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: Prado Power has developed E&S policy statements on (i) Environmental Protection; (ii) HSE; (iii) Gender; and (iv) Anti-Bribery-and-Anti-Corruption. The Company’s E&S Management System (ESMS) has been developed following guidelines from the WB approved DARES Platform E&S Management Framework (ESMF). This ESMF serves as an E&S assessment and management tool for DARES projects and provides guidance for satisfactory E&S performance management during project planning design, construction and operation phases in line with the applicable WB E&S Standards (ESS). Also, the ESMF is supported by separate instruments such as Resettlement Plan Framework (RPF), Labor Management Plan (LMP) and Stakeholder Engagement Plan (SEP) prepared for the DARES Projects, based on WB’s ESS. These documents serve as anchor E&S instruments for RESCOs selected to participate in the DARES program.
Prado Power’s ESMS is guided by the DARES ESMF and adequately covers most of the key E&S risks associated with Prado Power’s activities. Going forward Prado Power will strengthen its ESMS by including (i) an E&S training plan to guide training to management and staff on core E&S policies, plans and standard operating procedures; (ii) an E&S monitoring and reporting procedure and associated Key Performance Indicators (KPIs) for tracking and monitoring E&S (including OHS, labor, waste and hazardous materials and biodiversity) performance (iii) Supplier Code of Conduct and supply chain procedure; (iv) a document control system and an interface for recording and safe guarding of E&S performance management documents and data; and (v) an updated Land Acquisition section of the ESMS that includes a requirement for selection of only sites that avoid physical or economic activities that do not trigger involuntary displacement as defined in IFC PS 5, and requirements for monitoring of land acquisition related social risks. The company will also update the Emergency Preparedness and Response Plan (EPRP) to include; (i) emergency scenarios related to diesel spillage and severe weather (including heatwaves, heavy rains and flooding) leading to collapse of structures like distribution poles; (ii) engagements with local emergency services in planning drills; setting clear schedules for emergency response training and post-training evaluations to measure effectiveness; (iii) performance indicators to track emergency preparedness; (iv) clearly referenced national and local emergency laws, and (v) a requirement for clear emergency instructions to be displayed at all mini-grid sites in the EPRP (ESAP #1).
Identification and Management of Risks and Impacts: Prado Power has established a comprehensive site selection strategy that combines desktop studies and field assessments with community input. The company criteria for site selection include remoteness from the grid, minimal security challenges, absence of agricultural activity, limited or no historical energy access, availability of labor, low GBV-SEAH risks and climate resilience. All sites that fall within the DARES program exclusion criteria are not selected. The DARES ESMF mini grid site exclusion list, that the company complies with, 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; under active dispute or litigation; environmentally high-risk (flood-prone, erosion-prone); belongs to vulnerable groups; or serving as a primary source of livelihood. In accordance with the Nigerian Environmental Impact Assessment (EIA) Act, Prado Power has developed and submitted ESMPs for mini-grid projects to the relevant state authorities and has obtained approval in the states of Ondo, Taraba, Benue, Nasarawa and Niger. These ESMPs include detailed E&S baseline assessments, impact identification, mitigation strategies, stakeholder engagement, and decommissioning plans. Similarly, 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.
Land Acquisition: Prado Power acquired all 18 mini-grid sites to be financed by IFC through 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 acquisition process. There will be no additional land acquisition for the distribution lines, which will be laid along the village roads to the client premises. Similarly, for all future sites to be considered for the mini-grid Project, Prado Power will, as part of its ESMS upgrade, 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 as defined in the updated Land Acquisition section of the ESMS per ESAP #1 above.
Management Programs: Prado Power has developed overarching E&S Management Plan (ESMP) that covers a batch of sites in each State of operation in accordance with the regulatory requirements. Each ESMP includes a detailed Mitigation and Monitoring Plan, which specifies the environmental and social aspects to be monitored, the frequency of monitoring, responsible parties, and performance indicators. In addition to the ESMP, the company has developed a comprehensive management program which comprises a series of associated sub-plans and other risk management procedures including (i) Contractor Management Plan; (ii) Community and Stakeholder Engagement Plan; (iii) Emergency Response Preparedness Plan; (iv) E-Waste Management Plan; (v) Chance Find Procedure; (vi) Grievance Procedure (vii) Site Security Plan; (viii) OHS Management Plan; (ix) Hazardous Materials Management Plan; (x) Waste Management Plan; (xi) Water Management Plan; (xii) Gender Action Plan. Finally, Prado Power assigns specific E&S responsibilities to project managers, environmental officers, community liaison officers, and contractors and integrates training and capacity-building programs like site induction training and regular toolbox talks to ensure personnel are aware of their E&S responsibilities. As part of the IFC Financing, Prado Power will (i) update its core E&S plans to ensure that the E&S requirements included in the Contractor Management Plan are expressed in procurement standards, translated into tender documents and finally in contracts and (ii) develop a Site E&S Pre-clearance Procedure that includes site-specific templates for a) preconstruction E&S assessment, b) safety risk assessment c) security risk assessment d) site specific transport risk assessment, driver fatigue management and periodic review of road transport accident statistics, e) stakeholder engagement plan, and f) construction kick-off checklist. This procedure will be used as a management tool to ensure that all E&S processes are completed before commencement of work at each mini-grid project site (ESAP #2).
