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 Impact
CVA has developed an ESMS including processes aligned with IFC PS1 requirements for its airport operations. The ESMS incorporates policy statements that align with VINCI’s corporate E&S policy framework including AIRPACT and details CVA’s approach to identification and mitigation of project risks and impacts, labor and working conditions, OHS, Contractor management, and stakeholder engagement. As part of IFC financing of Phase 1-B, CVA will update its ESMS to cover Phase 1-B risks and impacts with the following elements: Update its ESMS to cover Phase 1-B risks and impacts with the following elements: (i) coordination procedure between construction and operating entities; (ii) coordination procedure between different concessionaires operating at the airport with overlapping E&S issues like waste; (iii) Standard Operational Procedures (SOPs) for operating and maintaining new plants like WWTP, Incinerators, Oil water separators, etc; (iv) Supplier Code of Conduct and Supply Chain Procedure; (v) Outstanding recommendations from 2020 and 2024 Phase II Environmental Site Assessment (ESA), (vi) Outstanding Noise Management Plan (NMP) roadmap actions; and, (vii) E&S monitoring/reporting procedures aligned with VINCI E&S commitments and including Key Performance Indicators (KPIs), ground contamination, noise, ambient air quality linked to construction facilities on site and incinerators as per the thresholds defined in the WBG EHS Guidelines and greenhouse gas emissions (GHG) reporting (as per VINCI E&S reporting commitments) for both construction and operations activities (ESAP#1).
CVA developed an E&S Screening and Assessment Procedure and completed E&S Strategic Assessment commensurate to the scope of Phase 1-A works in line with IFC PSs. As per the requirements of the Cabo Verdean environmental legislation (Law No. 86/IV/93 recently amended by Law No. 23/X/2023 of 18 April 2023) and other relevant statutory requirements, CVA has conducted Simplified Environmental Studies (SES) (Estudo Ambiental Simplificado in Portuguese) for the international airports and E&S Management Plans (ESMPs) for the aerodromes as scoped out by the National Directorate of Environment (DNA). The SES (Local ESAI) identifies key impacts associated with the project, including waste, noise, air pollution, water, and health and safety impacts management. Going forward CVA will; (i) obtain the certificate of conformity from the relevant regulatory authority for the local ESIA, (ii) complement the local ESIA to meet IFC PSs with (a) robust noise baseline data collection, (b) assessment of physical climate risk on airport operations and infrastructure, and any climate risks that may be exacerbated by the project and affect the communities (e.g. floods, water availability, winds etc.), (c) cultural heritage assessment of BVC airport expansion area conducted by a qualified specialist; and, (d) a cumulative impact assessment of the international traffic and associated tourism on the freshwater resources and waste management infrastructure in the area of influence of the airports aligned with IFC PS1 requirements (ESAP#2).
The ESIA for the Phase 1-B works has associated ESMPs for both the international airports and aerodromes. These airports and aerodromes specific ESMPs outline mitigation and monitoring measures across key domains, including climate, soil, hazards, energy and waste, socioeconomic factors, cultural heritage, water, biodiversity, landscape, air quality, and noise. While the ESMP details responsibilities for implementation and monitoring by CVA and the EPC Contractor, the measures prescribed remain largely generic and descriptive, lacking the necessary specificity to ensure effective execution. Going Forward, CVA will (i) update the airports/aerodromes specific ESMPs by incorporating more detailed, actionable, and context-specific provisions to adequately address and manage the identified E&S impacts throughout the project life cycle aligned with IFC PS1 and (ii) require the Phase 1-B EPC to develop and implement a construction ESMP (CESMP) that is aligned with the ESMPs and If the Phase 1-A Consortium is awarded Phase1-B works, update the Phase 1-A CEMP to incorporate mitigation measures that address additional risks and impacts associated with Phase 1-B scope of work and ESMPs (ESAP #3).
The overall CVA management structure includes non-operational entities responsible for oversight including the Audit Board, the Board of Directors and the Certified Auditor who reports to the CVA General Assembly. The Department of Quality, Sustainability and Environment (QSE) seats under the Engineering Management Department. Currently, CVA has a E&S Manager on term contract supported by three environmental specialists and one HSE representative who also have other functions at each of the international airports. An external consultant has also been appointed to monitor and report on the E&S performance of Phase 1-A construction activities. Going forward, CVA will strengthen its organizational capacity by: (i) deploying a clear, centralized structure for managing and reporting E&S performance across the airports; (ii) recruiting experienced personnel for open positions in its E&S organogram including E&S Supervisors at each international airport to monitor and report on E&S performance to senior management, as well as stakeholder engagement; and, (iii) mandating that all EPC Contractors deploy experienced E&S representatives (ESAP#4).
