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
Policy
The BGC Health, Safety and Environment (HSE) Commitment & Policy defines BGCs expectations for operating safely and in an environmentally responsible manner. This is underpinned by HSE Standards, which set the high-level expectations for managing BGC’s key risk areas, whilst the supporting manuals (which include environment and social performance) define the minimum mandatory requirements needed for the identified risk management areas.
Environmental and Social Management Systems
BGC’s management systems and supporting procedures have been developed to broadly align with the IFC Performance Standards (IFC PS) and industry sector guidelines, such as the International Association of Oil & Gas Producers’ guidelines (IOGP), which include the life-saving rules, HSE management in contracting, environmental performance indicators and other guidance documents. The BGC Health Safety Security and Environment and Social Performance Management System (HSSE & SP MS) applies to all activities associated with BGC work, as well as to contractors and other third parties working on BGC’s behalf.
Identification of Risk and Impacts
Environmental, Social, Health Impact Assessment (ESHIA) is BGC’s primary tool for the identification, evaluation and mitigation of E&S risks and impacts. In 2018 an ESHIA for the overall Project was prepared in line with Iraqi ESIA regulations, WBG General EHS guidelines (IFC, 2007), WBG EHS Guidelines for Onshore Oil and Gas Development (2007), WBG EHS Guidelines for Liquified Natural Gas (LNG) Facilities (2007), WBG EHS Guidelines for Waste Management Facilities (2007), IFC PS (IFC, 2012) and IFC cumulative impact assessment and management guidance for the private sector in emerging markets (IFC, 2013). Stakeholder Engagement Plans (SEP) in support of the ESIA were also developed and implemented.
The ESHIA includes a comprehensive Hazards and Effects Register, based on a Quantitative Risk Assessment, covering environmental, health, safety and social risks associated with construction and operation of the Storage and Marine Terminals. The register identifies potential impacts such as emissions to air, wastewater discharges, waste generation, occupational and process safety hazards, and community health and safety risks, and evaluates them in terms of likelihood, consequence, and control measures in accordance with BGC’s HSSE management framework.
The Project area is part of an existing industrial zone north of Umm Qasr city, and no residential communities are identified within the immediate project footprint.
The Company will develop an addendum to the ESHIA, as per ESAP#1, to address the impacts associated with the construction and operation of the OHTL that will be required to operate the refrigeration trains associated with the Project. The transmission line is classified as an Associated Facility, as per IFC’s definition, and therefore the Company will use its influence and leverage with the owner/operator of the transmission line to implement the mitigation measures that may be deemed to be necessary for the facility to be constructed and operated in a manner that is consistent with the IFC PS.
As per ESAP#2, the ESHIA addendum will also assess construction-phase workers’ accommodations to ensure potential risks are identified and that appropriate mitigation measures are integrated into project planning and implementation.
BGC relies on a Hazard and Effects Management Process (HEMP) and a Risk Assessment Matrix (RAM) for occupational health and safety (OHS) risks identification. These processes and tools are included in BGC’s HSSE & SP MS.
Management programs, Monitoring and Review
As part of the BGC’s ESHIA process, a project specific E&S management plan and commitments register have been prepared. Commitments relevant to the design phase are incorporated into a project’s Premises and Basis of Design documents. Prior to commencement of the construction phase of a project, contractors will be required to develop Project HSE Plans as well as other relevant supporting E&S plans which include the detailed mitigation measures included in the ESHIA. ESIA commitments relevant to the operational phase of a project are part of BGC corporate and/or site level procedures. This ensures that ESHIA commitments are embedded across BGC and contractor management systems, and evidence of their implementation will be reviewed during supervision.
As part of its HSSE & SP Control Framework, BGC has developed Asset Integrity & Process Safety Manual. The system aims to prevent process safety incidents resulting from the unintentional release of hazardous substances or energy. It applies to all facilities handling flammable or pressurized materials, including pipelines, gas processing and liquefaction units, and product storage and export installations. It ensures that process hazards are systematically identified and assessed using the company’s Risk Assessment Matrix (RAM), with risks managed to tolerable levels through design, engineering, and operational controls. Technical integrity is maintained by implementing design and construction standards, conducting regular process safety reviews, and ensuring that HSSE-critical equipment is operated within safe limits, inspected, and maintained according to defined criteria. Formal Management of Change and override procedures govern any modifications or deviations, and each asset has a designated Plant Director accountable for process safety performance, supported by competency management, supervision, and monitoring of leading and lagging process safety indicators.
