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
Environmental and Social Policy and Management System
StarTimes Energy has an E&S Management System (ESMS) that will be updated to follow the guidelines of the DARES Platform E&S Management Framework (ESMF), which has been approved by the World Bank. The DARES ESMF serves as the core E&S assessment and management tool for all projects under the program, providing guidance for E&S performance management during the planning, construction, and operation phases in line with applicable World Bank E&S Standards (ESS). The ESMF is supported by separate instruments, including a Resettlement Policy Framework (RPF), Labor Management Plan (LMP), and Stakeholder Engagement Plan (SEP). As part of this financing, StarTimes Energy will update its existing ESMS to ensure full alignment with the DARES ESMF and IFC Performance Standards. This will include (i) having the corporate E&S policy formally signed by senior management to ensure leadership endorsement; (ii) incorporating DARES-provided tools, such as screening and exclusion checklists and E&S risk assessment templates; (iii) updating its management programs to align with IFC PS and national legislation relevant to StarTimes Energy’ operations; and (iv) developing an E&S monitoring and reporting procedure with associated Key Performance Indicators (KPIs) to assess the effectiveness of risk mitigation (ESAP #1).
Identification of Risks and Impacts
StarTimes Energy, under the DARES program, is committed to screen all potential mini-grid sites for E&S risks and impacts and exclude all sites that fall within the exclusion criteria. Sites that fall in the exclusion criteria includes projects with footprint: located within protected areas (e.g., national parks, conservation areas, forest reserves); internationally recognized areas; critical natural habitats and where mini grid construction will cause significant degradation of natural habitats (e.g. mangroves); hosting cultural heritage or sacred sites; under active dispute or litigation; located in environmentally high-risk areas (flood-prone, erosion-prone); belonging to vulnerable groups; or serving as a primary source of livelihood. StarTimes Energy conducts an initial E&S screening followed by risk categorization, which determines the scope and details required for E&S studies. StarTimes Energy has prepared and submitted Environmental and Social Management Plans (ESMPs) for the initial 50 mini-grid sites located in Adamawa, Benue, Katsina, Kogi, Nasarawa, and Sokoto States to the Federal Ministry of Environment. Approvals from the ministry is currently pending. These ESMPs outline environmental and social risks associated with land acquisition, vegetation clearance, erosion, pollution, occupational and community health and safety issues, and management of electronic and battery waste, along with mitigation measures. The low voltage distribution lines are designed to run along the village roads, and their design is compliant with the national technical requirements, hence pose low E&S risk. Going forward, as per ESAP #1, StarTimes Energy will develop a site selection procedure to align with the DARES platform RPF and adheres to the exclusion criteria outlined above.
Land Acquisition
StarTimes Energy purchased all 95 mini grid sites to be financed by IFC through willing buyer-willing seller agreements. No physical or economic displacement occurred for the purchased sites and no outstanding community grievances were reported related to the land purchase process. There will be no additional land acquisition for the distribution lines, which will be laid along the existing road servitudes. Similarly, for all future sites to be considered for the mini-grid project, StarTimes Energy 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.
Management Programs
To manage E&S risks and impacts associated with the mini-grid projects, StarTimes Energy has developed policies, procedures and plans on HSE, training, gender equality and inclusion, and grievance redress mechanism within the framework of its ESMS. Going forward, as per ESAP #1, StarTimes Energy will update its management programs with the following documents: corporate E&S risk register, emergency preparedness and response plan; supply chain code of conduct; waste management plan, hazardous material management plan; stakeholder engagement plan; traffic management plan; security management plan; pre-clearance checklist, chance find procedure; E&S / OHS monitoring and reporting procedure, including key performance indicators (KPIs).
Organizational Capacity and Competency
StarTimes Energy has a corporate HSE director, who covers all mini-grid sites, providing technical HSE support while the site managers oversee E&S performance on site. The board of directors provide strategic and oversight role in E&S governance, ensuring that environmental and social risks are properly managed and aligned with institutional goals. Considering the expected surge in sites under construction due to this program and the expected increase in the scope of E&S risk oversight on site contractors, StarTimes Energy will appoint HSE officers at State level to oversee the update and implementation of ESMS and reporting of E&S performance to senior management and train all site managers on E&S risk management to ensure E&S risks are adequately managed (ESAP #2).
