The scope of IFC’s E&S review encompasses all elements across both Project stages. 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
Aukera BV operates a management system which includes separate policies for Sustainability and for Health, Safety and Environment (HSE). These policies align with IFC’s PS and apply to all Aukera BV operations, employees, contractors, and stakeholders. Aukera is certified to ISO14001:2015 (Environmental Management) and ISO 45001:2018 (Health and Safety Management) and while the certifications apply to the UK entity, the processes are implemented company wide in all countries in which it operates. A single, standardized HSE reporting and action-tracking platform is employed by Aukera across countries and construction sites.
The Aukera BV Executive Leadership team has overall responsibility for HSE and Environmental, Social, and Governance (ESG) performance. The Head of HSE has a direct line of reporting to one of the two CEOs and sits within the Support Team in the UK, supported by an HSE Coordinator and external advisors. The Construction Manager in Romania is currently responsible for Project level HSE, with the contracted Owner’s Engineer (OE) providing day-to-day management. Aukera will recruit an HSE Manager for Romania as per
ESAP#1, with clearly defined responsibilities, including oversight of the OE on E&S matters, implementation of ESAP items and relevant measures specified in the ESIA, SEP and ESMP. The in-country HSE Manager will have responsibility for community relations and grievance management, worker welfare and management of worker accommodation and monitoring of environmental and social performance.
Stage I of the Project was subject to an Environmental Impact Assessment (EIA) screening in accordance with national legislation, which determined that EIA was not required. However, an ESIA has been developed for Stage I to align with IFC PS, supported by an ESMP and SEP. Stage I of the Project has obtained local permits according to Romanian regulations, including a Building Permit.
During the construction stage, environmental impacts are predicted to be localised and temporary, resulting principally from noise, soil disturbance, traffic, and waste generation. The sites are modified in nature, having no overlap with protected habitats or designated areas. Potential indirect impacts to biodiversity are managed as part of the ESMPs, including avoidance of impacts to Natura 2000 sites in the surrounding areas, and appropriate measures to avoid/minimize potential impacts on biodiversity values that may occur in the area.
During operations there will be low volumes of waste produced and minimal air emissions. Water consumption will be low and will be sourced either by tanker or by installing a groundwater well in accordance with local permitting requirements.
Lease agreements and grid connections for the Stage II sites have been secured. Aukera is applying E&S standards and procedures established for Stage I to all Stage II sites. This ensures consistent mitigation of risks across Roman, Dumbrava, and Lacu Sarat, with site-specific assessments currently being finalized to confirm the baseline at each location. As per ESAP#2, Aukera will conduct environmental and social impact assessments for Stage II, with scope appropriate to the scale and nature of the projects and its locations, and aligned with IFC PS, prior to commencement of construction.
The ESMP developed as part of the ESIA for Stage I establishes measures for identifying, preventing, minimizing and managing the environmental and social impacts associated with the Project at Gura Ialomi?ei, across the Project lifecycle. The ESMP is site specific and includes roles and responsibilities, environmental and social mitigation measures, legal compliance and monitoring. Plans and procedures developed by the construction contractor and/or BESS Operator consider risks identified in the ESIA and include: Emergency Preparedness and Response Plan (EPRP) and Fire-Specific Emergency Plan, Pollution Prevention & Spill Response Plans; Waste and Materials-Management Plans; Occupational Health & Safety Plan; Environmental Monitoring Plan; Stakeholder Engagement Plan; Complaints / Grievance Management Procedures; Traffic Management Plan and Anti-Discrimination & Gender-Based Violence (GBV) Procedures.
Under ESAP#3, ESMPs and SEPs will be established for Stage II of the Project, as part of Stage II ESIAs covering construction and operation phases, and including management plans and contractor requirements specific to each site and aligned with E&S standards established in Stage I and site-specific baseline assessments, ensuring consistent application of IFC requirements across all locations. Responsibility for developing these plans and implementing actions on the ground will sit with the EPC Contractor during
construction and with the BESS operator during operations. Aukera includes contractual E&S obligations, and maintains a Supplier and Contractor Code of Conduct, referenced in all contracts.
E&S monitoring requirements for construction and operation phases of the Project are included in the Sponsor’s HSE management system, including monitoring frequency, performance indicators, and targets.