BGC has an internal audit procedure, which includes three levels of assessment, with the first level consisting of a self-assessment to be performed by a Project team or a contractor, while the second and third audit levels are subject to annual planning and may rely on external support. BGC is in the process of developing an online tracking system in which all self-assessments will be stored, tracked and trended. Level 2 and 3 audit reports are shared with relevant BGC Management and discussed during close-out meetings. The HSE Director also provides briefings during BGC leadership meetings.
BGC monitors compliance with national E&S requirements through an HSE performance monitoring process, which includes a detailed set of procedures. The procedures stipulate the parameters that are subject to monitoring and must be reported as part of the internal HSSE & SP reporting framework. BGC also monitors the project-specific ESHIA commitment registers for projects/assets through its HSSE assurance process.
The HSE and Social Performance teams prepare weekly and monthly reports that are shared with BGC Senior Management, BGC Site Plant Directors, Operations Leads and HSE Site Leads and discussed within the relevant assets’ leadership teams. HSE information is also regularly shared with BGC shareholders.
BGC carries out an annual management review to assess the validity and application of the HSSE & SP MS. This includes:
• Assessing the effectiveness and adequacy of the HSSE & SP MS in delivering the policy and objectives and in driving continual improvement.
• Reviewing trends and learnings from:
• HSSE & SP performance using leading and lagging performance indicators.
• Incident investigations; and
• Audits, reviews and self-assessments
The output from the management review provides input to the BGC annual HSE Improvement Plan.
Organizational Capacity and Competency
The Company has a robust team to manage E&S matters across its operations in Southern Iraq. The team includes eight environmental professionals and eight social specialists (covering social performance, social investment & community liaison). In addition, the Company can rely on the wider support of approximately four hundred HSE team members covering issues such as technical safety, occupational health, emergency response, HSE systems and assurance and operational and project HSE. The HSE functions report to the Company’s HSE Director, while the social performance team report to the Corporate Affairs Manager. Both the HSE Director and Corporate Affairs Manager are part of the BGC Leadership team, reporting directly to the BGC Managing Director.
The HSE and Social Performance teams prepare weekly and monthly reports that are shared with BGC Senior Management, BGC Site Plant Directors, Operations Leads and HSE Site Leads and discussed within the relevant assets’ leadership teams. HSE information is also regularly shared with BGC shareholders.
Emergency Preparedness and Response Plan (EPRP)
The Company has an Emergency Response Plan in place addressing both safety and environmental incidents affecting all BGC locations and /or activities under BGC control including BGC employees, contractors and visitors. The emergencies that are considered in the plan include:
• Process related incidents (Unignited and Ignited releases)
• Pipeline related incidents
• Incidents involving hazardous materials response.
• Limited oil spill response
• Road transport incidents
• Incidents that require rescue of personnel
• Medical emergencies
The emergency response plan clearly defines responsibilities and actions to be taken in the event of an incident and includes provisions for drills and continuous improvement of the plan.
As per ESAP#3, the Company will develop a community emergency response plan that addresses actions that may be taken by community members in the event of a major incident that could extend beyond the Company’s facilities. This is further discussed below under PS 4 – Community Health, Safety, and Security.
E&S Contractor Management
BGC has a contractor HSSE Management Procedure in place that sets out in detail BGC’s contractor HSSE & SP management process. The procedure entails that minimum E&S requirements for contractors are stipulated in the requests for Expression of Interest documents that BGC sends to pre-qualified contractors. The pre-qualification assessment criteria and tools are incorporated into the invitation to tender and contractors are required to provide evidence related to E&S performance for the previous five years. The HSE technical evaluation includes the above standard/assessment and covers additional requirements for worker welfare, child labor, modern-day slavery, and labor and working conditions. During contractors’ mobilization, BGC adopts a Go-No-Go process to verify the contractors’ compliance with the E&S requirements. BGC monitors workers’ welfare by conducting regular audits and effectiveness surveys.