Emergency Preparedness and Response
StarTimes Energy does not have a standalone emergency preparedness and response plan (EPRP), however the ESMPs, include sections on “Environmental Emergency Preparedness and Response”. These sections outline emergency scenarios such as fires, explosions, rainstorms, chemical and oil spills, and equipment failures. During the site visit, fire extinguishers, smoke detectors, and first aid boxes were present. As part of ESAP #1, StarTimes Energy will develop and implement project site-specific EPRP that sets out principles and approaches to emergency response planning and management for construction and operational phases. The EPRP will include (i) potential emergency scenarios such as medical emergencies, electrical hazards, and security emergencies; (ii) an emergency response team with roles and responsibilities (as well as their back-up); (iii) operational requirements, including engagement with local emergency services in planning drills; (iv) address coordination with neighbouring facilities and communities (especially with regards to collapse of distribution poles); (v) provision and display of signages, emergency response contact numbers and instructions at all mini-grid sites; (vi) planning for climate-related events - heavy rains, floods and heatwaves; (vii) regular monitoring, inspection and maintenance of emergency equipment; (viii) reporting, performance evaluation, and determination of training needs and schedules. All employees and contractors will receive training on emergency response.
Monitoring and Review
The StarTimes Energy ESMPs include regular monitoring of parameters such as noise, vibration, air quality, and hazardous materials during construction and operational phases. As per ESAP #1, StarTimes Energy will develop and implement an E&S / OHS monitoring and reporting procedure with defined KPIs including, OHS leading and lagging indicators (incident records, near miss, hazard reporting, drills and other workplace monitoring data), resource (water and energy) usage and efficiency, pollution prevention and control (air emissions, noise, effluents, solid/hazardous waste management) for both construction and operations phases to assess the effectiveness of the mitigation measures. 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 a reporting structure that extends from the monitoring site up to the Board of Directors.
PS2- Labor and working conditions
StarTimes Energy currently has 135 employees, 42% of whom were females. During mini-grid site construction, workers are recruited from the local communities by contractors and their numbers are based on workforce needs at each phase of construction. StarTimes Energy assigns four staff members at each mini-grid site during operations: a site manager, a caretaker, and two security personnel. When all mini-grids go operational, StarTimes Energy is projected to employ 620 people.
Human Resources (HR) Policies and Procedures
StarTimes Energy has policies and procedures on human resources and labour management, which outline labour management policies under the DARES project, aligned with IFC PS2 and Nigeria’s labour law. These procedures mandate non-discrimination, clear employment terms, and emphasize safe working conditions, while prohibiting child and forced labour. Workers are entitled to grievance redress, freedom of association, and protection from sexual exploitation, abuse and harassment (SEAH) and gender-based violence (GBV). The procedures include transparent recruitment, age verification, and occupational health and safety measures. Labour influx is managed through local hiring and community engagement, and any incidents resolved promptly. These policies ensure ethical, safe, and inclusive labour practices throughout the project from planning and construction through to operations.
Working Conditions and Terms of Employment
All project workers receive written contracts with clearly defined terms, including oral explanations in the language they understand. Employment conditions comply with national labour laws and cover wages, hours, benefits, and termination procedures. Workers are entitled to regular pay, with lawful deductions (statutory social security) clearly communicated. Adequate facilities such as hygiene areas, rest zones, and ergonomic workspaces are provided. Special provisions are made for pregnant women, including maternity leave as per the national law. Additionally, StarTimes Energy has a policy on gender equality and inclusion committing to non-discrimination and equal opportunity across all employment practices.
Workers organizations
StarTimes Energy employees are not currently part of a labor union. However, StarTimes Energy has documented its commitment to freedom of association and collective bargaining in its labor management policy and procedure.
Grievance Mechanism: StarTimes Energy has a grievance mechanism which entails fair and prompt resolution of workplace and community-related issues. The grievance procedure follows a multi-level approach and includes confidentiality, and fairness but does not address sexual exploitation, abuse and harassment (SEAH). Going forward, StarTimes Energy will update this grievance redress mechanism and align it with IFC PS. This update will include a segregated process to managing GBV/SEAH complaints, allow confidential and anonymous reporting, define timelines for action, include an anti-retaliation statement, and extend coverage to workers employed by third parties (ESAP #3).
Occupational, Health and Safety (OHS)
StarTimes Energy has an Occupational Health and Safety (OHS) policy. However, StarTimes Energy will develop an OHS plan aligned with IFC PS2 and WB General Guidelines requirements which will include: i) procedures 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; ii) implementation of heat stress management protocols, provision of drinking water to workers, alternative work schedules during high temperatures, and the provision of shaded/cooled breaks; and iii) ensure that the Health and Safety Management plan and all implementation procedures and templates are retained at each site (virtually or physically) for use by site workers. These procedures will be implemented at all project sites, supported by regular training and communication to all employees (ESAP #4).
Contractor Management
As per ESAP #1, StarTimes Energy will develop and implement a contractor management plan, in line with IFC PSs, applicable to all contractors working on construction, operation and maintenance activities of the project, and maintain oversight on contractors’ performance. The contractor management plan will include clauses on commitment to compliance with labor and HSE standards aligned with StarTimes Energy policies, the right for StarTimes Energy to audit the operator’s labor practices and set up regular meetings with contractors to review E&S / OHS performance as well as labor aspects, discuss non-compliance issues and promptly address them with corrective actions.