Also, CVA will (i) provide adequate training to all direct employees commensurate with their level of risk management responsibility, including but not limited to a) Company EHS policies, plan and procedures; b) applicable local EHS regulations and c) IFC PSs and WBG General EHS Guidelines and all relevant sector specific guidelines; (ii) mandate the same level of training for the EPC Contractor and other subcontractors involved in Phase 1-B construction activities; and, (iii) ensure that all sub-contractors implement CVA’s training requirements. (ESAP #5).
CVA has developed and implemented specific emergency preparedness and response plans for each of its airports. The company has trained and certified firefighters and firefighting equipment commensurate to the level of risk and classification ascribed to the different airports and aerodromes. The arrangement at international airports as typified by the set-up at RAI includes two operational fire trucks adequate for category 7 classification and one spare truck for back-up, 25 trained firefighters who work in sets of 4 per shift of 6 hours with one team rotating. Also, each international airport has a stock of fire extinguishers and an ambulance amongst its firefighting resources. Finally, each airport has a firefighting training center and conducts weekly fire drills. Going forward, CVA will include a KPI (ref. ESAP#1) related to emergency drills and will document and share lessons learned from each drill.
CVA has developed an E&S monitoring plan based on VINCI commitments, which is aligned with IFC PSs, relevant WBG EHS Guidelines, as well as national environmental regulatory requirements. CVA’s ongoing monitoring relies heavily on the Phase 1-A external E&S consultants’ scope. Going forward, CVA will implement its E&S monitoring and reporting plan (ref. ESAP#1) to report on KPIs, OHS leading and lagging indicators (incident records, near miss, hazard reporting 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 activities.
PS2: Labor and Working Conditions
CVA currently has 348 direct employees including 32 new hires in 2024 and 38 in 2025. Women represent 29% of the total workforce. Also, about 323 workers are engaged by security provider and 513 by the ground handling service provider at different airports. Additionally, 76 EPC Consortium staff and 306 subcontractor workers are deployed across seven airports for the Phase 1-A works expected to be finalized by October 2025. CVA has a dedicated Human Resources (HR) department led by an HR Manager.
CVA has developed HR policies and procedures in relation to its HR management which follow VINCI’s Guide to Human Rights and together with associated procedures outline the principles, commitments and guidelines in relation to labor, applicable across all operations and subsidiaries and for all employees, sub-contractors and business partners. CVA’s HR process is enforced through the Code of Ethics and Employee handbook accessible to all staff. The company prioritizes internal promotions and conducts performance evaluations to inform compensation reviews. Job vacancies are advertised both internally and within the local community to ensure a fair and inclusive recruitment process. As part of this IFC investment, CVA will sensitize its workforce and contractors including migrant workers, and service providers about HR procedures and grievance mechanisms (ESAP #6).
CVA’s labor and working conditions reflect the provisions of the Cape Verdean Labor Code. The HR process covers key aspects of labor and working conditions, including recruitment, equal opportunity, onboarding, working hours, leave, training, resignation and mandates strict adherence to the Internal Regulations and Employee Code of Conduct. CVA’s HR procedure manual includes zero tolerance to sexual exploitation and harassment. The company complies with work schedules mandated by the national labor law. Where work hours go beyond the stipulated 8-hours but within limits set by the national labor law, overtime is paid at the appropriate rate as stipulated by statutory requirements.
CVA respects the rights of workers to join unions or form worker’s associations of their choosing. Currently, out of the 348 direct employees of CVA, 226 are union members. As part of the onboarding and induction process, new employees are sensitized about the union’s role and offered the possibility of affiliation. Three unions are associated with CVA: SINTAP (Union of Transport, Communications and Internal Administration); SITTHUR (Transport, Hospitality, and Tourism Union); and SIMETEC (Metalwork, Transport, Communications and Tourism Union in São Vicente Island). Third-party workers also join unions, but rights negotiations are the responsibility of the third-party companies. Most third-party workers are affiliated with SICOTUR – the Union for Industry, Commerce, and Tourism. The union presidents meet and speak directly with the employees once every quarter and salary negotiations are conducted at the end of the first quarter of each year.