PS 2 – Labor and Working Conditions
General
The Project’s current workforce amounts to approximately 38 BGC full-time employees (all male), supported by about 40 Contractor (EPCm) personnel in Iraq (including four women) and 40 in Dubai (including 10–15 women), as well as around 160 Subcontractor staff (generally male).
The workforce for the Project’s construction phase will include expatriate and Iraqi nationals with peak labor demand anticipated at up to 1500 workers. Final workforce figures will be determined upon completion of the contractor tendering process.
BGC has Human Resources (HR) policies and procedures aligned with Iraqi labor law and IFC PS 2. These cover recruitment, working conditions, compensation and benefits, performance management, training, non-discrimination, grievance handling, termination, and contractor management. A Code of Conduct outlines human rights protections and prohibits harassment. Policies are available in Arabic and English, and a dedicated HR desk supports staff inquiries. An HR Committee provides oversight on HR matters, ensuring alignment with corporate policies, regulatory requirements, and best practices.
BGC has not established a standalone retrenchment policy and instead applies the provisions of Iraqi labor law in cases of workforce reduction. No collective dismissals have occurred over the past five years.
BGC appoints international and national contractors for construction activities. When international contractors are appointed, some workers require on-site accommodation. BGC uses a standardized checklist to audit accommodation against Iraqi legal requirements and international good practice and conducts pre-award and post-award verifications of contractor readiness and welfare provisions. Worker welfare audits, visual inspections, and anonymous worker interviews are part of BGC’s oversight strategy.
BGC embeds labor and welfare requirements in contractors’ contracts, including minimum standards for accommodation and the right to audit. Contractors’ selection includes technical evaluation of E&S performance, and feedback is sought from other operators. Contracts also include provisions to ensure PPE is provided free of charge and that worker welfare standards are budgeted upfront.
As per ESAP#4, BGC will update its HR policies to explicitly address and prohibit Gender-Based Violence and Harassment (GBVH) amongst the workforce, which shall include safeguards to mitigate risks related to unfair treatment, lack of transparency of the terms of employment, and barriers that may restrict access to grievance mechanisms.
Worker’s Organizations
BGC’s HR policies respect employees’ right to form or join trade unions, where permitted by national law. Staff are free to meet, raise concerns, and engage in dialogue with management. In line with the BGC HR Policy Manual, staff are informed of their right to join or not to join a trade union and are encouraged to communicate workplace issues collectively, whether or not a union or formal staff representative body exists. BGC’s employees are represented through the Federation of Oil Unions in Iraq (FOUI), a national sectoral union that includes oil and gas workers from across the Basrah region and is affiliated with IndustriAll Global Union.
Non-discrimination and Equal Opportunity
BGC’s Code of Conduct explicitly protects the rights of its employees and stakeholders, ensuring a work environment free from harassment, intimidation, bullying, or violence. These principles are reinforced in BGC’s HR Manual which prohibits discrimination and promotes equal opportunity for all workers, including contractor staff. The same standards are reflected in the Worker Welfare Procedure, which are also applicable to contractors. Reported breaches of these policies are subject to professional investigation, and appropriate disciplinary measures are applied when violations are substantiated.
Gender-Based Violence and Harassment (GBVH)
BGC employs a total of 207 women across its operations, including 45 direct hires, 152 secondees from Iraq’s SGC and Shell/Mitsubishi, and 10 contractors. In 2018, and as an outcome of BGC conducting a Gender Impact Assessment study, BGC established the Gender Diversity Network (GDN) to provide a support forum for all female employees in BGC. This network, now called the Integration Women Empowerment Network (IWEN), has a broad remit including drawing on speakers/experts for raise participants’ awareness and provide support, as well as providing a forum to seek contribution to the business activities from the female community. BGC has also embedded mechanisms to monitor workplace culture and staff well-being. Since 2022, the company has conducted an annual survey, which includes an assessment of employees’ working conditions and their ability to work in an environment free from violence and harassment. Survey results are disaggregated by gender and shared with senior leadership to inform ongoing improvements. BGC provides training to all workers on harassment prevention and equal opportunity through multiple channels. All employees undergo a mandatory ethics awareness course upon joining the company, and every three years thereafter, which includes modules on harassment and equal opportunity. In addition, recurring harassment awareness sessions are organized with the BGC Women’s Network (IWEN) and the Extended Leadership Team.