Organizational Capacity and Competency: Prado Power’s organogram for its mini-grid projects outlines a decentralized structure led by a Head of Mini-grid Sustainability, supported by three Regional Managers (North, Benue, and South), a Central Technical Operations Manager, and a network of Field and On-Site Technicians assigned per community. The Chief Executive Officer (CEO) has overall oversight on the Company’s organization including accountability for E&S matters. Going forward Prado Power will strengthen its E&S organizational capacity by; a) including clearly defined roles and responsibilities and reporting lines; b) appointing a dedicated experienced EHS manager at the corporate level supported by suitably experienced HSE Officers at State level to oversee the update and implementation of the ESMS and reporting of E&S performance to senior management; and, c) mandating construction contractors to have dedicated E&S organizational structure comprised of at least a dedicated HSE and human resource personnel (ESAP #3).
Emergency Preparedness and Response: Prado Power has developed a standard Emergency Preparedness and Response Plan (EPRP) for all activities. The EPRP outlines procedures for hazard identification, communication systems, emergency resources, and post-incident debriefing and defines roles within the emergency response team including those of the incident commander and operations officer. As indicated in ESAP #1, Prado Power will update the EPRP to adequately address prepare for, and handle, emergencies.
Monitoring and Review: Prado Power has an internal audit procedure approved in July 2024 which defines the purpose, authority, and responsibilities of the internal audit function. It outlines the audit’s independence, reporting structure, scope, and adherence to professional standards and includes provisions for audit planning, reporting, quality assurance, and consulting services. Also, the procedure ensures governance and accountability for periodic monitoring and external audits of projects. Finally, the ESMS and ESMP include monitoring requirements and provisions for reporting to senior management. Going forward, Prado Power will implement an E&S monitoring and reporting procedure (ref. ESAP #1) with defined KPIs. The procedure will include key E&S indicators to be monitored, levels of E&S monitoring and a clear reporting structure from the lowest monitoring 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 Procedure will be implemented at all Project sites.
Supply Chain: Prado Power procures solar panels, inverters, batteries, charge controllers and associated electrical equipment from ‘Tier 1’ suppliers. Each of these supply streams involves coordination between procurement, logistics, and technical teams to ensure timely delivery, quality assurance, and compliance with project specifications. The Company has a Procurement Management Policy with provisions prohibiting forced labor, child labor, and significant safety issues in its supply chain. Also, the Policy emphasize ethical sourcing, supplier due diligence, and compliance with international labor and safety standards. To safeguard against unfair labor and OHS practices in the PV solar supply chain, Prado Power will a) develop and implement a Supplier Code of Conduct and supply chain procedure (within the ESMS, as required in ESAP #1 above) 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. The Code of Conduct will require suppliers to contractually commit to E&S requirements like traceability audits consistent with international standards and compliance with Nigerian laws and regulations (ref ESAP #3) and include mechanisms for escalation into the grievance mechanism of supply chain related issues where relevant to guarantee satisfactory resolution.
PS 2: Labor and Working Conditions
Prado Power currently employs 68 staff split into 82% male and 18% female. Additionally, up to 30 contractor workers are currently deployed for site construction at the SL Farms mini-grid project site in Kwali. The workforce is expected to grow as the Company expands their mini-grid coverage. During mini-grid site construction, workers are recruited from the local community by Contractors and their numbers are based on workforce needs at each phase of construction. It is expected that both Company and Contractor workers will be deployed across the mini-grid construction site at any given time. Prado Power has a dedicated HR department led by a HR Manager.
HR Policies and Procedures. Prado Power implements labor practices consistent with the national labor code applicable to all employees. The HR processes are spread out in many documents including HR policy, Employee Handbook and Code of Conduct with associated procedures outlining the principles, commitments and guidelines in relation to labor recruitment and management, applicable across all operations and for all employees and contractors. Furthermore, the company has a Gender Policy with gender action plan that sets an ambitious target of achieving gender equality within the workforce by 2030. The company prioritizes internal promotions and conducts performance evaluations to inform compensation reviews. Job vacancies are advertised both internally and externally to ensure a fair and inclusive recruitment process. At the level of the local communities, the Community Power Committee (CPC) is directly involved in the selection of local workforce. Going forward, Prado Power will formalize and implement a comprehensive HR manual that establishes formal policies on (i) freedom of association and collective bargaining, (ii) retrenchment, (iii) workers accommodation; (iv) grievance mechanisms, (v) third party labor audits in compliance with Nigerian labor law, IFC PS 2 and DARES requirements (ESAP #4).