CVA has established a grievance redress mechanism (GRM) for its employees which allows workers to voice their concerns and complaints either directly to the HR or through union representatives to the company management. As part of this IFC investment, CVA will sensitize its workforce including third-party workers through inductions, notice boards and online platforms on the provisions of its GRM including (i) roles, responsibilities, action timelines and a system to log, track and report grievances; (ii) submission of anonymous grievances and specific channels for gender-based violence and sexual harassment (GBVSH) complaints(ref. ESAP #5). Also, CVA will provide specialized training for staff handling GBVSH complaints as per the requirements of IFC PS2.
CVA does not support any form of child or forced labor and does not employ anyone under 18 years of age including interns. Interns are sourced from universities, provided an internship agreement and adequate safety training before being granted access to the worksite. Contractor employees are trained for their respective tasks and provided with suitable protective equipment prior to being deployed on site.
CVA prioritizes OHS and has adopted VINCI’s OHS Management System which includes: i) an OHS Policy; ii) a procedure for health and safety risk assessments in relation to activities and tasks; iii) a risk register; iv) hazard controls and preventive protocols to manage health and safety risks; v) a work-related injury recording procedure, using the internal monitoring tool (BaSAFE) for corporate level reporting; and vi) an OHS training program for to all airport workers. All personnel undergo safety inductions upon mobilization and job specific trainings, followed by general weekly safety meetings and specific daily toolbox talks. Contractors implements a safe system of work with permits issued and closed for all tasks and each activity begins with a risk assessment with associated controls. Workers are required to always wear appropriate PPE. Two lost time injuries and zero fatality have been reported since inception of the Phase 1-A construction program in 2023.
CVA utilizes an important number of third-party service providers including for security, cleaning and several other terminal passengers experience services. CVA developed an EPC Contractor Monitoring Procedure with E&S requirements applicable to the works performed by contractors and service providers. However, the Contractor Management system focuses on health and safety but does not fully address broader labor and HR requirements needed for alignment with PS2. Going forward, CVA will conduct an audit of its relevant third-party service providers based on their scope of activity and risks, to determine compliance with CVA procedures and IFC PSs requirements (ESAP #7).
PS3: Resource Efficiency and Pollution Prevention
CVA currently utilizes electricity sourced from the national grid for its airports. Also, back-up power generation plants exist at the international airports and aerodromes. As part of phase 1-A investments CVA has installed solar systems including a solar roof at the car port in RAI constituted by up to 500 solar panels connected to the airport electricity network, and a solar park at BVC with about 3000 panels. The newly developed solar park at RAI airport will supply 25% of its energy needs during daytime operations, while BVC airport will be powered entirely by solar energy. CVA aims to reach 40% renewable energy in line with the VINCI 2040 program. Energy efficiency management at various airports involves switching light bulbs to LED and increasing solar in CVA’s energy mix at all 4 international airports.
CVA aims to reuse 50% of its water and waste and will feature a circular economy. Water used at the airports is obtained from public or municipal sources and stored in tanks at the respective airports. In April 2024, CVA completed a review of its water storage facilities at each of the seven airports. Water use efficiency measures are built into the design of the wastewater treatment plants that form part of Phase 1-B installations and require that all wastewaters be collected, treated and re-used. Going forward, CVA will implement any additional water conservation measures (ref. ESAP #2) and updated airport/aerodrome specific ESMPs (ref. ESAP #3).
The AIRPACT Policy commits to achieving Level 1 (Mapping) Carbon Accreditation under the Airports Council International (ACI) Carbon Accreditation scheme for all airports in VINCI’s portfolio within three years, followed by becoming carbon neutral by 2030, and net zero by the end of the concession period or by 2050 whichever comes earlier. Based on data provided by CVA for 2024, Scope 1 (1,231.97 tCO2e) and Scope 2 (1,900.87 tCO2e) GHG emissions associated with the project were below 25,000 tons of CO2 equivalence per year. As per ESAP #1 CVA will still report on its direct and indirect (Scope 1 and Scope 2) GHG emissions associated with airport operations in accordance with VINCI E&S reporting commitments.
The day-to-day operations of the airport generate limited ambient air emissions typically associated with landing and take-off of aircrafts and movement of ground vehicles and trucks. Phase 1-B activities will include extension of the BVC runway up to 400m and related earth works will constitute a source of dust emissions during construction. Also, the incinerators included in the Phase 1-B works will generate additional point source emission. As per ESAP #1, CVA will include ambient air quality monitoring requirements at facility boundaries and sensitive receptors and analyzed for any spikes in pollutant levels which may be attributed to its activities including applicable regulatory requirements for particulate matter; PM 2.5 and PM10 as well as stack emission including NOx and SOx for the incinerators in alignment with WBG EHS Guidelines.
