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: In compliance with the WB Nigeria DARES E&S Management Framework, the overall E&S risk management guideline document developed jointly by the Rural Electrification Authority and the WB for the DARES Project in Nigeria, GVE has established a formal Environmental and Social Management System (ESMS) that outlines the company's approach to identifying, assessing, mitigating, and monitoring environmental and social (E&S) risks across its operations. The ESMS comprises (i) a Health, Safety and Environment Policy; and (ii) a mini-grid ESMS Manual with an E&S policy statement, project screening and categorization tools, procedures for preparing ESMPs, RAPs, and stakeholder engagement plans, as well as grievance redress mechanisms and monitoring tools. GVE also has a Mini-Grid Sustainability Policy which reinforces E&S commitments, especially on promoting local employment, responsible land acquisition practices, and long-term operational sustainability through community engagement. To implement the ESMS, GVE has developed a set of plans and procedures that address key topics, including hazardous materials management, waste management, occupational health and safety, site environmental and social impact management, stakeholder engagement, procurement, gender and equality and human resources. GVE will update the existing ESMS ensuring alignment with IFC PS1 and develop a Contractor E&S Management Procedure, a Chance-find Procedure, a supply chain Code of Conduct and a Security Risk Management Procedure; and update the Emergency Preparedness and Response Procedure, the Stakeholder Engagement Plan and the E&S Monitoring and Review Framework (ESAP #1).
Identification of Risks and Impacts: Guided by the E&S Screening Checklist, all GVE project sites undergo an initial environmental and social screening, to flag sensitive environmental, social, or land tenure conditions that may render a site ineligible or high-risk. The risks screened include those related to social conflict from labor influx; children and other vulnerable groups; and climate aspects – e.g., floods, soil erosion and landslides. The company’s site selection criteria explicitly avoid locations within protected areas, conflict zones, densely forested land, or any site involving physical or economic displacement. Sites must be more than 5 km from the national grid, host a population above 1,000, and have stable land access and community buy-in. These exclusion principles are consistently applied across the portfolio. The findings of IFC virtual screening of the 20 proposed pipeline mini grid sites indicate that some sites have a few farm plots while others are in unused land. The screening also confirmed that no other material impacts are expected from the project. Prior to commencement of activities on each site, sufficient time will be provided to allow for harvesting of crops in cases where farming is ongoing. 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. Therefore, the E&S risk profile of the mini grid sites ranges from low to medium and can be managed by the company’s E&S risk management system. In accordance with the national law, GVE conducts E&S impact Assessments, and develops and submits ESMPs for batches of mini-grid projects per State to the relevant State authorities for permitting. These ESMPs include detailed environmental and social 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 and the environmental permits prior to project commencement.
Land Acquisition: As indicated above, land will acquired through lease agreements with individual landowners and Voluntary Land Donation Process, in accordance with the DARES Project Voluntary Land Donation Guidelines. IFC reviewed the site screening reports, community engagement reports and a sample of the executed agreements which are aligned with good international industry practice (GIIP) including appropriate engagement and records, no evidence of coercion or intimidation, user consent, direct benefits to donors etc. The land acquisition process will not result in any physical displacement and where relevant, the users of the community-donated lands will be given sufficient time to harvest their seasonal crops before activities begin. Therefore, no physical displacement has occurred or is expected to occur and there are no outstanding community grievances related to the land acquisition process. No additional land acquisition for the distribution lines is anticipated as they will be laid along existing road servitudes. Should any future economic displacement occur, GVE will comply with the requirements of the DARES Resettlement Policy Framework and implement them in line with IFC PS 5.
