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
The company has developed and maintains a structured framework designed to manage risks and impacts associated with its projects through adherence to applicable national standards, E&S regulatory permits, and good international practice requirements.
R.Power’s Vice-President of the Board is responsible for overseeing EHS across the company projects and operations, with a focus on developing and implementing the company’s health and safety (H&S) strategy, safeguarding compliance with national and international H&S regulations and good international industry practice, overseeing contractors’ E&S performance, and implementing R.Power’s Corporate Social Responsibility (CSR) program and sustainability reporting.
R.Power has implemented comprehensive E&S policies, including a Code of Business Ethics and Conduct, an Environmental, Health, and Safety (EHS) policy, and a Whistleblowing policy. These policies demonstrate top management's commitment to adhering to principles that align with IFC's Performance Standards (PS), and such policies will be applicable to the Project. The company also has several ISO certifications, including ISO 14001:2015 (on environment management system) and ISO 45001:2018 (on occupational health and safety).
The company's primary operations are carried out by EPC and O&M contractors, with specialized teams monitoring the contractors' E&S-related performance. The Environmental Proceedings Office at the R. Power development, which handles permitting and developing, has 10 people, managed by the Head of Regulatory. The EHS function is also part of the R Power Asset Management subsidiary, which oversees renewable energy asset performance.
R.Power is taking further significant steps to strengthen its Environmental, Health, and Safety functions across its operations. The company Corporate Head of Health and Safety commenced work in May 2025. The Corporate Head of Health and Safety will develop and implement a comprehensive Health & Safety strategy and procedures across all of the company's business units (development, construction, and operation), and ensure compliance with national and international H&S regulations and industry best practices.
As stipulated in ESAP #1, part of the EHS management system, this new corporate function will specifically include the oversight of contractors' environmental, health, and safety performance.
At the project level, since IFC PS6 requirements of No Net Loss will apply, environmental oversight will focus on management and reporting of all biodiversity mitigation activities relating to the project.
An Environmental Impact Assessment (EIA) was approved by the authorities for the Jedwabno BESS and made publicly available. As the BESS is located within the Protected Landscape Area, additional biodiversity analysis has been conducted on the terrain and its protection objectives, with no significant adverse impacts identified. Standard environmental mitigation measures are proposed. The non-technical summary in English will be published before the construction starts.
The two other BESS projects were not required to undergo an EIA as they met regulatory compliance through detailed project information cards, which contained initial environmental assessments approved by the regulatory authority.
The permitting process is underway at the three sites.
Per ESAP#2, R. Power will undertake a supplementary Environmental and Social Impact Assessments (ESIAs) in line with IFC PS1 requirements prior to the commencement of the construction phase of the projects. The supplemental studies will bridge existing gaps in baseline data and information, and provide a detailed impact assessment and mitigation measures, specifically related to socio-economic aspects, noise impacts, biodiversity values and potential traffic impacts during construction. For Tursko Wielkie, additional data and assessments will include mammal species that are currently using the Ecological Corridors and occur in nearby Natural Habitat, potential impacts of the project on these species and measures to avoid and minimize impacts of habitat loss and fragmentation.
As agreed in the ESAP#3 , before start of the construction and operation, the project will develop site-specific Construction and Operation Environmental and Social Management Plans (ESMP) for each BESS site, including a number of “implementation” plans detailing the controls that will be applied to ensure compliance with E&S requirements, such as: Code of Conduct for employees and sub-contractors (addressing gender-specific safety and equity in the workplace and communities); Workers accommodation plan; Community Health and Safety Plan; Occupational Health and Safety Plan; Traffic Management Plan; Emergency Preparedness and Response; Erosion and Sediment Control Management Plan; Archaeological/Cultural Heritage Chance Finds Procedure; Dust reduction Plan; Waste water management Plan; Waste Management Plan, including Battery Disposal; Hazardous materials management Plan; Noise pollution minimization Plan; Water Resources Plan; Biodiversity action plans; and Site Security Plan and Security Management Plan, as applicable and proportionate.
The company will rely on the BESS suppliers for Construction and O&M services. To ensure that contractors duly follow the project’s E&S commitments, as described in ESAP#4, R Power will develop a Contractor Management Plan to include general and project-specific E&S, including OHS, requirements and conditions for the construction and operation of all BESS in line with IFC’s Good Practice Note “Managing Contractors: Environmental and Social Performance”. The provisions of the Contractor’s Management Plan shall be an integral part of the EPC and O&M contract.
The company’s environmental and social assessment includes climate-related risks to the project, such as heat or cold waves, wildfires, heavy precipitation, storms, or flooding. Certain risks are addressed during the site selection stage, while other adaptation measures are implemented throughout the design, procurement, and construction stages. These measures include careful selection of construction materials and techniques that are resistant to extreme temperature changes, reducing the risks of fire ignition and spreading, and minimizing the likelihood of installations being damaged by strong winds or other natural hazards.
The IFC review identified moderate project environmental and social risks and impacts on the selected sites due to climate change, including an increased probability of heatwaves, which may affect outdoor workers during construction and maintenance.