As per ESAP#5, upon full mobilization of the construction workforce for the Project, BGC will conduct a GBVH Risk Assessment of BGC’s operations. The assessment will apply to the direct and contracted workforce and will also cover GBVH risks both towards workers and within the surrounding communities. Specifically, the assessment will also identify and evaluate potential GBVH risks that could arise in connection with the Client’s local community development projects and from interactions between workers (including construction and contractor personnel) and community members during project operations.
Worker’s Grievance Mechanism
BGC has a formal worker grievance mechanism available to staff, contractors, and third parties. Workers can raise concerns through their supervisors or anonymously via a third party managed hotline (EthicsPoint), which is managed by an independent third party (NAVEX). The helpline can be accessed via website, telephone, or mobile QR code, and is available 24/7, 365 days a year, in English and Arabic. Reporters may choose to remain anonymous, and reports are handled confidentially by the Ethics and Compliance Department.
BGC’s HR policy outlines expected standards of behavior and provides a grievance process for managing concerns related to undesirable interactive conduct including harassment, discrimination, bullying, victimization, and violence. BGC encourages informal resolution of concerns where appropriate and provides a multi-tiered formal grievance procedure for serious or unresolved cases. Individuals may escalate grievances to senior management or the HR Committee, with final decisions taken by the Managing Director. Grievance procedures apply to all staff and emphasize confidentiality, impartiality, and protection from retaliation.
BGC maintains a centralized log of all Code of Conduct incidents reported either through the Compliance Helpline or directly to HR or Ethics and Compliance representatives, ensuring oversight and accountability. Contractors are required to establish their own grievance mechanisms in line with BGC standards. Induction training for contractors’ personnel includes guidance on how third parties can raise formal complaints and contact the CLO.
As per ESAP#6, BGC will further enhance its Worker’s Grievance Mechanism by:
• Including minimum requirements for all contractors and subcontractors to raise awareness of BGC’s worker grievance mechanism amongst their staff and encourage its use to report concerns promptly and anonymously, if required.
• Communicating the availability of multiple channels for contractors’ and subcontractors’ workers to effectively access and raise workforce concerns, including a separate confidential channel to raise sensitive cases (discrimination, harassment, GBVH).
• Ensuring that grievance procedures are clearly communicated to all workers, and accessible without fear of retaliation.
• Ensuring that staff involved in managing grievances are adequately trained and have relevant experience in the management of GBVH cases and in providing victims of GBVH in the workplace with support using trained personnel and referral pathways, accessible to all employees, including third-party workers.
Supply Chain
BGC manages E&S risks in its supply chain through procedures included in its Contracting Policies and Procedures Manual (CPPM). All potential suppliers are subject to Integrity Due Diligence (IDD) screening prior to engagement, as a mandatory requirement to assess potential reputational, compliance, and ethical risks.
Supply chain risks are evaluated during the contract risk evaluation process, which considers both commercial and E&S risks. This evaluation informs the level of oversight and resource allocation throughout the contract lifecycle. As part of procurement planning, BGC conducts market analysis to identify and profile suppliers and understand market conditions, including high-risk geographies and sectors in terms of geopolitical risks and concerns on labor rights in source countries.
When elevated supply chain risks are identified, BGC implements mitigation measures such as sourcing from alternative suppliers, adjusting inventory levels, and strengthening contract terms. For higher-risk contracts, BGC’s Contract HSSE focal points conduct pre-qualification assessments that may include desktop reviews, site visits, and risk-based classification of contractors to determine the required level of HSSE oversight, in line with the Contractor HSSE Management Procedure.
Workers’ Accommodation
BGC uses both new and existing contractor camps. A dedicated worker accommodation camp will be built for one of the key Project work packages, and existing contractor camps will also be used. BGC verifies worker welfare conditions through technical evaluations and visual inspections and shares a standardized accommodation checklist with contractors during bidding to ensure welfare requirements are included in budgets. Accommodation inspections include spot checks of selected rooms and common facilities. BGC assesses worker welfare risks during contractor pre-qualification and site mobilization. In addition, as part of ESAP#2, the ESHIA addendum will address potential impacts associated with the construction-phase workers’ accommodation and describe appropriate mitigation measures that will be adopted.
