While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security

While all IFC Performance Standards apply, PS1–PS4 were identified as most material given the construction-driven nature of HRID’s activities, the project’s urban setting, and contractor-based workforce profile. Based on IFC’s E&S due diligence, the Project is not expected to generate material impacts related to PS6, PS7, or PS8. In addition, no physical or economic displacement, private land acquisition, or loss of assets or livelihoods has been identified; accordingly, PS5 is not triggered.

The project is classified as Category B under IFC’s Policy E&S Sustainability due to limited and site specific E&S risks and impacts and readily addressed through mitigation measures. Key E&S risks associated with the proposed investment include (i) Company's capacity to assess and manage E&S impacts, including a PSs compliant ESIA; (ii) supply chain and contractors’ management; (iii) labor and working conditions, including occupational health and safety (OHS), workers grievance mechanism (GM), nondiscrimination and equal opportunities, gender based violence and harassment (GBVH), emergency planning, seasonal and migrant workers; (iv) air emissions, waste, wastewater, hazardous materials, noise; (v) resource-efficiency; (vi) community health, safety and security, including traffic and road safety; (vii) emergency preparedness and response, structural safety, and life and fire safety; and (viii) stakeholder engagement and grievance mechanism.

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

E&S Policy
HRID has established corporate-level E&S policies covering environmental protection, labor and working conditions, occupational health and safety, employee welfare, and stakeholder engagement, broadly aligned with national requirements and GIIP. However, these policies are not fully aligned with IFC Performance Standards and require strengthening to ensure consistent project-level implementation and effective cascading of E&S requirements across the supply chain. The current framework remains largely policy-driven, with limited translation into a project-specific ESMS. Key PS1 elements—such as project-specific procedures, management programs, and enforceable E&S requirements for contractors and subcontractors—have yet to be fully developed and implemented. Under ESAP #1, HRID will update and formalize its E&S Policy, secure senior management endorsement, and communicate it to workers to ensure full alignment with IFC Performance Standards and establish the basis for a robust, project-level ESMS.

Identification of E&S Risks and Impacts
HRID has completed an environmental and social impact assessment (ESIA) in line with Kurdistan Regional Government Environmental Law No. 8 (2008), as amended by Law No. 11 (2022), and with the objective of aligning the Project with IFC Performance Standards and WBG EHS Guidelines. The ESIA establishes baseline conditions and identifies key environmental risks during construction and operations, including air emissions, noise and vibration, traffic, soil disturbance, stormwater runoff, waste generation, and demand for energy and water. To address these risks, ESAP #2 requires HRID to finalize and implement construction and operations ESMPs consistent with ESIA findings and PS1 requirements. The ESIA will be disclosed on the IFC website.

Social risks are primarily associated with the construction phase, including traffic and access disruptions, community health and safety risks, pressure on local services, and GBVH/SEAH risks. The Project is located in a dense urban setting with proximity to residential areas and sensitive receptors (e.g., schools and healthcare facilities), making community safety, traffic management, and stakeholder engagement key priorities. A Social Impact Assessment (SIA), integrated within the ESIA, assesses baseline conditions (demographics, livelihoods, health, security, and land ownership) and identifies vulnerable groups, including female-headed households, elderly persons, persons with disabilities, unemployed youth, and school-age children. While the ESIA and stakeholder engagement plan (SEP) include differentiated mitigation measures, the SEP requires further operationalization (ESAP #8) to ensure effective implementation. Alternatives analysis was undertaken, including the no-project option (deemed socioeconomically unviable), design alternatives, and site selection through a structured multi-criteria approach. The selected site complies with zoning requirements and avoids involuntary resettlement.

E&S Management System & Programs
At appraisal, HRID had initiated ESMS development through preparation of the ESIA and draft ESMPs; however, a project-specific ESMS had not yet been established. Under ESAP #3, HRID will develop, finalize, and operationalize a project-specific ESMS prior to construction. This will include documented procedures, defined E&S roles and responsibilities, contractor and subcontractor management protocols, training programs, and monitoring and reporting arrangements aligned with PS1–PS4 and applicable WBG EHS Guidelines. In parallel, ESAP #4 requires the integration of ESMS, ESMP, EHS, labor, grievance, and emergency preparedness requirements into contractor and subcontractor contracts, supervision, and performance monitoring systems.