Aukera and the OE will oversee the implementation of monitoring programs and control of contractor and subcontractor E&S performance. An independent E&S monitoring consultant will also be engaged during the construction and early operations phases to monitor the implementation of the ESMS and E&S Action Plans and recommend any necessary corrective measures.
As per ESAP#4, Project and site-specific Emergency Preparedness and Response Plans (EPRPs) will be developed in accordance with the ESIAs and ESMPs and aligned with IFC PS to address risks to workers, the environment and local communities from emergency situations, including battery unit fire. EPRPs will be tailored to the specific risks for each stage of the Project; construction, installation, commissioning and operations; encompassing specific risks such as electrical and hot works. To address climate-related extreme weather events, Aukera has conducted a Climate Change Assessment for Stage I and is building on the detailed CCA methodology established for Stage I to conduct focused CCAs for the Stage II sites. Findings from these verifications will be integrated directly into the site-specific ESMPs (ESAP#3) and reflected in the site-specific EPRPs (ESAP#4), ensuring the standardized BESS design remains resilient to local environmental conditions." This shall be reflected in Stage II ESIAs.
The EPC Contractor for Stage I operates an Integrated Management System which is certified to ISO 14001 (environment) and ISO 45001 (OHS). The E&S Plan for Stage I established by the EPC Contractor includes a Quality Plan (QP), Environmental Management Plan (EMP) and Social Responsibility Plan (SRP), along with
a standalone Traffic Management Plan (TMP), all of which are aligned with the outcomes of the ESMP. These plans provide site level measures to address E&S and OHS risks and impacts for Stage I, supported by the EPC Contractor corporate codes and policies including; Code of conduct and professional ethics policy; Policy on Environmental Protection, safety and social responsibility; Supplier Code of Conduct; Code of Professional Conduct and Ethics; and Environmental Protection, Safety and Social Responsibility Procedures. These codes and policies align with IFC’s PS. Construction ESMPs and related sub-management plans will be established for each site under Stage II by the relevant EPC contractor as part of ESAP#3.
Social risks related to the Project are identified in the SRP, along with mitigation measures and responsibilities. Due to the specific skills required, local employment is limited; however, site security personnel are recruited locally and there is a positive temporary local economic benefit from accommodating the construction workforce in surrounding hotels. Measures to address human rights, worker and stakeholder grievance mechanisms, and gender-based violence and harassment are specified in the SRP and align with IFC PS. No physical or economic displacement is expected.
The TMP developed by the EPC Contractor for Stage I applies to all construction activities which may have an impact on traffic and on internal and external road safety. The plan applies to contractor staff, subcontractors, suppliers, carriers and authorized visitors.
A Chance Finds Procedure will be implemented in accordance with the EPC Contractor E&S Plan to manage the risk of previously undiscovered cultural heritage sites or artefacts being exposed and identified during construction.
The Sponsor’s E&S and OHS policies and Project-specific ESMP provide a suitable framework for implementation of the EPC Contractor’s E&S and OHS plans and procedures. Together, these management measures are commensurate with the scale and E&S risks and impacts of the Project.
PS 2 – Labor and Working Conditions
The Sponsor has documented HR policies which apply to all employees for (i) Company Culture; (ii) Code of Conduct; (iii) Health, Safety and Welfare; and (iv) Whistleblowing. These policies are consistent with IFC PS 2 requirements and establish the framework for Project-specific workforce measures which are implemented by the EPC Contractors. The Aukera Code of Conduct prohibits exploitation, discrimination, harassment, including unwanted behaviours of a sexual or gender-based nature. Non-compliance is contractually defined as a material breach, allowing Aukera to impose corrective actions or terminate the contract. The Sponsor implements workers grievance mechanism through a corporate level Grievance Policy and a Whistleblower Policy. As part of ESAP#5, Aukera will consolidate the current grievance mechanisms and include an identified avenue for sensitive cases (such as discrimination or sexual harassment), with multiple reporting options, a consolidated process for investigation, and available referral pathways to support services. Training on the grievance mechanism and HR procedures is provided to staff as part of onboarding.