Working Conditions and Terms of Employment. Prado Power’s HR process encourages non-discrimination and equal opportunity for its staff with 41% of female within its administration and management. Each worker receives a written contract that outlines the working conditions and terms of employment including salary, working hours, probations, and benefits. Work is performed in one shift of 8 hours per day and 40 hours a week. Overtime work is monitored for each worker to keep it within regulatory limits and paid accordingly. Also, all employees are enrolled in the mandatory social insurance scheme and salaries are paid regularly fortnightly. Prado Power does not prohibit the freedom to associate and workers right to form and join workers organization.
Workers Grievance Mechanism: Prado Power has developed a grievance mechanism for its internal workforce. It starts informally with the immediate manager, then progresses to a formal written process if unresolved. The formal process includes the right to accompaniment, confidentiality, thorough documentation, written communication of outcomes, and an impartial appeal process led by a senior manager. Additionally, it covers grievances raised during disciplinary actions. Going forward, Prado Power will update its grievance mechanism (ref. ESAP #4) and render it accessible to all workers, including third-party workers, and will ensure that the updated GM will; a) allow anonymous GBVH complaints, b) be communicated in local languages at each mini-grid, and c) feed aggregated data into Board-level E&S dashboards (ref. ESAP #1).
Occupational Health and Safety; Prado Power has developed and is implementing an OHS management plan aligned with relevant local regulatory requirements. It outlines the company’s commitment to providing a safe and healthy work environment through structured policies, legal compliance, hazard identification, training, emergency preparedness, and performance monitoring. Also, the OHS plan includes procedures for risk assessment, corrective actions, audits, and safety integration into operations. Use of personal protective equipment is mandatory for site activities and trained First Aiders are deployed on site during construction and operations. Going forward, Prado Power will update its OHS management plan (ref ESAP #3) to include i) standard templates for method statements, risk assessments for manual work, work at height, use of ladders and ensure these are well understood by all relevant staff and adequately implemented at the project sites; ii) procedures for electrical safety and for safe installation and servicing of power distribution network in compliance with WBG General EHS Guidelines and EHS Guidelines for Electric Power Transmission and Distribution, and train all relevant workers on implementation of these procedures, and; iii) governance procedure for site safety.
Workers Engaged by Third-Party: One contractor is currently engaged by Prado Power for its mini-grid sites under construction at the SL Farms in Kwali not part of the current investment. At peak construction, this contractor employed 30 workers. Similar workers numbers are expected for the IFC financed activities. Prado Power has developed a Contractor Management Plan which outlines the procedures for selecting, onboarding, managing, and monitoring contractors. It emphasizes compliance with Prado Power’s E&S expectations for risk management, incident reporting, performance evaluation and relevant health and safety regulatory requirements. Also, Prado Power has developed an Anti-Bribery and Anti-Corruption Policy that establishes a zero-tolerance stance toward unethical practices and applies to all employees, contractors, and suppliers.
As part of this IFC investment, Prado Power will update its Contractor Management Plan (ref ESAP#2) to i) include audits of labor conditions beyond health and safety compliance to areas including monitoring of periodic working hours, wages, or benefits; and requirement for risk assessments of vulnerable groups including migrant workers and women; and ii) ensure that the E&S requirements of the Contractor Management Plan translated into contract include requirement for labour rights clauses in all contracts (wages, hours, freedom of association) and periodic spot interviews with contractor workforce and (iii) require Contractors to implement a separate GM and / or cascade its GM to contractor workers.
PS 3: Resources Efficiency and Pollution Prevention
Solar mini-grid projects are not expected to materially consume key resources (e.g., energy, water) or result in significant emissions or pollution during operations. EHS risks are largely associated with the construction phase and are typically site-specific, short-term in nature, and managed through the implementation of the ESMPs.
Resources Efficiency: Prado Power’s core business model is centered on the development and operation of solar mini-grid projects to provide clean, renewable energy to underserved and off-grid communities. As such, the company inherently promotes energy efficiency through its projects and operations. For interconnected grids, the company sources electricity from the national grid and ensures minimal air pollution from stationary generators through advanced technologies.
During construction, water usage is restricted to domestic purposes, concrete mixing and occasional dust control meanwhile during operations more water is used especially during the dry season for cleaning of the solar panels to improve their efficiency. Water is sourced from ground water wells or boreholes developed at mini-grid sites. Prado Power has developed a Water Management Plan (WMP) which focuses on responsible water use and conservation relying on strategies like water-efficient infrastructure design, using high-efficiency plumbing fixtures, and implementing leak detection and maintenance programs. Also, the WMP encourages the use of alternative water sources such as rainwater and monitoring of water use to improve efficiency. Going Forward, Prado Power will include tracking of energy and water use and their efficiencies as KPI in its E&S performance monitoring (ref. ESAP #1) requirements.