Occupational health & Safety (OHS)
Company-wide OHS statistics for 2025 year-to-date indicate that BGC employed 4,902 direct employees and 6,036 contractor employees, with a combined total of over 12 million man-hours worked. Fifteen near-miss incidents were reported, along with eight recordable incidents (three for direct employees and five for contractors). No fatalities occurred. Recordable non-fatal injuries with lost workdays totaled five, resulting in 204 lost workdays. The incidence rate for all recordable cases was 0.47 for direct employees and 0.88 for contractors.
BGC has a corporate Health, Safety, Security and Environment (HSSE) Management System and supporting procedures that apply to all projects and contractors. These include a Hazard and Effects Management Process (HEMP), a Risk Assessment Matrix (RAM), a permit-to-work (PTW) system, and Work Management Procedures (WMP) for 22 core activities. These include a Heat Stress and Adverse Weather Management Procedure, which sets requirements for planning, training, and controls to prevent heat-related illnesses, manage work during extreme temperatures and adverse weather, and ensure safe working conditions all year-round.
In addition, BGC has established a Contractor HSE Management Procedure that outlines expectations and minimum requirements for all contractors, covering both the tendering and execution phases. The procedure applies to all BGC-managed projects and is aligned with the Iraqi legal requirements.
Contractors are required to develop and implement project-specific HSE Plans that include risk assessments, safe work procedures, emergency response, training, and supervision. As part of contractor selection, BGC conducts HSE prequalification based on contract risk, which may include desktop reviews, site assessments, and risk-based classification of contractors. HSSE focal points are responsible for verifying HSE capabilities and documentation during pre-award and throughout contract execution.
BGC carries out routine monitoring and verification activities including inspections of work areas and accommodations, interviews with selected workers, and review of contractor performance. Contractors must ensure the provision of adequate personal protective equipment (PPE) at no cost to workers, and BGC monitors compliance with this requirement.
A standardized HSE checklist aligned with Iraqi labor law is provided to contractors prior to bidding, ensuring that compliance requirements are incorporated into contractor planning and budgeting. Contractor performance is monitored using Key Performance Indicators (KPIs), incident reporting, and regular review meetings. High-risk contracts are subject to increased oversight, including audits and intervention if performance is not aligned with BGC’s expectations.
Additionally, the BGC Engineering, Procurement, Construction Management (EPCm) HSE Bridging Document provides a joint framework for aligning BGC’s and its contractors’ management systems, ensuring no gaps in accountability, hazard control, or compliance during the execution phase. The document mandates annual reviews or immediate updates in case of significant operational changes.
PS 3 – Resource Efficiency and Pollution Prevention
BGC’s HSE Performance Monitoring Procedure includes provisions for all environmental parameters that need to be monitored and reported through the internal HSE reporting process. These include:
• Energy Use and Intensity
• Greenhouse Gas (GHG) emission (Scope 1, 2 and 3)
• Flaring, Acid Gases and other Emissions
• Water Use
• Waste
• Unintended emissions and discharges
Electrical power is provided to the site by the SRT. As part of the Project, a new, 22km, 132kV transmission line will be built by the Basrah Power Company to reach the site. Electrical consumption is metered by the SRT for billing purposes. The Company has recently installed a battery energy storage system (BESS) capable of providing eight hours of uninterrupted power supply in case of grid failure. In addition, emergency diesel generators are available to the Company in case the grid failure extends beyond the capacity of the BESS.
The investment that is currently being considered by IFC will result in absolute GHG emissions of 238 ktCO2e/year (Scope 1 and 2). GHG emissions from the upstream oil fields will, however, be reduced by approximately 2,330 ktCO2e/year as a result of the project’s utilization of the associated gas produced at the oil fields, which would otherwise be flared and leaked without the proposed investment.
Non GHG emissions include nitrogen oxides associated with non-routine flaring of gas during maintenance or emergency conditions. The ESHIA that was carried out for the Project determined that the emissions are limited in magnitude and contribute less than 10% of the maximum permissible concentrations at ground level, based on the World Health Organization’s standard.