E&S Organizational Capacity/Competency and E&S Training
At appraisal, HRID’s E&S organizational capacity was still under development. The existing organizational arrangements reflected the Project's stage of development at the time of appraisal; however, additional environmental and social capacity will be required to support the Project during construction, effective implementation of the ESMS, and subsequent operational phases. Coordination between corporate and project-level E&S functions had not been formalized. Contractor supervision capacity remains a key focus given the multi-tier contracting structure and peak workforce of approximately 800 workers, making dedicated E&S oversight critical during construction and operations. The ESMS will establish clear E&S roles, responsibilities, and reporting lines at both corporate and project levels. Under ESAP #5, HRID will formalize and operationalize an adequately resourced E&S organizational structure to support effective ESMS implementation. A comprehensive training plan for E&S and HSE personnel will be developed in parallel.

Emergency Preparedness and Response
IFC reviewed HRID’s Emergency Preparedness and Response Plan (EPRP) against PS1, PS2, PS4, and WBG General EHS Guidelines. The EPRP addresses a range of scenarios, including accidents, fires, explosions, hazardous material spills, natural hazards, and disease outbreaks, supported by defined roles, procedures, and coordination with external emergency services. Initial health, safety, environment (HSE) induction training was provided to 154 workers during early mobilization. However, gaps remain in alignment with IFC Performance Standards and GIIP, and effectiveness has yet to be fully demonstrated. Areas identified for further enhancement include contractor-wide implementation, systemic testing through regular drills, response coordination and command structures. Community-facing preparedness measures, including emergency notification and engagement with adjacent receptors, also require strengthening. Under ESAP #6, HRID will update and operationalize a project-specific EPRP prior to construction to ensure full alignment with PS1, PS2, and PS4 and WBG EHS Guidelines. This will include enhanced contractor integration, systematic testing (e.g., drills), and incorporation of emerging risks such as drones, falling objects, and debris.

E&S Monitoring and Review
At appraisal, HRID initiated an E&S monitoring framework, with responsibilities assigned for inspections, non-compliance tracking, and performance reporting. However, the monitoring framework requires further formalization to ensure consistent implementation, reporting, and review as project activities progress. Under ESAP #7, HRID will further develop and formalize a comprehensive E&S monitoring and review system, including defined KPIs, inspection protocols, incident and grievance tracking, and reporting procedures, in line with PS1 adaptive management principles. The system will also incorporate periodic ESMS reviews to ensure continuous performance improvement. HRID will submit Annual Monitoring Reports to IFC throughout the investment period, covering ESAP implementation progress and E&S performance against established KPIs.

Stakeholder Engagement, External Communication and Grievance Mechanisms
The project ESIA included stakeholder engagement analysis and consultation planning. Stakeholder engagement is currently being undertaken through a project-specific Stakeholder Engagement Plan (SEP) under development, covering affected and vulnerable groups within the Project's Area of Influence. However, at the time of appraisal, the standalone IFC PS1-aligned SEP and the associated grievance mechanism (GM) had not yet been finalized or fully operationalized. HRID has established interim grievance arrangements and is developing a grievance mechanism covering workers and external stakeholders, with multiple intake channels, confidentiality provisions, anonymous reporting options, and GBVH/SEAH-sensitive grievance handling arrangements, including appropriate referral pathways and protection of complainant information. As required under ESAP #8, HRID will finalize and implement the community SEP and establish a fully functional grievance mechanism, including defined response timelines, escalation procedures, and systematic recordkeeping, in line with IFC Performance Standard 1 requirements.


PS2 – Labor and Working Conditions

Working Conditions and Management of Worker Relationship

The Project will be implemented in Sulaymaniyah (KRI), where the labor market is characterized by heavy reliance on contractor-based and semi-formal employment. Iraq has limited labor inspection and enforcement capacity. Construction will involve a peak workforce of approximately 800 workers, including direct, contracted, subcontracted, and migrant labor, with a significant share of non-local workers dependent on employer-managed accommodation and welfare systems.
This context presents key PS2 risks, including inconsistent application of labor standards across contractor tiers, variable employment practices (e.g., inconsistent documentation), limited worker awareness—particularly among migrants—and reliance on contractor-managed systems. Labor influx is a primary risk driver, especially in relation to contractor management and worker protection.