Management Programs: To manage E&S risks and impacts associated with the construction and operations phases of the mini grid sites, GVE implements the ESMPs drafted in line with the DARES Program ESMP template. In addition, GVE implements the Solar EPC HSE Management Plan and the Occupational Health and Safety Management Plan (OHSMP) to manage health and safety risks in projects. These systems are further supported by GVE’s Solar Project Pre-Mobilization Plan which provides operational guidance for contractor mobilization, HSE training, equipment logistics, and onsite supervision—ensuring that contractor oversight is embedded in the project delivery process. The Project Pre-Mobilization Plan, however, focuses more on health and safety. To achieve full compliance and operational consistency in implementation of these management programs in the new sites, the company will develop and operationalize an E&S risk register for each site and at the corporate level; develop an adequate Contractor E&S Management Procedure (per ESAP #1); and ensure that the site staff are inducted on the programs, trained on completion of risk registers and that all these plans are accessible to site personnel for reference in addressing site E&S risks (ESAP #2).
Organizational Capacity and Competency: GVE’s Head of Operations is also the designated HSE leader, reporting to the Managing Director. An external Firm is contracted for periodic E&S support, as needed. However, given GVE’s rapid scaling of operations and the increasing pipeline of projects, a full-time competent Corporate HSE Lead and at least one supporting HSE officer will be recruited to lead E&S risk management and ESMS implementation. Additionally, as required in the ESMS, the company will develop and implement a risk-based program for internal training and onboarding for staff and contractors and retain training records for reference. To address the increasing scope of operations, GVE will also conduct E&S training for all site engineers to build their capacity to manage day-to-day E&S issues at individual sites, with the support of the HSE officers. (ESAP #3).
Emergency Preparedness and Response: GVE has developed a set of emergency preparedness and response procedures (EPRPs) embedded in multiple documents including the Solar PV Project HSE Plan, the ESMP for Plateau State – Phase II, and the Security Emergency Plan. These documents outline the required controls, responsibilities, and response protocols to address foreseeable emergency scenarios such as fires, chemical spills, explosions, and equipment failures at solar mini-grid installations. Given the size of the operations and the variation in characteristics of project sites, the company will develop a stand-alone EPRP (required in ESAP #1) that, in addition to the identified emergency scenarios above, includes emergency scenarios related to severe weather (including heatwaves, heavy rains and flooding) leading to collapse of structures like distribution poles and diesel spillage; and include clear schedules for emergency drills, response training and post-training evaluations to measure effectiveness. In the EPRP, the company will create performance indicators to track emergency preparedness and clearly reference national and local emergency laws and ensure that emergency instructions are displayed at all mini-grid sites.
Supply Chain: GVE procures solar panels, batteries, and associated equipment from ‘Tier 1’ suppliers. GVE’s Solar Ethical Procurement Policy addresses key supply chain risks by defining standards for supplier conduct, sustainable sourcing, and E&S compliance throughout the procurement process. The company’s evaluation and qualification criteria includes completion of a Forced Labor Declaration Form by all prospective bidders, their associates and sub-contractors. To ensure a more comprehensive safeguard against unfair labor and OHS practices in the PV solar supply chain, GVE will (as required in ESAP #1) i) develop and implement a supply chain Code of Conduct prohibiting forced labor and containing other relevant EHS requirements, including a supplier registration/evaluation sheet that includes these labor and HSE provisions, and; ii) in the PV solar equipment supply contracts, require the supplier to contractually commit to E&S policies that are consistent with core international standards and compliance with Nigerian and international laws and regulations. These provisions will be applied for all solar PV equipment procurement for the Project.
Monitoring and Review: GVE has outlined a formal environmental and social monitoring and review framework as part of its ESMS and has an E&S Monitoring Plan derived from the ESMPs. The monitoring framework specifies key parameters across environmental, social, and occupational health and safety domains, including energy output, fossil fuel use, quantity of solid waste recycled, job creation (with gender disaggregation), access to clean energy, and stakeholder grievances. Each monitoring item is linked to: (i) a mitigation measure; (ii) a performance indicator or unit of measurement; (iii) a frequency of monitoring; and (iv) a designated responsible party. GVE’s self-monitoring protocol also includes biannual reporting to the regulator and internally to management, designed to support accountability and continual improvement of E&S performance. As required in ESAP #1, the company will update the E&S monitoring and review framework to include a site-level E&S monitoring schedule and keep all applicable documentation related to the sites, and overall corporate performance to track trends, compare performance across locations, identify recurring issues, and take proactive corrective actions. Key highlights from the E&S risk register will also be integrated into the management reporting regime (including to the Board of Directors), for closer E&S oversight.