Air emissions and Greenhouse Gases: Solar mini-grid construction activities and transportation associated with the projects may generate dust and vehicle emissions, which will be managed within the site HSE management plans. Greenhouse gas emissions (“GHG”) from the project during construction are predominantly associated with the transport of project components and on-site equipment and machinery. During the operation phase, routine maintenance activities are expected to generate minimal air emissions during. Prado Power will monitor its fuel usage for its back-up generators and transportation as part of its E&S monitoring requirements. Prado Power’s GHG emissions are expected to be well below 25,000 tones CO2 equivalent.
Waste Management: Prado Power’s activities will generate typical construction non-hazardous waste like wooden boxes, cardboard wrappings, plastic, electric cables, domestic waste and hazardous waste like spent battery, damaged solar PV cells and hydrocarbon contaminated waste. Also, wastewater will be generated from site toilets and from washing of panels during operations. Prado Power has developed a Waste Management Plan which encompasses both general and electronic waste, outlining procedures for collection, storage, segregation, and disposal in line with national regulations and the waste management hierarchy. The plan emphasizes minimization, reuse, and recycling, with Contractors required to follow the waste hierarchy during construction. For operations, general and hazardous waste is collected in separate sealed containers and disposed of using authorized service providers. E-waste management adheres to the waste hierarchy and including detailed procedures for labelling, segregation, and tracking. Going forward, Prado Power will ensure all workers are trained in waste management processes including segregation at source and will track all waste generated from cradle to grave and include waste numerical data in the E&S performance monitoring (ref. ESAP#1) consistent with IFC PS3 requirements and WBG EHS Guidelines.
Hazardous materials handling and Waste: Hazardous materials handled at the solar mini-grid sites include batteries (e.g., lead-acid or lithium-ion), electronic parts (e-waste), and diesel fuel. Prado Power has developed a Hazardous Materials Management Plan which details protocols for handling hazardous substances, including hazard identification, labeling, classification, storage, and disposal, ensuring compliance with global standards. Responsibilities are assigned across departments, with significant emphasis on training, emergency preparedness, and personal protective measures. The plan mandates annual training for personnel and detailed record-keeping to maintain safety and regulatory compliance. Going forward, Prado Power, will i) maintain a hazardous material inventory, ii) train the site workers on hazardous materials handling and emergency response; iii) deploy sealable hazardous waste skips at all Project sites; (iv) adopt a bar code or app based inventory that tracks electrical/ battery serial numbers through end of life take back and v) implement a waste transfer and disposal process to ensure compliance with its ESMS, Waste Management Plan (ref. ESAP #1 & ESAP #2), national regulatory requirements and IFC PS3 requirements.
PS 4: Community Health, Safety and Security
Road Safety & Traffic Management: Prado Power’s mini-grid projects incorporates several measures to ensure the health and safety of surrounding communities during both construction and operation phases including; (i) health and safety risk assessments for each site; (ii) community awareness campaigns in local languages to inform local residents about the project, potential risks, and safety precautions; (iii) installation of safety signage and physical barriers around work zones to prevent unauthorized access; and, (iv) Emergency Response Plan tailored to local conditions. Prado Power manages traffic risks associated with the transportation of its mini-grid components, equipment and staff to and from site by implementing several key measures including mandatory driver training and certification with training materials translated into local languages and consider pictograms to ensure accessibility, regular vehicle maintenance and inspections to prevent mechanical failures, and the enforcement of speed limits through communities and use of designated transport routes to reduce the risk of accidents. Going forward, Prado Power will incorporate site specific transport risk assessment template containing requirements for driver fatigue management and periodic review of accident statistics (even if zero) in the E&S Pre-clearance Procedure (ref. ESAP #2).
Security Management: Prado Power’s Site Security Plan includes physical, electronic, and cyber security measures, access control, emergency contacts, and training protocols as well as a Security Code of Conduct which highlights respect for human rights, proportional use of force, community engagement, and non-interference in local affairs. In line with current practices each of the IFC-financed mini-grid sites will be fenced off and provided with a single controlled access point as well as locally recruited unarmed security agents. Prado Power will (i) complete a site-specific security risk assessment per the template in the Pre-Clearance Procedure (ref ESAP #2) and will provide training (ref ESAP #1) to all security agents deployed at the different mini-grid sites including on Ethical Conduct and the Voluntary Principles on Security and Human Rights (VPSHR). consistent with principles of IFC PS 4, particularly in promoting respectful and culturally sensitive security practices.