Human Resources Policies and Procedures
HRID has established a human resources and contractor management framework broadly aligned with IFC Performance Standard 2, including policies and procedures covering labor management, non-discrimination, freedom of association and collective bargaining rights, Code of Conduct, worker grievance mechanisms, GBVH/SEAH prevention, contractor ESHS management, contractual ESHS requirements, worker training and awareness, monitoring, and compliance verification applicable across contractors and subcontractors. Environmental and social requirements have been systematically incorporated into the Project's contractor management framework through contractor ESHS guidelines, contractual clauses, monitoring and verification procedures, and contractor submission requirements. As construction activities progress, the primary focus will be on ensuring consistent implementation across all contractor and subcontractor tiers, maintaining worker awareness of labor rights and GBVH/SEAH requirements, and verifying effective implementation through supervision, inspections, audits, spot checks, and contractor performance monitoring. Under ESAP #9, HRID will implement and demonstrate the effective operation of the worker training, awareness, and contractor management system across all contractor tiers.

Working Conditions and Terms of Employment
Working conditions are defined through HR policies and contractual provisions, including written contracts, standardized wages not differentiated by nationality or migration status, regulated working hours, and prohibitions on child and forced labor. Safeguards include mandatory age verification, prohibition of passport retention, and a no-recruitment-fee policy applicable to labor brokers. Workers engaged to date have received written contracts in local and Arabic languages confirming wages and key employment conditions.
HRID has established contractual requirements and contractor management procedures for monitoring labor and working conditions, including working hours, overtime, wage payments, and contractor and subcontractor compliance. As the Project has not yet entered the main construction phase, the effectiveness and consistent application of these arrangements across all contractor tiers have not yet been fully demonstrated in practice. As workforce mobilization progresses, HRID will operationalize the contractor labor management and verification system under ESAP #4 through periodic audits, document reviews, worker interviews, inspections, and corrective action tracking, including verification of working hours, overtime, wage payments, and compliance across contractors and subcontractors.
Worker accommodation is currently provided on-site for a limited workforce, with workers retaining full freedom of movement. Additional on-site and off-site accommodation is expected to be developed for the peak construction workforce. Under ESAP #12, HRID will prepare and implement worker accommodation plans covering all accommodation types in accordance with the IFC–EBRD Guidance Note on Workers’ Accommodation and applicable good international industry practice.

Workers' Organizations
HRID recognizes workers’ rights to freedom of association and collective bargaining. Where formal representation is limited, the Company will provide alternative engagement channels, including direct dialogue with HR and access to the grievance mechanism. Under ESAP #9, HRID will update its HR policies to ensure full alignment with IFC PS2 requirements on freedom of association and collective bargaining.

Non-Discrimination and Equal Opportunity
HRID’s Code of Business Conduct prohibits discrimination on the basis of nationality, language, religion, race, ethnicity, gender, age, disability, or other protected status, and promotes equal opportunity across the employment lifecycle. The HR framework also prohibits harassment and retaliation against workers raising grievances, supported by a diversity, equity, and inclusion (DEI) approach. Under ESAP #13, HRID will prepare and implement a Retrenchment Plan, if required, in line with IFC PS2 and applicable labor law, including measures to mitigate adverse impacts on affected workers.

