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: Maskh has implements an ESMS comprising Land Acquisition Policy, Human Rights Policy and Customer Relations and Protection Policy; as well as embedded procedures for environmental and social screening, risk categorization, preparation of project-specific instruments (eg. ESMPs), health, safety environment and quality (HSEQ), waste management, stakeholder engagement, grievance management, and monitoring and reporting. Although the ESMS is guided by the DARES ESMF, there is limited implementation arrangement at project site level. As part of the IFC financing, Maskh will strengthen its ESMS by; (i) preparing an overarching E&S policy with clear commitments on the scope of E&S issues related to the operations; (ii) preparing a GBV/SEAH Policy covering its operations, especially the SHS sub-project; (iii) preparing a Land Acquisition Procedure that includes a requirement for selection of only sites that avoid physical or economic activities that do not trigger involuntary displacement as defined in IFC PS 5, and requirements for monitoring of land acquisition related social risks; (iv) updating the supply chain management plan with a Supply Chain Due Diligence Procedure; (v) updating the Emergency Preparedness and Response Plan; (vi) preparing a corporate E&S monitoring and reporting procedure and associated Key Performance Indicators (KPIs) for tracking and monitoring E&S performance including OHS leading and lagging indicators, labor, waste and hazardous materials and corrective action management as well as periodic internal audits and management reviews, regularly updated risk registers informed by incidents and grievances; (vii) preparing an E&S training plan that guides how workers, including in the SHS sub-project, are trained on core E&S policies, plans standard operating procedures and clearer site-level roles and reporting lines; (viii) preparing a comprehensive Occupational Health and Safety Management Procedure for entire operations; (ix) updating the Waste Management Plan to meet site-specific requirements and include a basic lifecycle and decommissioning approach for key components (batteries and PV panels); (x) developing a Security Management Plan consistent with IFC PS 4, and; (xi) preparing a corporate Stakeholder Engagement Plan (ESAP #1).
Identification and Management of Risks and Impacts: Maskh has established procedures for identifying E&S risks and impacts as part of its ESMS and project-level documentation. Also, the ESMS adequately defines the screening process. Furthermore, the DARES ESMF mini grid site exclusion list, that the company complies with, includes avoidance of sites located in legally protected areas (e.g., national parks, conservation areas, forests), in internationally recognized areas, in critical natural habitats and where mini grid construction and operation will cause significant degradation of natural habitats (e.g., mangroves); hosts cultural heritage or sacred sites; under active dispute or litigation; environmentally high-risk (flood-prone, erosion-prone); land that belongs to vulnerable groups or serving as a primary source of livelihood. For existing sites, Maskh has developed ESMPs on a cluster basis for mini-grid projects and obtained approvals. Similarly, for all Project activities, the company will (i) develop and maintain a centralized E&S risk register with assigned responsibilities and a closure verification mechanism for routine risk management across the business, and; (ii) conduct an E&S risk assessment for the SHS sub-project in line with IFC PSs and develop a SHS Standard Operating Procedure aligned with the risks identified in its risk register (ESAP #2).
On land acquisition, Mask has developed a detailed Land Acquisition Policy governing both outright purchase and land lease arrangements. The Company is expected to acquire all 38 mini-grid sites to be financed by IFC through lease agreements or willing buyer/willing seller transactions. No physical or economic displacement is expected in the acquisition of these sites and no outstanding community grievances have been reported related to the land acquisition process before. There will be no additional land acquisition for the distribution lines, which will follow village road alignments to client premises. For all future sites to be considered for the Project, Maskh will apply site selection criteria that avoid physical or economic displacement, as defined in IFC PS 5. Should a negotiated acquisition not be achieved, Maskh will consider alternative sites and not resort to any form of eminent domain. These commitments will be implemented as defined in the Land Acquisition Procedure required per ESAP #1 above.
Management Programs: The Company’s E&S risk management program consists mainly of; a (HSEQ) Guideline, an Operations and Management (O&M) Plan, a Waste Management Plan, a Transportation and Logistics Plan, a Supply Chain and Procurement Management Plan, a Climate Risk Memo, and the suite of site-level ESMPs. The ESMPs are prepared at a cluster level, and don’t consistently address site-level management issues. Therefore, Maskh will develop a site-specific Construction ESMP (CESMP) Template that would operationalize site-specific E&S pre-clearance process for (i) pre-construction E&S assessment, (ii) safety risk assessment (iii) site security risk assessment (iv) site specific transport risk assessment, (v) site specific stakeholder engagement, and (vi) construction kick-off and completions sign-off. This CESMP Template will be used as a Go-No-Go management tool to ensure that all E&S processes are completed before commencement of groundbreaking activities at each mini-grid project site as well as prior to deploying the SHS business across any state (ESAP #3). The SHS E&S Risk Management and Monitoring Plan will be implemented to guide risk management in all SHS activities.
Organizational Capacity and Competency: The Company Managing Director is supported by directors responsible for key functional areas including operations, finance, administration, logistics, human resources, and customer relations. At the operational level, the HSE Officer reports to the O&M manager. The Company carries out ad hoc competency management processes including periodic E&S training, which will be improved according to the requirement in ESAP #1 above. Going forward, Maskh will bolster its E&S capacity by; a) appointing a dedicated experienced EHS manager at a manager level supported by suitably experienced HSE Officers at State level, with E&S management scope for both mini-grid and SHS sub-projects; b) mandating construction contractors to have dedicated E&S organizational structure comprised of at least a dedicated HSE and human resource personnel (ESAP #4).