As outlined in the ESAP#3 and ESAP#8, the Emergency Preparedness and Response Plans (EPRP) will be developed as part of site-specific ESMPs, with consideration of the potential events of heatwaves, droughts, and flooding. Any potential adverse impacts from increased temperatures will be managed by implementing relevant measures within its occupational health and safety protocols which should be included in the Construction and Operation Environmental and Social Management Plans (ESMP) for each BESS site. These may include 1) the provision of sufficient drinking water on-site; 2) adjusted work schedules to minimize exposure during peak heat periods; and 3) access to shaded or climate-controlled rest areas, with frequent breaks encouraged. Additionally, the client will update its Emergency Preparedness and Response Plans to cover climate-related risks, such as flooding and wildfires.
The BESS will be situated in sparsely populated regions, on previously agricultural land leased from individual farmers at each location, based on mutually agreed terms. The company is securing land for its renewable energy projects through land lease agreements usually signed for 30 years. Land needs to be secured for all infrastructure elements necessary for a proper operation of a BESS facility (i.e., battery system containers, transformer stations, cables, switching station, internal access roads etc.). The rights for the transmission infrastructure, like evacuation cable, are typically obtained at further stages of the Project’s development, when the location of the point of connection and the connection concept is already known. Rights for the land used for the connection route are obtained based on transmission easements with landowners.
Considering that PS5 impacts may potentially occur in the future during acquisition of land rights for the yet-to-be specified underground transmission lines routes, the company will develop Land Acquisition Framework in compliance with PS5, as outlined in the ESAP # 5. The LAF will evaluate the project's land acquisition process, including securing right-of-way and easement rights, and outline the Company's principles and commitments regarding compensation for any impacts on land users and other affected individuals or businesses during construction and operation, including informal land users, in accordance with national requirements and IFC’s PS5. Furthermore, the LAF will detail the steps that will be taken to implement and monitor the impact of land acquisition for the Project in accordance with national requirements and IFC’s PS5.
PS2: Labor and Working Conditions
In 2024 the company employed 89 male workers and 81 female workers in addition to 52 contracted male workers and 18 contracted female workers, totaling 240 workers.
R.Power's HR policies include a Code of Business Ethics and Conduct, a Remuneration policy, and a Whistleblowing procedure. The Code covers equal employment opportunities, non-discrimination, and harassment prevention.
R.Power does not prohibit the freedom to associate and workers right to form and join workers organization. A worker representative was elected in 2024.
The company has a documented internal grievance mechanism and management procedure that is responsive and enables workers to raise concerns without fear of retaliation. The grievance mechanism for labor-related matters will also be made available to contractor workers. The procedure clearly explains how a worker can file grievances and how they are handled. The grievance mechanism is explained to all workers and all grievances are documented in a centralized register. The mechanism allows for confidential and anonymous complaints and all complaints are required to be investigated. No grievances were received to date.
The company's HR policies and procedures comply with IFC's PS2 requirements.
The project supply chain includes procurement of BESS and electronic components from international suppliers. The shortlisted BESS suppliers should have supply chain management systems (SCMS) in place, also applicable to cell suppliers. The company will verify and document that this is the case. In accordance with the ESAP#6, the company will update/develop SCMS for equipment procurement to ensure that a due diligence process is established to assess suppliers before entering a commercial relationship and that their practices are aligned with legal and IFC PS2 requirements. The SCMS will include an IFC PS2-aligned code of conduct for suppliers, a procedure for due diligence of the potential equipment suppliers including mapping of their supply chain up to battery cell level, contractual clauses requiring suppliers to comply with the code of conduct, engagement and disengagement procedure for suppliers when found to be in breach of contractual obligations, and an ongoing supplier evaluation and verification procedure for compliance with the code of conduct.
PS3: Resource Efficiency and Pollution Prevention
IFC expects this project to result in annual emissions reductions of approximately 451,370 tCO2e.
The project will handle battery waste from maintenance activities during operation and batteries at “end of life” before decommissioning as well as in case of damaged batteries. As required by the ESAP #3, The Project will develop a Battery Disposal Plan including the recycling options for e-waste and identification of licensed waste processing facilities. The plan will specify which materials will be recycled, disposed of locally and which will be exported and to which locations.
In addition to the impacts identified in the ESIA, as per ESAP#7, the company will ensure that appropriate battery leakage protection is part of the design.
As described in PS1 section, the company will apply site-specific Construction and Operation ESMPs to manage environmental risks and impacts, particularly in terms of noise management, dust control, spills, battery disposal, and hazardous materials management.
PS4: Community Health, Safety and Security
The BESS sites are located in rural areas.
The distance to the nearest residential structure is 270 m for BESS 1 (Jedwabno), 26 m for BESS 2 (Tursko Wielkie) and 405 m for BESS 3 (Gdansk II). These distances have been proved acceptable under applicable legal regulations, particularly in terms of noise emissions, which are a key factor affecting residential comfort. A noise assessment was prepared for the project, demonstrating that the predicted levels of noise
generated by the installation would not exceed the permissible limits defined in the relevant regulations, including the Regulation of the Minister of the Environment of 14 June 2007 on permissible ambient noise levels (LAeq D or LAeq N). During operational phases of the installation, monitoring of ambient noise will be part of the ESMP, ensuring the protection of nearby residents from potential excessive acoustic impacts.