Worker Grievance Mechanism
HRID has established a worker grievance mechanism (GM) with multiple intake channels, including anonymous reporting, and GBVH/SEAH-sensitive procedures. While broadly aligned with IFC PS2, gaps remain in full integration across contractor and subcontractor tiers, as well as in systematic monitoring and analysis of grievance data and consistent implementation of GBVH-sensitive processes. Under ESAP #10, HRID will strengthen the GM by integrating contractor and subcontractor processes into a centralized system; defining clear roles, escalation procedures, and resolution timelines; and establishing systematic monitoring, analysis, and reporting of grievances. The GM will be accessible to all workers and responsive to labor, GBVH/SEAH, and other workplace concerns, with appropriate recordkeeping, follow-up, and protection against retaliation. Worker awareness of the GM will be ensured through mandatory induction

Protecting the Work Force
The Project prohibits child labor and all forms of forced or exploitative labor. Given the hazardous nature of construction activities, HRID will ensure that no persons under 18 are employed on the Project. All contractors and subcontractors will be required to conduct documented age verification prior to site access using government-issued identification. Compliance will be verified by HRID through pre-mobilization document reviews and periodic labor audits. Where employment of minors is permitted under national law, such engagement will strictly comply with legal requirements and be subject to risk assessments and ongoing monitoring of health, working conditions, and working hours.

Occupational Health and Safety
Occupational health and safety (OHS) is a material project risk during construction, given the contractor-driven workforce (peak ~800 workers) and high-risk activities, including work at height, heavy lifting, confined space entry, electrical works, hazardous materials handling, and traffic management. Construction-phase OHS risks have been identified in the ESIA, with mitigation measures including site-specific risk assessments, supervision of high-risk activities, welfare provisions, and structured training programs. HRID has established an OHS management framework aligned with IFC PS2 and the WBG EHS Guidelines, incorporating Job Safety Analysis (JSA), Permit-to-Work systems, task-specific procedures, mandatory training, PPE requirements, hazardous materials management, incident reporting, contractor management procedures, monitoring and verification arrangements, and corrective action tracking. As the Project progresses into the main construction phase, the focus will be on effective implementation and consistent application of these arrangements across all contractors and subcontractors, supported by inspections, audits, performance monitoring, and verification of OHS performance. Under ESAP #11, HRID will finalize and operationalize the Project OHS Plan applicable to all worker categories.

Workers Engaged by Third Parties
HRID has established contractor management requirements, including contractual obligations for compliance with applicable national legislation, IFC Performance Standards, and relevant Good International Industry Practice (GIIP). Contractors are required to prepare and implement risk-appropriate E&S documentation, including construction-phase risk assessments, emergency preparedness and response measures, labor management requirements, and occupational health and safety controls. Project-specific contractor management procedures, monitoring and verification arrangements, contractual ESHS requirements, and contractor submission requirements have been established to support consistent implementation across contractor and subcontractor tiers.
As the Project progresses into the main construction phase, the focus will be on effective implementation and systematic verification of these established arrangements across all contractor and subcontractor tiers. Under ESAP #4, HRID will operationalize the contractor labor management and verification system through structured contractor performance reporting, periodic audits, inspections, worker engagement, document reviews, and corrective action tracking to demonstrate effective implementation in accordance with IFC Performance Standards and GIIP.

Supply Chain Risk Assessment and Management
The Project will rely on primary suppliers for construction materials and equipment. At appraisal, HRID had not completed a documented supply chain risk assessment. While contractor-related risks are addressed separately, supply chain risk management requires a targeted approach. Accordingly, HRID will integrate supply chain due diligence into its procurement and contractor management systems, including screening of primary suppliers, contractual prohibitions on child and forced labor, and risk-based monitoring and verification measures where material risks are identified. These requirements will be implemented through the project-specific ESMS and contractor/procurement management framework.

PS3: Resource Efficiency and Pollution Prevention

The Project is expected to generate environmental impacts related to resource consumption, emissions, effluents, waste generation, and the use of hazardous materials during construction and operations. In line with IFC Performance Standard 3, HRID is required to apply GIIP to promote resource efficiency, prevent pollution, and manage emissions and waste throughout the project lifecycle. At appraisal, PS3-related assessments and management instruments, including project-specific plans, were under development. While the Company has demonstrated awareness of PS3 requirements, the framework remains high level. Further work is required to establish quantified baselines, define performance indicators, and implement operational controls to enable effective management, monitoring, and verification of resource efficiency and pollution prevention measures.