Supply Chain
StarTimes Energy procures solar panels, batteries, and associated equipment from ‘Tier 1’ suppliers and have low leverage on influencing the suppliers’ E&S policies. To safeguard against unfair labor and OHS practices in the PV solar supply chain, StarTimes Energy as per ESAP #1 will: i) develop and implement a supply chain code of conduct to include: i) prohibiting forced labor and containing other relevant EHS requirements, including a supplier registration/evaluation sheet that outlines these labor and HSE provisions; ii) contractual clauses requiring suppliers’ compliance with the code of conduct; iii) a verification process to ensure new suppliers have the policies and procedures in place to meet requirements of the code of conduct; and iv) a formal process for supplier engagement, remedy or disengagement in case of unresolved non-compliances.
PS3-Resource 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.
Resource efficiency: Water resource needs during construction and operations will be limited to domestic needs and for cleaning of panels and will be sourced from onsite water wells, as is the case for existing sites. Due to the small size of the solar plants, the volume of water requirement for cleaning is expected to be small and will not affect community water supplies. However, StarTimes Energy will install flow meters to measure consumption from each well and report as KPI in its E&S performance monitoring requirement.
Air emissions and Greenhouse Gases
The operations at the solar mini-grid sites are expected to produce minimal air emissions during the operational phase. However, site construction activities and transportation associated with the projects may generate dust and vehicle emissions, which will be managed within the site ESMPs. Greenhouse gas emissions (“GHG”) from the project during construction are predominantly associated with the transport of project components and on-site equipment and machinery. Immaterial GHG emissions are expected during site operations, mainly from occasionally used back-up generators. Annual GHG emissions are expected to be less than 25,000 tons of CO2 equivalent (tCO2eq/year).
Waste Management
StarTimes Energy has a battery recycling agreement with the Alliance for Responsible Battery Recycling (ARBR). ARBR collects used batteries directly from end-users or renewable energy operators and refunds recycling fees deposited depending on the type, size, or chemistry of the battery for recycling (currently available only for Lead Acid Batteries). ARBR issues annual certificates, and StarTimes Energy earns carbon credits for sustainability efforts in used battery management. StarTimes Energy generates other hazardous waste streams such as damaged PV modules and electronics, used oil, and solvents which are stored in clearly labeled, leak-proof containers within a designated hazardous waste storage area. These wastes are subsequently collected by government-licensed third-party waste management facilities. Going forward, as per ESAP #1 StarTimes Energy will develop a waste management plan and document waste storage, transfer and disposal process to ensure compliance with the national regulatory requirements and IFC PS3. Additionally, StarTimes Energy will adopt a bar code or app based inventory that tracks electrical / battery serial numbers through end of life take back. Wastewater from the washing of solar panels drains into the soils on-site.
Hazardous Materials Management
Hazardous materials handled at the solar mini-grid sites include batteries (e.g., lithium-ion), electronic parts (e-waste), and diesel fuel. As per ESAP#1 and as part of ESMS improvement, StarTimes Energy will develop a hazardous material management plan with specific procedures and work instructions for managing hazardous materials including storage, handling and use of the chemicals as well as response to any spills. Training on these procedures will be provided to all employees at all facilities during the workers’ induction session and on a regular basis thereafter.
PS4-Community Health, Safety and Security
Road Safety & Traffic Management
The transportation of mini-grid components and equipment to the site and staff movements to and from site represents the key safety risk in relation to staff, other road users and communities adjacent to the roads being used. As per ESAP #1 StarTimes Energy will develop a traffic management plan which: i) outlines procedures and protocols for site access, traffic routing, and management, emphasizing the safety of all road users; ii) require vehicles to be equipped with in-vehicle monitoring systems to track speed limits and driver behavior, thereby mitigating the risk of accidents; iii) include requirement for driver fatigue management and periodic review of accident statistics; iv) emphasize regular vehicle maintenance and inspections to prevent mechanical failures, and the enforcement of speed limits through communities and use of designated routes to reduce the risk of accidents; v) emphasize community awareness campaigns to inform local residents about the project, potential risks, and safety precautions, with materials translated into local languages to ensure accessibility; and vi) include installation of safety signage and physical barriers around work zones to prevent unauthorized access. This plan will be adopted and implemented at all project sites.
Security Management
Each mini-grid site is fenced off with a single controlled access point, and access control and security are provided by unarmed, locally employed watchmen. This will be the case for all future sites. As per ESAP #1, StarTimes Energy will undertake a security risk assessment of all its project sites and develop a security management plan to support the safe and secure development and operations of the project, in line with IFC PS4 requirements and provide trainings on UN Voluntary Principles on Security and Human Rights including on SEAH; life and fire safety emergency trainings; and engagement practices with surrounding communities.