The construction workforce includes a mixture of nationalities, with induction materials and site signage provided in multiple languages. A procedure for the integration of foreign workers is implemented by the EPC Contractor for Stage I, encompassing contracting, logistics, food and accommodation, visas, training, supervision and health and safety. Risk assessments, Personal Protective Equipment (PPE), training, emergency response, hazardous material handling, traffic safety, electrical safety, and contractor oversight are included in the Stage I ESMP, which also defines roles and responsibilities for managing OHS at the site level. Working conditions and the management of OHS risks and impacts are aligned with IFC PS2, with OHS KPIs recorded and tracked for the Project via the Aukera HSE reporting and action-tracking platform, encompassing incident and near-miss reporting, investigations, corrective actions and audits.
OHS management procedures will be established as part of ESAP#3, for construction of Stage II, and operations for all sites, including risks related to electrical hazards.
The EPC Contractor E&S Plan specifies measures for non-discrimination, prohibition of forced and child labor and a workers grievance mechanism with specific provisions for GBV cases, as well as workers’ right to form or join unions or worker organizations. The E&S Plan is consistent with national labor regulations and IFC PS2 requirements and includes a Supplier Code of Conduct encompassing ethics, human rights, environment, anti-corruption, and conflict minerals, although it is not specific to battery due diligence obligations. The Supplier Code of Conduct requires subcontractors to comply with International Labour Organization (ILO) standards.
The EPC Contractor(s) for Stage II will implement worker procedures aligned with IFC PS2 and in accordance with Aukera codes and policies. Where worker accommodation is provided, housing will be aligned with the IFC Guidance Note on Workers Accommodation (2009) as per ESAP#6. Accommodation conditions will be inspected regularly by the Sponsor HSE Manager for Romania and/or the appointed OE HSE Representative and any non-conformities corrected.
Aukera has established sourcing procedures and procurement processes that apply across all business units and countries. Aukera’s Supplier Code of Conduct is contractually mandatory for all suppliers and subcontractors and expressly prohibits: forced labor, modern slavery, human trafficking; child labor; unsafe working conditions; and discrimination, harassment, and other human rights violations.
PS 3 – Resource Efficiency and Pollution Prevention
During construction there will be temporary and localised impacts to nearby receptors from noise, dust and traffic. Continuous low-level noise will be produced during operations by transformers, inverters and cooling systems and biannual operational boundary noise monitoring will be undertaken and reported.
During operations, indirect emissions are generated through the charging and discharging processes; however, Stage I of the Project is anticipated to result in an overall greenhouse gas (GHG) emission reduction of 70,286 tonnes of carbon dioxide equivalent (CO2e) per year. Aligned with its sustainability policy, the Sponsor is committed to tracking GHG emissions and maintaining zero Scope 1 emissions.
Routine operation of the BESS sites will not result in significant quantities of waste and emissions. The principal pollution risks and impacts associated with the Project arise from construction and decommissioning activities, battery waste from maintenance and end-of-life activities, accidental events and emergency situations.
Pollution prevention measures for environmental risks and impacts related to water, air, noise and vibration, soil and subsurface, waste management and hazardous chemicals are identified for construction and operations in the ESIA for Stage I, in accordance with legal requirements and Good International Industry Practice (GIIP), specifically referencing IFC PS and World Bank Group EHS Guidelines (WBG EHSGs). These measures are applied through design controls, operational procedures, monitoring requirements, and emergency response
measures as set out in the ESMP and implemented on site through the EPC Contractor E&S Plan. The measures specified in the ESMP encompass both construction and operation of Stage I and are proportionate to the nature and scale of activity and aligned with IFC PS and WBG EHSGs.
Construction waste will be segregated at the source and stored in impermeable, clearly marked areas for transfer to authorized waste contractors. Construction and demolition waste will achieve at least 70% reuse/recycling/recovery and a record of waste from construction activities will be reported to the competent authority. Hazardous waste will be separated and stored at site, and disposed of by a licensed contractor, aligned with the WBG EHS Guidelines. In accordance with the ESMP, a Waste Management Plan (WMP) and a
Construction Waste Management Plan (CWMP) will be implemented for Stage I and waste management plans for construction and operation will be developed for Stage II as per ESAP#3.