Resource Efficicncy

Greenhouse Gas Emissions
The Project will generate greenhouse gas (GHG) emissions during construction and operations, primarily from fuel combustion (Scope 1) and electricity use (Scope 2), including temporary or backup power. At appraisal, a consolidated project-level GHG inventory had not been completed, because the project design is being completed, thus it remains uncertain whether emissions will exceed IFC’s 25,000 tCO2e/year reporting threshold. In line with PS3, HRID will quantify GHG emissions using an IFC-accepted methodology and implement technically and financially feasible mitigation measures. While preliminary measures (e.g., energy-efficient design and system optimization) have been identified, quantified baselines, emissions intensity indicators, and the reduction targets will be established following completion of the ESIA and detailed design. The project is expected to achieve EDGE certification, which will incorporate high levels of resource efficiency in building design, including energy, water, and materials; however, further measures may still be required to address residual GHG emissions at the project level.

Water Consumption
The Project will also require water for construction, workforce welfare, building services, and operational uses. Supply is expected to rely primarily on municipal systems. At appraisal, a consolidated water balance and quantified demand baseline had not yet been finalized.

Preliminary water-efficiency measures include low-flow fixtures, consumption monitoring, and consideration of rainwater harvesting and reuse for construction and landscaping. Stormwater management systems, including potential reuse for irrigation, are incorporated in project concepts to reduce potable water demand. These measures, together with monitoring responsibilities and performance targets, will be formalized through the ESMP.

Pollution Prevention

Air Emissions, Noise and Vibration Management
During construction, air emissions will primarily include dust from earthworks and exhaust from construction equipment. During operations, emissions will mainly arise from indirect sources, including electricity use and traffic, with limited on-site combustion. These impacts will be managed through construction and operational ESMPs, applying project-specific controls in line with national standards and WBG EHS Guidelines. Planned mitigation measures include dust suppression, equipment maintenance, controlled material handling, and management of works near sensitive receptors. At appraisal, detailed air quality modelling and quantified emission levels had not yet been completed and will be addressed during detailed design. Noise and vibration impacts will be managed through scheduling, equipment controls, and monitoring against applicable standards. These risks will be addressed under ESAP #2.

Wastewater Management
The Project will generate domestic and operational wastewater during construction and operations. Wastewater is expected to be managed primarily through connection to municipal systems, supplemented by on-site treatment where required. At appraisal, wastewater flow estimates and effluent quality characterization had not been finalized. Pollution prevention and monitoring measures will be formalized and implemented through the ESMP under ESAP #2, in line with national requirements and WBG EHS Guidelines.

Soil, Groundwater, Surface Water and Stormwater Protection
Soil, groundwater, surface water, and stormwater risks will be managed through project-specific measures under the ESMS and ESMPs. Construction-phase controls will focus on erosion prevention, sediment control, and spill management, while operational measures will address stormwater management and runoff. No legacy contamination has been identified at the site; however, procedures will be in place to identify, manage, and remediate any unexpected contamination encountered during construction.

Waste and Hazardous Materials Management
The Project will generate non-hazardous, construction, and hazardous waste, including debris, municipal waste, and materials such as waste oils, chemicals, and batteries. As the Project remains in the pre-construction phase, construction-phase waste and hazardous materials management arrangements have not yet been operationalized. Accordingly, project-specific measures for segregation, storage, disposal, contractor oversight, traceability, and hazardous materials management will be implemented during construction in accordance with the Project's ESMS and applicable management plans.Under ESAP #2, HRID will strengthen waste and hazardous materials management through development of project-specific plans, implementation of tracking and record-keeping systems, enhanced contractor oversight, and establishment of spill prevention and response procedures.

PS4 – Community Health and Safety

Community health and safety (CHS) is a material risk given the Project’s dense urban setting, proximity to residential areas and sensitive receptors, and limited buffer zones. Construction activities may generate dust, noise, and vibration, with potential cumulative impacts. However, appraisal findings indicate that mitigation measures remain high-level, with limited receptor mapping, no predictive modelling, and absence of monitoring thresholds linked to corrective actions. Construction activities, workforce presence, traffic, and security arrangements may increase community exposure. While the Project site is controlled and does not require land acquisition, surrounding communities may still be affected by construction disturbances, traffic flows, worker influx, and perceived emergency risks. Overall risks are expected to be localized and manageable; however, the urban context and presence of vulnerable groups necessitate structured, site-specific CHS management.