Water required for civil and process use (flushing plant equipment and piping, as well as cooling for the instrument air system and for C3/C4/natural gasoline (condensate) product pump seals) is extracted from shallow aquifers and treated to achieve the required sanitary or process standards. Water consumption is monitored and reported on a monthly basis. Wastewater generated at the site is collected in septic tanks and transported to the Company’s main facilities where a sewage treatment plant is in operation.
Historical contamination of soil and groundwater associated with spills of hydrocarbon has been identified by BGC and groundwater quality is monitored as part of the Company’s general environmental monitoring program.
Waste is managed in accordance with BGC’s waste management plan, which covers all requirements for management of waste that are generated at the Project site during construction, pre-commissioning/commissioning and operation. EPC contractor(s) will develop their own construction phase waste management plan aligned with BGC’s as well as Iraqi’s regulatory requirements. BCG’s waste management strategy relies on identification and segregation of all possible recyclable waste streams. In view of the limitations and E&S shortcomings associated with waste management facilities in the region, all but domestic waste is stored at the site in dedicated and secured waste storage areas. Domestic waste is disposed of at a licensed landfill operated by a local municipality.
To overcome the constraints associated with long-term storage of hazardous and recyclable waste streams the Company is actively seeking means of selling scrap steel and other non-hazardous recyclable waste streams (e.g., used office furniture, wood. plastic, tires, etc.). BGC has already identified a suitable contractor that can receive and suitably dispose of medical waste. Waste oils are stored in drums or ISO Bulk Containers (IBCs) and transported to the Basrah oil refinery for reprocessing. Asbestos waste that is being generated as part of the refurbishment works, is temporarily stored in sealed containers within the waste storage area until the Company obtains a license from the Ministry of Environment to develop an engineered landfill for permanently storing asbestos-containing waste within the Project site. As per ESAP#7, to mitigate the risks of domestic waste disposal through use of municipal facilities, the Company will either procure, install and operate a domestic waste incinerator in compliance with WBG EHS Guidelines for Waste Management Facilities, or contract similar incineration services through a suitably licensed third party, subject to due diligence by the Company. In addition, the Company will implement a process for disposal of recyclable or obsolete, scrap or surplus materials.
PS 4 – Community Health, Safety, and Security
The BGC UQ project covers a 2-km2 area at the existing BGC UQ facilities, north of Umm Qasr Marine Terminal (UQ MT). The UQ MT is on the Khor Al Zubair (KAZ) waterway about 11 km to the north of Umm Qasr city and 60 km south of Basrah. The ST is about 12 km to the north of Umm Qasr city and about 6 km away from the MT. The project components are located wholly within the existing footprint of the UQ ST facilities.
Traffic Management
BGC has a corporate Road Safety Policy supported by the HSSE & SP Control Framework, which sets requirements for driver competence, journey management, vehicle standards, and incident reporting. All drivers must complete road safety training and meet defined competence standards. Journey management procedures are used to assess route risks, schedule trips to avoid night driving where possible, and ensure communications protocols are in place. Vehicle safety is ensured through regular maintenance and inspections, in line with manufacturer guidance and internal standards. Contractors are required to comply with BGC’s road safety requirements, and road safety is included in prequalification and ongoing performance monitoring.
As per ESAP#8, BGC will assess potential community road safety risks associated with increased traffic during construction and operations. Based on the findings, BGC will develop and implement a Community Road Safety Management Plan, including mitigation measures such as speed controls near populated areas, driver awareness campaigns, and engagement with local communities and authorities, with specific attention to vulnerable groups.
Security Personnel
BGC’s utilizes private security personnel, with all security providers undergoing Integrity Due Diligence (IDD) screening as a prerequisite to employment. Military or police (primarily the Oil Police Force (OPF)) are not formally contracted by BGC but are deployed by the government of Iraq to protect strategic installations such as those operated by BGC.
BGC’s Code of Conduct and related contractual clauses include commitments to respect human rights and adhere to the Voluntary Principles on Security and Human Rights (VPSHR) and all security personnel are trained on these requirements which include emphasis on principles such as the right to life, prohibition of torture, and peaceful engagement. Awareness training on the VPSHR is also periodically delivered to the OPF (on a voluntary basis). Security personnel are trained in de-escalation, respectful conduct, and documentation of incidents, including how to manage protests and conflict situations without infringing on human rights. BGC has also implemented a Human Rights Policy aligned with its HSSE&SP commitments.