Aircraft landing and taking off are the main source of operational noise pollution. The SID airport in SAL island is the busiest and supports an average of 20 flights of different categories per day. CVA has developed a Noise Management Plan (NMP) that includes a noise model based on pre-determined noise maps. The NMP included a Roadmap for improvement, which required update of the noise models. Going forward, CVA will collect adequate noise baseline data (ref. ESAP #2) to enhance the noise maps, strengthen related noise models and improve the overall noise risk management approach detailed in the NMP as well as implement all noise management measures outlined in the NMP, CIA and airport/aerodrome specific ESMPs consistent with IFC PS3 requirements (ref. ESAP #1). Also, noise monitoring will be conducted regularly at nearby receptors as part of the ongoing E&S monitoring program and any community complaints on noise addressed via the external grievance mechanism implemented at part of the ESMS.
In 2020 VINCI commissioned Phase II Environmental Site Assessment (ESA) for the areas of potential contamination identified at the SID, RAI and VXE. The conclusions of the assessment did not include in a requirement to excavate and remediate soil. CVA has developed remediation plans for each facility and has installed surface water drainage systems, including oil-water separators (OWS), at all international airports (SID, RAI, and VXE) to enhance environmental protection. The OWS are designed according to Standard EN858 - Part 2 and treat 10% of the calculated flow. Aprons for aircraft parking and refuelling are drained to OWSs which have solar power mounted alert systems. Water from the separators is drained through to outlets with weirs and rock riprap to prevent scouring during heavy rainfall. Going forward, CVA will monitor (ref ESAP #1) and test for ground contamination upon decommissioning of any underground hydrocarbon storage tanks.
The international airports have wastewater treatment processes with varying degrees of operability and the aerodromes use septic tanks. RAI has the lone functional WWTP with a designed capacity of 250m3 treatment per day, but currently the inflow is about 15m3 a day and up to 35m3 during peak periods in August. Currently, treated water is tested daily and discharged with plans to improve the treatment process and further test for legionella to determine if the treated water can be re-used. As part of Phase 1-B works, CVA will install new WWTPs at SID, BVC and VXE, upgrade the existing WWTP at RAI and install new septic tank systems at the remaining airports. The WWTPs would be designed to treat wastewater such that it can be reused in flushing toilets and other operations at the airports like fire drills. As per ESAP #1, CVA will develop and implement SOPs for all the operations, maintenance and E&S monitoring of all the plants financed as part of the phase 1-A and Phase 1-B projects.
CVA generates waste in varying quantities at its respective airports, and this waste is currently disposed at through poorly managed municipal waste facilities by authorized waste management service providers. Inert and hazardous waste generated as part of Phase 1-A works has been segregated and stockpiled at site pending identification of recycling or disposal options by the EPC Consortium. CVA is enhancing its waste management implementation plan for each airport as part of the phase 1-A investment. Going forward, CVA will include SOPs (ref ESAP#1) for the operations, maintenance and monitoring of incinerators to be installed as part of phase 1-B investments or require its waste management service provider to develop SOPs consistent with CVA E&S commitments.
Hazardous materials used at airports are mainly Jet-A, diesel and lubricants. The international airports have aircraft fuel storage facilities of various sizes managed by a specialized company with a mature safe system of work and advanced hydrocarbon handling procedures. At the RAI airport, the Jet-1A is stored in two tanks of 90m3 each within a 126m3 secondary containment drained to an adequately dimensioned OWS. Each fuel storage area is fenced and has spill response kits and a trained spill response team. CVA has developed and is implementing an HMMP and a Spill Response Plan that integrates recommendations of the assessments of potential contaminated sites and sources of pollution conducted in 2020 and 2024 respectively aligned with IFC PS 3 requirements and relevant WBG EHS Guidelines.
PS4: Community Health, Safety and Security
The VXE, SNE, SFL and MMO airports have some isolated structures located at least 200 m away from sections of the perimeter fence while SID, BVC and RAI, are in close proximity to the city of Espargos, Rabil town, and the communities of Palia and Chave Grande respectively. The Rabil community near BVC and Fortinho near SID are the closest communities and the most exposed to noise impact during landing and take-off. CVA has developed a NMP. Going forward, CVA will strengthen its noise management program as part of its ESMS update (ref. ESAP #1, ref. ESAP#2 and ref. ESAP#3) and implement its updated NMP in accordance with the ICAO balanced approach.