Infrastructure and Equipment Design and Safety
HRID applies GIIP and IFC PS4 requirements to facility design and operation, incorporating safety-by-design measures, controlled access, mechanical and electrical safeguards, and fire and emergency response systems, integrated within the ESMS, OHS framework, and EPC contracts. Under ESAP #14, HRID will engage qualified, IFC-acceptable professionals to: (i) review and certify that Life and Fire Safety (L&FS) systems meet applicable WBG EHS requirements; and (ii) verify during commissioning that construction is implemented in accordance with approved designs and L&FS standards.

Traffic Impacts and Transportation Safety
Traffic represents a key community health and safety risk given the Project’s location along major corridors, including the Sulaimani–Kirkuk Road and Malik Mahmoud Ring Road. Increased heavy vehicle movements during construction may elevate risks for pedestrians and other vulnerable road users. Appraisal identified opportunities to further develop traffic management measures, including route-specific risk assessments, driver competence and fatigue management verification, and systematic monitoring of off-site incidents. HRID will ensure that contractor requirements related to working hours, fatigue management, and safe driving practices are clearly defined, monitored, and enforced across all contractor tiers. Under ESAP #15, HRID will develop and implement a site-specific Traffic Management Plan (TMP) for both construction and operations. The TMP will be based on traffic risk assessments, incorporate off-site risk management measures, reflect local road conditions and community context, and be updated as needed.

Hazardous Materials Management and Safety
Transport of hazardous materials is currently managed within the broader waste and hazardous materials framework, with fuels, chemicals, and other materials transported by authorized contractors in compliance with national requirements and applicable international standards (e.g., ADR). Existing controls include segregation, labeling, designated storage, use of manifests, and spill prevention and response measures. However, appraisal identified the need for project-specific hazardous materials transport procedures and associated arrangements for end-to-end traceability, contractor oversight and verification, and assessment of community exposure risks, particularly along transport routes and near sensitive receptors. Under ESAP #2, HRID will strengthen this framework by developing and implementing a dedicated Hazardous Materials Management Plan, including transport requirements, contractor controls, route-specific risk assessments, and monitoring of transport activities, in line with PS3 and PS4.

Community Exposure to Disease and GBVH
The Project will involve a large, predominantly non-local, contractor-driven workforce, which may increase community risks related to communicable diseases, worker behavior, and safety, particularly for vulnerable groups. Workforce presence may also create perceived and actual risks of GBVH/SEAH affecting women, girls, and other vulnerable populations. HRID has established zero-tolerance policies, Codes of Conduct, and confidential grievance mechanisms; however, effectiveness depends on consistent implementation across all contractor tiers, particularly at the worker–community interface. To address these risks, HRID will enforce contractual requirements across contractors, implement structured accommodation arrangements, and deliver targeted training on worker conduct and community interaction. Accessible, confidential, and survivor-centered grievance mechanisms will be maintained for both workers and community members.

Emergency Preparedness and Response
Construction activities may generate community risks, including fire, explosion, and hazardous materials incidents, particularly given the Project’s dense urban setting. HRID has established an Emergency Preparedness and Response system aligned with GIIP, incorporating defined roles, procedures, drills, and coordination with external emergency services. While the Emergency Preparedness and Response system primarily addresses internal emergency response arrangements, appraisal identified opportunities to further strengthen community-facing components, particularly communication with nearby communities and integration of community considerations. These aspects will be strengthened through enhanced stakeholder engagement and grievance mechanisms to ensure effective communication, preparedness, and response to community-level risks.