During operation and decommissioning, the OE HSE Representative under supervision of the Sponsor HSE Manager for Romania will oversee management of hazardous waste, including used batteries, chemical waste, and maintenance related waste, in accordance with the WMP and a Hazardous Materials & Waste Management Plan (HMWMP).
As per ESAP#7, once detailed design is completed the Project will implement a full HMWMP for all stages of the Project, covering: battery cell chemistries, expected volumes of hazardous waste (e.g., spent modules, electrolyte, contaminated materials), storage, packaging and transport, licensed recycling or final disposal routes, and spill response plan.
At Project closure, the Sponsor will prepare a Decommissioning Plan (ESAP#8) setting out detailed procedures for site restoration, in alignment with current GIIP, including the regulatory requirements of the EU Battery Regulation (EU) 2023/1542 and the Waste Electrical and Electronic Equipment (WEEE) Directive (2012/19/EU). Full site restoration will be undertaken and all waste and materials removed by authorized companies. The Sponsor will develop a decommissioning plan (ESAP#8) with procedures for site restoration
aligned with current GIIP.
Gura Ialomi?ei is located within the broad, natural floodplain of the Lower Danube. Although the area is protected from flooding by a series of dikes and embankments, flooding events may lead to chemical/electrolyte spills, contaminating soil, water bodies, or drainage systems and water intrusion into BESS units via floodwater can short-circuit battery cells, triggering thermal runaway potentially resulting in fire. As per ESAP#4 a Project-specific EPRP will be developed for both Stage I and Stage II, considering climate related extreme weather events and results of the CCAs.
Noise impacts for Stage I were assessed in the ESIA. The nearest sensitive receptors are a farmhouse and disused but informally inhabited railway station; both properties located approximately 150 m from noise emitting sources. Noise levels at the sensitive receptors are estimated to remain below 50 dB during both construction and operations, aligned with WBG EHS Guidelines and local regulatory requirements. Noisy works during construction will be limited to the hours of 08:00-18:00. Routine operational noise will be produced by cooling systems, inverters and transformers; noise monitoring will be conducted during both construction and operations.
As per ESAP#9, once detailed design is complete the Project will commission noise modelling and implement regular noise monitoring at the site boundary and nearest sensitive receptor to confirm noise limits are met.
PS 4 – Community Health, Safety and Security
The BESS site is located approximately 500m from the outskirts of Gura Ialomi?ei, which is the closest settlement. The surrounding area is agricultural in nature. Potential construction-related risks and impacts to surrounding communities from noise, dust, Project traffic and accidents and emergencies are assessed in the Stage I ESIA and addressed under PS1 and PS3 above. Social risks and impacts from routine operations will be low. The principal community health and safety risk during operations will arise from an emergency such as a fire. Automated systems, fire detection and suppression and emergency preparedness and response planning will be implemented on site in accordance with E&S standards and procedures agreed with IFC (ESAP#4). The Project will also have positive social impacts on grid stability, renewable energy integration and reducing CO2 emissions.
As per ESAP#4, the company will develop and implement site-specific EPRPs (encompassing battery installation, commissioning and operations) in consultation with responsible authorities and communities to cover potential emergency situations. In order to mitigate community risks from the transport of hazardous materials, the EPRPs will also consider chemical spills and releases from Project transportation.
The BESS systems will be fully automated and include safety design features as standard. Continuous monitoring of control systems and critical safety and environmental parameters will be undertaken along with automated alarms and temperature/smoke/gas detection. A clear command structure is defined for emergency response along with key responsibilities in an emergency.
Site security is provided by CCTV and perimeter fencing with warning signs. Security personnel from a licensed contractor provide site security during construction. Security guards are screened and trained as per local regulations and encompassed by the relevant codes of conduct. No security personnel will be stationed on site during operations.
Project transport routes for Stage I are defined and controlled via a Traffic Management Plan (TMP). Project vehicles will use approved routes with specific transport protocols for oversized vehicles. Sensitive receptors are identified in the TMP, which is broadly aligned with IFC PS4 and specifies speed limits, scheduling to avoid peak hours and formal community notification procedures for oversized transports. TMPs for Stage II will be established as part of the respective ESMPs under ESAP#3.