CVA conducted a comprehensive Human Trafficking Risk Assessment (HTRA), led by a team of external consultants. The assessment confirmed the broad alignment of CVA’s actions with key international aviation guidelines and compliance with PS 4 requirements. Corrective measures have been proposed across all airports and aerodromes and CVA will implement these as part of the ESMS.
Most of the operational traffic is related to buses taking tourists to and from the airport. The primary risk to community during construction is road traffic associated with the transport of construction materials, equipment and workers to and from the sites. These risks will be managed by EPC Contractor under the CESMP (ref. ESAP #3) including transport risk assessment and traffic management plan.
CVA has completed a Life and Fire Safety (L&FS) audit of the existing passenger terminals and other priority areas against Cabo Verdean regulations and relevant WBG EHS Guidelines. The audit was focused on critical L&FS systems including fire detection and alarm, accessibility of exits & evacuation signalization. CVA has developed and is implementing L&FS corrective measures resulting from the audit at the different airports.
Security at the airports is managed by a security contractor. All security staff are unarmed. State security is also deployed at the airport with a different responsibility from airport operational security and immigration services. As part of phase 1-B works, the EPC Contractor will develop and implement a construction phase security management procedure as part of its CESMP (ref. ESAP #3) that will include relevant requirements for training of third party security agents and alignment with overall airport security protocols.
PS5: Land Acquisition and Involuntary Resettlement
The new concession areas for RAI, SID, and BVC included some plots of land that were outside the original airport land titles. For RAI and SID, these were publicly owned. For BVC, these consisted of 24 unregistered plots under the possession of families and one publicly owned plot (in total 16.5 ha), all within the airport’s easement area and formally under the legal ownership of the GoCV. All the plots at SID and BVC are unoccupied (no structures) and not being used for economic purposes due to the land use restrictions in place for the airport easement – i.e., there is no physical or economic displacement. At RAI, the plot is occupied by airport’s WWTP owned by the previous state-owned airports operator, ASA.
Based on information available at the time of appraisal, the Grantor had incorporated the plots at RAI and SID into the respective airport concession areas prior to the Concession Commencement Date. At BVC, the GoCV initiated a land acquisition process in May 2023. According to a review of the process undertaken by CVA in June 2024, although the plots legally belonged to the GoCV and were of limited or no economic value, the state entity in charge of land affairs (Direção-Geral do Património e da Contratação Pública or DGPCP) agreed to compensate the families for the withdrawal of possession based on land rates established by the national legislation Ordinance No. 38/2009. The review also found that in-order to receive this compensation, the plot “owners” had to register their possession, the costs of which are borne by the owner. As of August 2025, 12 plots had been compensated for and the remaining were either in the process of being registered, agreements yet to be signed, or, in a number of cases, the owners could not be reached (as they were living abroad). Going forward CVA will (i) develop and implement measures to close the gap identified with respect to IFC PS5; (ii) share correspondence relating to set aside of compensation for any outstanding payments, and (iii) track and confirm the status of the compensation payments to remaining plot owners (ESAP #8). For any future land acquisitions, CVA has developed a Land Acquisition Procedure in line with IFC PS 5 requirements.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
All the airports under the CA are on islands that fall within the Cabo Verde dry forests ecoregion. MMO is less than 1 km from Salinas de Porto Ingles Ramsar site and the Lagoa do Rabil IBA is in the BVC airport area of influence. Whilst both airports' Areas of Influence consist primarily of modified habitat, they fall into areas broadly qualified as critical habitat due to the presence of threatened and restricted range species including Phoenix atlantica at BVC and Kickxia elegans at MMO. IFC-financed works at both airports will occur in modified habitats, hence no significant residual impacts to the biodiversity values is predicted. As part of the Phase 1-A financing, CVA has developed a Biodiversity Action Plan (BAP), an Invasive Species Management Plan (ISMP), a Wildlife Management Plan (WLMP) and a Biodiversity Monitoring and Evaluation Plan (BMEP) for both airports, consistent with IFC PSs. Going forward, CVA will update the BAPs for MMO and BVC airports to include programs that support the conservation aims of the protected areas, in consultation with the protected area sponsors and to the satisfaction of the lenders; and will report on the implementation of the BAPs in accordance with the KPIs set out in the BMEPs (ESAP #9).