PS 2: Labor and Working Conditions
The current workforce at GVE is 72 employees - 75% male and 25% female. The workforce is expected to grow to approximately 270 as the company expands its mini-grid coverage. During mini-grid site construction, workers are recruited from the localities by contractor companies, and their numbers are based on workforce needs at each phase of construction.
HR Policies and Procedures. GVE’s Human Resources Policies and Procedural Manual serves as the primary internal reference for regulating employee relations and working conditions. The Manual outlines recruitment procedures, job classifications, leave entitlements, disciplinary measures, performance management systems, and employee benefits including health insurance and pension contributions. It reflects adherence to national labor legislation and provides a structured framework for employment administration. Employee contract documents are comprehensive and clear. The Manual also has a workers’ grievance management procedure with clear time-based steps. GVE’s Gender Equality & Inclusion Policy articulates a commitment to providing fair and inclusive work environments for all staff, irrespective of gender, age, religion, or background. The Policy promotes equal opportunity in recruitment, leadership, and workplace practices, and sets a foundation for integrating gender perspectives into project activities. Going forward, GVE will (i) improve the HR Manual to clarify coverage of third-party workers; include provisions on the right to freedom of association; add options for anonymous reporting in the grievance management section; require that the grievance management system is communicated in local languages at each mini-grid, and; aggregated data fed into Board-level E&S reporting; and (ii) improve the Gender Equality & Inclusion Policy to include the implementation tools (e.g., gender action plans or templates); provide for gender-related grievance handling; provide clarity on accountability and enforcement; add provisions for capacity-building of staff and implementing partners; and include monitoring indicators or evaluation framework; all in line with IFC PS 2 (ESAP #4).
Working Conditions: Working hours are clearly defined per local law, with structured leave entitlements including annual, sick, and maternity leave. Recruitment procedures are merit-based with clear onboarding and performance expectations. Employee benefits include training support; and disciplinary procedures are clearly outlined, including misconduct definitions and modes of enforcement.
Occupational Health and Safety; The OHSMP developed by GVE outlines the company’s strategy to mitigate occupational risks during both construction and operation phases of mini-grid projects. The plan addresses physical, chemical and biological hazards, and assigns roles and responsibilities to internal staff and contractors. It incorporates procedures for risk assessment, training, incident reporting, and emergency preparedness. The Plan references both Nigerian national laws and international standards, including IFC PS2 and General EHS Guidelines. In addition, the Project Pre-mobilization HSE Plan noted above details procedures for lifting operations, electrical work, fire safety and emergency response, work at height, hot works, incident and accident management and security risk management and stakeholder engagement that all contractors must adhere to. GVE will ensure that copies of the OHSMP and Project Health and Safety Plan and all implementation tools and templates are retained at each site (virtually or physically) for reference and use by site workers (including contractors), and all site workers are trained on managing the key OHS risks (ESAP #5).
Workers Engaged by Third-Party: GVE engages contractors for specific tasks during installation of solar panels, Although the OHSMP and the Project Pre-Mobilization HSE Plan are designed cover contractor workers, there is need for a more adequate contractor E&S risk management process and the Contractor E&S Management Procedure developed under ESAP #1 above will be implemented at all the Project sites.
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.
Water Use: Given the nature of solar mini-grids which are typically modular, ground-mounted systems with limited operational water needs, GVE’s infrastructure is not water-intensive. Water consumption is mainly associated with temporary construction activities (mainly civil works, sanitation and drinking) and basic operation-phase support, such as cleaning and providing potable water for technicians and staff. Due to the small size of the solar plants, the volume of water requirement for cleaning during operation phase is expected to be small and not expected to affect community water supplies.
