNG as fuel (ESAP #4).

PS3-Resource Efficiency and Pollution Prevention

The plant produces a maximum of 754 GWh of electricity per year, transmitted through an existing overhead transmission line. No change in production capacity is expected with the conversion project. However, scope 1 GHG emissions are projected to decrease from 381,000 tonnes CO2eq to 257,383 tonnes CO2eq, representing about a 32% reduction.

The main point sources of air emissions are the five existing stacks 40 m high connected to the power generating engines. With HFO as fuel, the main pollutants are mainly Nitrogen Oxides (NOx), Sulfur Oxides (SOx) and Particulate Matter (PM). CdB currently undertakes bi-annual monitoring of stack emissions and ambient air quality, which are found to be compliant with WBG EHS guidelines. The ESIA includes an air modeling study focused on emissions from natural gas use. The primary pollutants anticipated are NOx and Carbon Monoxide (CO-under unusual operating conditions). The air modeling also considers the cumulative impact of a nearby power plant, which is also expected to operate on natural gas. NOx and CO emissions are expected to remain within the guideline values recommended by the WBG EHS guidelines, while SOx and PM emissions are not expected to be generated after the fuel switch. Going forward, CdB will install a continuous air quality monitoring system for the stacks to ensure live monitoring of its emissions (ESAP#5). Noise emissions are generally low and confined in the building inside the plant. Workplace noise exposure is managed under the OHS plan.

The water use at the plant relates to cooling, floor cleaning and sanitary uses, which is about 100 m³ per day. Water consumption is not expected to increase and will continue to be sourced from the national network. The plant does not produce process wastewater except for oil -contaminated cleaning water and stormwater from bunded area. This wastewater is treated at the existing wastewater treatment plant of the facility. The treated effluent quality is monitored on regular basis and used for the irrigation of green areas within the premises. Stormwater generated on the site is collected via on-site drains to an oil-water separator before being disposed to the national sewer system.

Annually, the plant will require approximately 150 million Nm³ of LNG, supplied as needed via pipeline, with no onsite storage. Currently, the plant has four above-ground HFO tanks with a total storage capacity of 8,000 m³, equipped with bund areas and level detection mechanisms. Daily visual inspections are conducted for leaks and risk-based inspections are carried out. CdB also conducts regular monitoring of underground water quality for presence of hydrocarbon, and no contamination has been observed. With the project, the HFO tanks are expected to be used only in emergency situations when LNG is not locally available.

Hazardous waste generated from the plant includes used filters, spent oil, and empty containers of hazardous chemical substances. All hazardous waste is collected and disposed of at a hazardous waste management facility through a licensed third-party company. Non-hazardous solid waste is collected by a licensed waste collecting company.

PS4-Community Health, Safety and Security

As discussed under PS1 above, the company has completed a QRA for the proposal conversion project in line with good international industry practice and this includes hazard identification, frequency assessment, consequence assessment and risk assessment in the form of iso-risk contours/impact zones and significance of the risks (e.g., fatality, serious injury or damage). The QRA concludes that the risk level for both workers within the associated plant and community are within the tolerability limit i.e. as low as reasonably practicable (ALARP) region.

CdB plant is equipped with fire alarms, fire detection systems and fire suppression systems in line with the national building and good industry practice. Upgrades to the life and fire safety system will be made in-line with the recommendations of the QRA, HAZOP, SIL and other related studies. The plant is also regularly audited by qualified and certified fire safety professionals in line with national legal requirements. The Company organises regular induction and refresher life and fire safety trainings; and safety drills for all of its workers.

CdB utilises third party security personnel to manage any security risk. The Company has a security management plan which will be updated to align with the requirements of Voluntary Principles on Security and Human Rights (ESAP#6). The need to carry out regular security risk assessment and appropriate trainings to security personnel will also be included in the plan.

The Company applies to several channels to engage with the local communities, including regular meetings with communities, corporate social responsibility programs and public consultation during impact assessment. CdB has a documented Stakeholder Engagement Plan mapping all relevant stakeholders including nearby communities. According to the Grievance Mechanism Procedures, any party concerned can send grievances via letters; reaching out directly to the CdB community liaison officer; or emails to the corporate sustainability and compliance teams.

Contact Person: Papa Mamadou DIACK
Company Name: ContourGlobal
Address: Centrale Electrique de Cap des Biches / Rufisque Ouest
BP 23607 Dakar-Ponty | Senegal

Email: papa.diack@contourglobal.com
Phone: +221 786371947

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	CdB will develop an action plan with agreed timelines to implement the QRA recommendations. CdB will conduct a Hazard and Operability (HAZOP) and Safety Integrity Level(SIL) study for the LNG conversion project.	01/31/2027
2	CdB will require the EPC contractor to develop and implement a comprehensive Construction Environmental and Social Management Plan (CESMP), along with sub-plans as needed. The CESMP will serve as the guiding framework for E&S risk management during construction, and CdB will contractually require the construction contractor to implement it. CdB will also require the EPC contractor to recruit qualified personnel for HSE risk management for this period.	10/31/2026
3	The Emergency preparedness and response plan will be updated based on findings from various process safety studies and a detailed Occupational Health and Safety (OHS) risk assessment. The updated EPRP will also address climate-related risks, such as heat waves.	01/31/2027
4	CdB will update its OHS risk assessment to account for the use of LNG as fuel.	01/31/2027
5	CdB will install a continuous online air quality monitoring system for the stacks to ensure live monitoring of its emissions.	03/31/2027
6	The security management plan will be updated to align with the requirements of Voluntary Principles on Security and Human Rights. The need to carry out regular security risk assessment and appropriate trainings to security personnel will also be included in the plan.	05/31/2026