Security Personnel
Security personnel will be deployed to manage site access and asset protection, supported by perimeter fencing, 24/7 guarded entry points, CCTV, and lighting. Personnel undergo pre-engagement vetting (including background checks and fitness certification) and receive training on access control, emergency response, conduct standards, and graduated use-of-force protocols. While aligned with standard practice, current arrangements remain largely compliance-based and do not yet reflect a fully risk-based approach consistent with IFC PS4, particularly regarding human rights integration and community-facing accountability. Under ESAP #16, HRID will develop and implement a project-specific Security Management Plan aligned with IFC PS4 and GIIP. This will include enhanced personnel screening; training on human rights, GBVH/SEAH, and community engagement; clear protocols on proportional use of force; and integration with grievance mechanisms to ensure effective management and resolution of security-related incidents affecting workers and communities


PS5 – Land Acquisition and Involuntary Resettlement

The Project is located in the central urban area of Sulaymaniyah on government allocated land (approximately 100,000 m²), representing brownfield redevelopment of a long abandoned public facility. The site is currently vacant, with no active residential, economic, or land based use, and is situated within an urban context where livelihoods are primarily based on wage employment, services, and trade. Vulnerable groups are present within the Area of Influence; however, their vulnerability is not linked to land access or land based livelihoods. Based on ESIA findings and appraisal stage assessments, the Project does not involve physical or economic displacement, private land acquisition, or loss of assets or livelihoods. On this basis, IFC Performance Standard 5 (PS5) is not considered applicable. Although the site has remained unused for several decades and does not support current land use, appraisal findings indicate that documentation of historical land use and verification of absence of third party users is limited. These gaps relate to procedural traceability rather than material resettlement risk and do not affect the conclusion of no displacement impacts.

Stakeholder engagement is structured under a project specific Stakeholder Engagement Plan (SEP) aligned with IFC requirements, covering affected and vulnerable groups within the Project’s urban Area of Influence. As an integral part of SEP, a grievance mechanism (GM) has been established with multiple intake channels, anonymous reporting options, and GBVH sensitive provisions. While broadly aligned with PS1, further operationalization is required. Appraisal identified opportunities to further strengthen documentation of consultation outcomes, formalization of defined disclosure processes, of measurable indicators, and further clarification of roles and responsibilities across the Company, EPC contractors, and operator, including community liaison functions. Under ESAP #8, HRID will finalize and implement the SEP and establish a fully functional GM, including defined response timelines, escalation procedures, systematic recordkeeping, and centralized tracking and reporting. These measures will strengthen stakeholder engagement, improve transparency and documentation, and support adaptive management of stakeholder concerns throughout the Project lifecycle.

Contact Person: Lanya Aziz Muhemed
Company Name: Hiwa Rauf for Investment and Development / Ltd
Address: Hiwa Rauf for Investment and Development, Building 1, Baharan Malik Mahmud Road, Sulaymaniyah 46001, Kurdistan Region, Iraq
Email: lanya.aziz@hiwarauf.com
Phone: +964 770 761 2665
Facsimile:

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	HRID will update and formalize its E&S Policy to fully align with the IFC Performance Standards and to underpin the development of a project level ESMS consistent with PS1 requirements.	07/31/2026
2	HRID will finalize and implement construction phase and operations phase environmental and social management plans (ESMPs), consistent with ESIA findings and the requirements of IFC PSs.ESMPs:- Air Quality & Dust MP- Noise & Vibration MP- Waste MP- Hazardous Materials MP- Water & Wastewater MP- Traffic & Road Safety MP (ref ESAP#15)- Labor & Working Conditions (PS2) (ref ESAP #4)- Occupational Health & Safety (OHS) Plan (ref ESAP#11)- Resource Efficiency (Operation Phase)	10/05/2026
3	HRID Client will finalize and operationalize the project specific ESMS	09/30/2026
4	HRID will update contractor (EPC, construction, and O&M) contractual requirements and establish a robust contractor labor management and verification system in line with IFC Performance Standards. This will include: (i) integration of ESMS, ESMP, EHS, labor (PS2), grievance, and emergency preparedness requirements into all contractor and subcontractor contracts, as well as supervision and performance monitoring arrangements; (ii) incorporation of PS2 aligned labor provisions across all contractor tiers with clear communication to, and formal acknowledgment by, workers; and (iii) implementation of periodic compliance verification (audits, document reviews, and worker interviews), with corrective actions tracked, enforced, and reported. HRID will (i) finalize and operationalize the Contractor Labor Management and Verification System across all contractor and subcontractor tiers, ensuring implementation of ESMS, ESMP, EHS, labor (PS2), grievance, emergency preparedness, and contractor management requirements; and (ii) demonstrate effective implementation through structured contractor performance reporting, periodic audits, inspections, document reviews, worker engagement, and corrective action tracking across all contractor and subcontractor tiers.	10/05/2026
5	HRID will formalize and operationalize the E&S organizational structure, including adequate resourcing and defined responsibilities to ensure effective ESMS implementation.	07/31/2026
6	HRID will update and operationalize the project specific EPRP to ensure full alignment with PS1, PS2, PS4, and WBG EHS Guidelines, including enhanced contractor integration, systematic testing (e.g. drills), and incorporation of emerging external risks (e.g. drones, falling objects, and debris).	07/31/2026
7	HRID will formalize ESMS monitoring, incident tracking, and reporting procedures, and conduct periodic ESMS reviews in line with PS1 adaptive management principles.	07/31/2026
8	HRID to finalize and implement the stakeholder engagement plan (SEP) and establish a fully functional grievance mechanisms (GM), including defined response timelines, escalation procedures, and systematic recordkeeping, in line with PS1 requirements	12/05/2026
9	HRID will align its HR Policy with IFC PS2 requirements to (i) include provision related to freedom of association and collective bargaining right, (ii) establish and implement a structured worker training and awareness system applicable to all workers, including mandatory induction and refresher training on the Code of Conduct, labor rights, and GBVH/SEAH prevention, alongside systematic verification of understanding and compliance through supervision, spot checks, and integration into contractor performance monitoring.HRID will (i) implement the IFC PS2-aligned Human Resources and Contractor Management Framework across all contractors and subcontractors, including mandatory induction and refresher training on the Code of Conduct, labor rights, and GBVH/SEAH prevention; and (ii) demonstrate effective implementation through systematic verification of worker awareness and compliance, including supervision, inspections, spot checks, contractor audits, corrective action follow-up, and integration into contractor performance monitoring.	09/30/2026
10	HRID will strengthen the GM by (i) integrating contractor and subcontractor grievance processes into a centralized system; (ii) defining clear roles and responsibilities for intake, escalation, and resolution; and (iii) establishing systematic monitoring, analysis, and reporting of grievance data. The GM will remain accessible to all stakeholders and responsive to labor, community, GBVH/SEAH, and other relevant concerns, with appropriate recordkeeping and follow up	09/30/2026
11	HRID will develop and implement OHS Plan applicable to all worker categories.HRID will (i) finalize and operationalize the Project Occupational Health and Safety (OHS) Plan applicable to all worker categories, ensuring alignment with the established contractor OHS management framework; and (ii) implement and demonstrate effective application of the OHS management system through systematic inspections, audits, training, incident reporting, corrective action tracking, and contractor performance monitoring across all contractor and subcontractor tiers.	12/05/2026
12	HRID will develop workers’ accommodation plans for all accommodation types, taking into consideration the IFC Guidance Note on Workers’ Accommodation: Processes and Standards, as a source of good international industry practice.	12/05/2026
13	In the event of a collective workforce reduction, HRID will prepare and implement a Retrenchment Plan consistent with IFC PS2 and applicable national labor legislation. The Plan will include consultation, notification, severance arrangements, and measures to mitigate adverse impacts on affected workers.	07/20/2027
14	HRID will, engage suitably qualified, IFC acceptable professionals to: (i) review the design and certify that L&FS systems meet applicable WBG EHS requirements; and (ii) verify during commissioning that construction has been carried out in accordance with the approved design and applicable L&FS standards	10/05/2026
15	Develop and implement site-specific Traffic Management Plans (TMPs) to address: (i) routing of heavy vehicles away from community areas where feasible; (ii) signage, speed limits, and flagging protocols at site access points; and (iii) responsibilities and monitoring frequency.	12/05/2026
16	Develop and implement site-specific Security Management Plans (SMPs) aligned with IFC PS4 and good international industry practices. This will include: (i) enhanced personnel screening; (ii) training on human rights, GBVH/SEAH, and community interaction; (iii) clear protocols on proportional use of force; and (iv) integration with grievance mechanisms to ensure effective management and resolution of security related incidents affecting workers and communities	09/30/2026