As per ESAP#9, BGC will develop and implement a Community Security Management Plan aligned with IFC PS4 and the VPSHR including:
- procedures for screening, training, and monitoring of security personnel;
- requirements for addressing risks of GBVH and inappropriate use of force;
- regular refresher training for all security personnel including OPF;
- mechanisms for the public to lodge complaints related to security personnel behavior, including anonymous channels and protections against retaliation.
- periodic audits of security providers to assess compliance with IFC PS4 and VPSHR principles.
Emergency Response
BGC has an Emergency Response Plan including procedures for managing incidents across operational sites.
As per ESAP#3, BGC will prepare a supporting Community Emergency Response Plan to ensure effective communication and coordination with potentially affected communities and local authorities in the event of an emergency including:
- Procedures to disclose relevant emergency response information to local communities, including key risks, and available support services.
- A mechanism for engagement with local authorities and emergency response agencies to clarify roles and align protocols.
- Provisions to conduct community-level awareness activities and include local communities in emergency drills, as appropriate to the nature and scale of risks.
- Communication measures tailored to the needs of vulnerable groups (e.g., elderly, women, children), including use of local languages and culturally appropriate formats.
PS5 – Land Acquisition and Involuntary Resettlement
BGC has experience managing land acquisition and resettlement in accordance with Iraqi legislation and IFC PS5, including through the preparation and implementation of project-specific Resettlement Action Plans. As part of its identification of E&S risks and impacts, the Company assesses potential land acquisition and resettlement requirements and determines appropriate mitigation measures.
No land acquisition or displacement is anticipated within the Project site itself as a result of the IFC funded investment. The Project will however require the construction of a new 22km 132kV OHTL that is classified as an Associated Facility, according to IFC’s definition. The OHTL is expected to result in land acquisition for tower foundations and might result in economic displacement due to land use restrictions under the conductors, such as limitations on farming, grazing, or construction.
As per ESAP#1 BGC will:
- Engage with SRT to obtain detailed information on the planned land acquisition process, including nature of rights affected, compensation arrangements, grievance mechanism and will promote alignment with IFC PS5 requirements;
- Conduct a review of the land acquisition process planned and develop corrective actions where gaps are identified;
- Disclose relevant information to potentially affected communities regarding the route of the OHTL, the land acquisition process, entitlements, and grievance channels; and
- Where the gaps are not addressed by SRT, BGC will collaborate with affected communities to close these gaps directly. This might include additional compensation, livelihood restoration support, and access to the Company-level grievance mechanism.
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project is located in the Arabian Desert ecoregion of the deserts and xeric shrublands biome. Project activities will be confined to the existing footprint with no greenfield expansion. The existing footprint does not overlap with Legally Protected or Internationally Recognized Areas or identified priority biodiversity values. The closest Protected Area to the Project site is the Khor Az-Zubayr Key Biodiversity Area (KBA), approximately 6 km to the east of the site. The KBA consists of six sub-sites, which are associated with priority biodiversity values including threatened and migratory raptors, and migratory waterbirds.
The proposed OHTL (Associated Facility) will follow an existing electricity transmission corridor. OHTL present a potential collision (e.g. large-bodied soaring birds colliding with powerlines) and electrocution (e.g. large birds, especially raptors, perching or nesting on pylons or poles) risk. For this reason, per ESAP#1, an addendum to the ESHIA will be prepared to assess and address impacts associated with the construction and operations of the OHTL. Pre-construction surveys along the OHTL route will be conducted as part of the ESHIA addendum, to identify potential high-risk areas for priority bird species and inform any mitigations needed.
If the additional ESHIA work confirms the need to minimize risks of impacting priority biodiversity values using the airspace, which are subject to IFC Natural Habitat No Net Loss (NNL) requirements, BGC will support SRT with the implementation of a bird-safe design, which may include: (i) placement of the pylons and insulators so that the risk of electrocution can be minimized; (ii) installation of bird flight diverters along the entire OHTL to minimize the risk of collision; and (iii) implementation of a post construction fatality monitoring (PCFM) program during operation of the power line to monitor bird flight activity, assess the effectiveness of mitigation, and identify any further measures to be taken, in line with an adaptive management approach.