Air Emissions and Greenhouse Gases (GHGs): 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 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); and the entire GVE mini grid expansion project is expected to offset approximately 16,300MTs of CO2 per annum.
Wastewater: GVE employs portable toilets and septic tanks at construction sites, in accordance with protocols detailed in the Waste Management Plan that is sufficient for the project risks. The operational facilities visited have toilets and effluent is directed into septic tanks within the facilities and all sewage will be removed by licensed contractors and disposed of at approved facilities as defined in the Plan.
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. Waste (general and hazardous) generated at the mini-grid sites includes construction waste (i.e., wood, concrete, packaging material, metal scrap), domestic waste (particularly food waste and plastic water sachets used by the project workers), used lead acid batteries and damaged PV modules and electronics. GVE has developed a Hazardous Materials and Waste Management Plan and reinforced by provisions in the ESMP for its solar mini-grid projects. The Plan specifies that hazardous substances should be stored in bunded containment areas, clearly labeled, and recorded in hazardous waste inventory registers maintained at each site. The Plan also identifies and categorizes hazardous waste streams commonly generated during both the construction and operational phases. The classification system references Nigerian legislation, specifically the Nigeria Harmful Waste Act, and aligns with international standards regarding labeling, containment, and the safe disposal of hazardous materials. Going forward, the company will i) document hazardous material inventory and train the site workers on hazardous materials handling and emergency response; ii) retain temporary waste disposal facilities at all Project sites, and; iii) document waste transfer and disposal process to ensure compliance with the Plan, national regulatory requirements and IFC PS3 at all Project sites. (ESAP #6).
PS 4: Community Health, Safety and Security
Road Transportation Management: Road transport activities associated with GVE’s mini-grid projects are addressed through the ESMP for Solar PV Mini-Grid Project in Plateau State – Phase II as well as ESMPs for all the other states, the Solar Project Pre-Mobilization Plan and the ESMP. These documents provide guidance on managing both internal (contractor/client) and external (third-party) vehicular traffic during site development. GVE recognizes the risks posed by transport during the construction and operational phases, particularly in densely populated or sensitive community locations such as the Wuse Market mini-grid site in AMAC, Abuja. According to the ESMP, risks related to vehicular movement include traffic congestion, pedestrian safety issues, increased emissions, noise, dust, and general nuisance to nearby communities. These are especially relevant in the context of unpaved access roads and narrow community pathways. To mitigate these impacts, the ESMP outlines several transport risk reduction measures, including pre-planned delivery schedules, avoidance of high-traffic hours (such as school commuting periods), and coordination with local stakeholders to reduce conflict with community mobility needs. Additionally, the ESMP emphasizes the need for signage, driver safety training, and use of designated access paths for heavy vehicles. The Project Pre-Mobilization Plan further supports these measures by requiring pre-arranged deliveries, identification of access tracks, and the use of barriers, cones, and signage to contain construction-related traffic to specific zones. Specific reference is made to the preparation of access roads using geogrid and geomembrane layers, demonstrating foresight into heavy-duty vehicle loads and community impact reduction. These safeguards are deemed adequate to address road transportation risks. The Contractor E&S Management Procedure will augment these existing safeguards.
Security Management: GVE has developed a structured approach to security management through its Security Emergency Plan, the Project Pre-mobilization HSE Plan, and the Mini-Grid Projects Sustainability Policy. Together, these documents outline the responsibilities, procedures, and physical and procedural safeguards for security personnel and assets. Each mini-grid site is fenced off with a single controlled access point and access control and security is provided on a need/on call basis by locally employed unarmed security personnel. This will be the case for all future sites. Considering that Nigeria has significant security challenges throughout all regions of the country, the company will undertake a security risk assessment of all its Project sites and develop a stand-alone security management procedure (required in ESAP #1) to harmonize management of security matters in the Project, in line with IFC PS4 requirements. The company will also sign contractual agreements with security service providers that outline expected behavior, use of force limitations, or escalation procedures during community tensions or incidents, in line with the updated procedures.