In accordance with ESAP #2, the Company will provide IFC with noise modeling results to confirm adherence to the WBG’s guidelines on ambient noise as specified in the General EHS Guidelines.
Transformer stations and transmission lines are sources of electromagnetic field emissions associated with BESS projects. The underground cable line will be housed in shielded enclosures to eliminate electromagnetic radiation, ensuring electromagnetic fields remain within permissible limits. Transformers will be located in transformer stations to minimize their electromagnetic impact.
The assessment and management of community health and safety risks as well as emergency planning and response will be the responsibility of the EPC and O&M contractors. As per ESAP #3, R.Power will ensure that the Code of Conduct for construction workers and sub-contractors (taking into account aspects of gender-specific safety and equity in the workplace and communities, such as provision of appropriate personal protection equipment); noise management, dust management, transport and road safety, and other relevant community health and safety aspects are addressed in the construction and operation ESMPs.
According to ESAP #9, the company will ensure that fire protection measures are included in the design of the BESS. These measures will be independently verified after construction is completed. Maintenance will be part of the Operation Environmental and Social Management Plans (O-ESMP) for each BESS site.
As agreed in the ESAP # 8, the company will review and update the emergency response plans for each of the BESS sites in consultations with responsible authorities and communities to cover at least fire, flood response, spills, severe injuries and fatalities, as well as other events that could reasonably be expected to occur.
No potential risks to the community have been identified from the implementation of planned security measures.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
All three BESS sites are situated in the Temperate Broadleaf and Mixed Forests biome, of which BESS 1 (Jedwabno) and BESS 2 (Tursko Wielkie) are in the Central European mixed forests ecoregion, while BESS 3 (Gdansk II) is in the Baltic mixed forests ecoregion (Resolve, 2017). All of the sites are in agricultural land, where the habitat conversion took place some decades ago. Jebwabno and Gdansk II are located within boundaries of Legally Protected Areas; Doliny Drwecy Protected Landscape Area and Zulaw Gdanskich Protected Landscape Area, respectively. Tursko Wielkie, on the other hand, partially overlaps with a legally designated Ecological Corridor, Swietokrzyskie Mountains and Vistula Valley KPdC-3B Corridor and is adjacent to Swietokrzyskie Mountains and Vistula Valley KPdC-8A Corridor, both of which provide ecological connectivity and enable movement of mammal species in the area.
Priority biodiversity values that could potentially occur in all three sites include ground-nesting species, including the European Turtle Dove (IUCN Red List –Vulnerable) and Eurasian Red Squirrel (IUCN Red List – Least Concern), and mammal species that could potentially be using the officially designated Ecological Corridors and also the Protected Landscape Areas, including the Red Deer, European Roe Deer, Red Fox, European Hare, Grey Wolf and Western Polecat. In Tursko Wielkie, there is also potential for occurrence of the threatened Common Hamster (IUCN Red List – Critically Endangered). IFC Natural Habitat No Net Loss (NNL) requirements will apply to all of these priority biodiversity values and the habitats they are associated with.
Prior to the commencement of the construction phase, R. Power will provide additional data and information and conduct an impact assessment on biodiversity values that are associated with the Ecological Corridors and natural woodland habitat in Tursko Wielkie within the scope of a supplementary Environmental Assessment (ESAP#2). The company will also develop and implement a construction-phase Biodiversity Management Plan (BMP), under the Construction ESMP (ESAP#3) to avoid impacts on priority biodiversity values associated with the Protected Areas in Jedwabno and Gdansk II, and the Ecological Corridors and nearby woodland habitat in Tursko Wielkie. The BMP will include all relevant measures, including pre-construction check-ins for priority biodiversity values and their nests. The company will designate a Biodiversity Specialist, who will be responsible for the check-ins and overall management and reporting of all mitigation activities relating to the project.
For the operations-phase of the project, R. Power will develop and implement an operations-phase BMP including a Monitoring Strategy for priority biodiversity values, notably for ground-nesting species and mammals that move through the ecological corridors and Protected Landscapes (ESAP#9). The operations-phase BMP will include: (i) recommendations for measures and opportunities to maintain biodiversity on-site, (ii) a clear demonstration of how NNL will be achieved, through implementation of the mitigation hierarchy and enabling continued animal movement, as applicable, and (iii) Monitoring Strategy to develop monitoring tools for priority biodiversity values and define any additional mitigation measures, if required. In line with IFC PS6 requirements, R. Power will coordinate with relevant stakeholders in developing and implementing the operations-phase BMP, including agencies responsible for designation and management of Protected Landscapes and Ecological Corridors, conservation organization, research institutions and experts. Through engagement and consultation with relevant stakeholders, R. Power will also seek opportunities to support management/conservation programs within the Protected Landscape Areas and Ecological Corridors.