Emergency Preparedness and Response: Maskh‘s HSEQ Guidelines and O&M Plan include general safety provisions related to emergencies including broad procedures for responding to incidents such as electrical faults, fire events, and operational disruptions, as well as general requirements for incident reporting, emergency coordination, and response actions during system failures or safety events. Also, the Company implements basic emergency measures at its operational sites including fire extinguishers and site evacuation schemes. As part of the ESMS update (ref. ESAP #1) Maskh will develop an EPRP that will include; (i) emergency scenarios related to diesel spillage and severe weather (including heatwaves, heavy rains and flooding) leading to collapse of structures like distribution poles; (ii) engagements with local emergency services in planning drills; clear schedules for emergency response training and post-training evaluations to measure effectiveness; (iii) performance indicators to track emergency preparedness; (iv) clear roles and responsibilities, and (v) a requirement for clear emergency instructions to be displayed at all mini-grid sites in the EPRP and (vi) community awareness on site emergency response.
Monitoring and Review: General requirements for monitoring, reporting, and review of E&S performance across the mini-grid operations are outlined in core documents including the ESMS, ESMPs, and O&M Plan, The E&S monitoring requirements collectively identify monitoring responsibilities, performance indicators, and reporting obligations, including periodic reporting to regulatory bodies. The E&S monitoring and reporting procedure required in ESAP #1 above will include a centralized ESMS tracking system for aggregating E&S data, tracking performance indicators (e.g., incident rates, near-misses, grievance resolution times) and provisions for periodic, formalized internal management reviews of E&S performance to drive continuous improvement and a clear reporting structure from the lowest monitoring site to the Board of Directors. The E&S monitoring will also include issues related to land acquisition and use (per ESAP #1 above), both from internal monitoring and external stakeholders (including external grievances raised), as well as issues related to SHS sub-project activities.
Supply Chain: Maskh procures solar panels, inverters, batteries, charge controllers and associated electrical equipment through third-party suppliers; and has developed a Supply Chain Management Plan which establishes its framework for procurement and supply chain management across mini-grid projects, including procurement principles, supplier selection, logistics coordination, contract management, and performance monitoring. The SCMP incorporates E&S safeguards within procurement practices, including requirements to avoid suppliers engaged in forced labor and child labor encompassed in its Forced Labor Declaration and Contractor Code of Conduct. As part of the ESMS upgrade (ref. ESAP #1), Maskh will update its SCMP to include a formal supplier due diligence procedure, incorporating E&S and labor requirements into supplier and seeking traceability information for solar PV modules and key components to the extent practicable, and implementing supplier monitoring and corrective action arrangements, including the ability to shift suppliers where material labor, human rights, safety, or environmental non-compliance is identified.
PS 2: Labor and Working Conditions
Maskh currently employs 58 staff comprising 31 direct employees and 14 outsourced or indirect workers as well as 13 Contractors workers. The workforce is split into 93% male and 7% female and is expected to grow as the Company expands its mini-grid coverage. During mini-grid site construction, workers are recruited from the local community by contractors, and their numbers are based on workforce needs at each phase of construction. Maskh has a dedicated HR department led by a HR Manager, reporting to the Managing Director.
HR Policies and Procedures. Maskh has established basic human resources (HR) arrangements, primarily reflected through individual employment contracts, service agreements, organizational structures, and its formal Forced Labour Declaration including commitments to fair labor practices and compliance with national labor requirements. Also, individual contracts or employment offers include provisions like define roles, responsibilities, confidentiality obligations, and termination conditions, providing a baseline level of clarity on job expectations. Going forward, Maskh will consolidate and implement a comprehensive HR manual that include provisions on working conditions and employment terms including (i) wages and benefits (ii) working hours and leave; (iii) non-discrimination and equal opportunity; (iv) disciplinary and termination procedures; (v) communication of employment terms to both staff and contractors; (vi) GBV/SEAH management mechanisms; (vii) conditions for contracted workers including third party labor audits in compliance with Nigerian labor law, IFC PS 2, (viii) monitoring of labor conditions including grievances, specific OHS obligations related to a safe a Working hours and leave; (ix) freedom of association and collective bargaining; and, (x) retrenchment (ESAP #5).
Working Conditions and Terms of Employment. Maskh’s HR framework including the Contractors Code of Conduct and the Staff Code of Conduct on SEAH introduce behavioral standards and expectations related to workplace conduct, safety, and prevention of social risks, including GBV, child labor, and harassment which are broadly aligned with ethical labor practices and aspects of IFC PS2 at a policy level key. Each worker has a written contract that outlines the job expectations. Work is performed in one shift of 8 hours per day and 40 hours a week. Overtime work is monitored for each worker to keep it within regulatory limits and paid accordingly. Also, all direct employees are enrolled in the mandatory social insurance scheme and salaries are paid regularly. Finally, Maskh’s existing Forced Labor Declaration prohibits child and forced labor with enforced age verification during recruitment for own staff and third-party contractors. As part of the formalization of the HR Manual (ref. ESAP #5), Maskh will strengthen consistency and completeness by ensuring that all contracts and offer letters include comprehensive provisions in accordance with the national labour law and aligned with IFC PS2.
Workers Grievance Mechanism: Maskh has established foundational worker grievance processes through its current HR framework outlined in its ESMS and ESMP. As part of the formalisation of the HR Manual (ref. ESAP #5), Maskh will develop and implement a formal Worker Grievance Redress Mechanism (WGRM) that covers all workers, contractors, wholesalers and agents associated to the SHS business. The WGRM will include: (i) clear grievance procedures (submission, acknowledgement, investigation, feedback, resolution, closure); (ii) confidential and anonymous reporting channels; (iii) protection against retaliation; (iv) defined timelines for grievance handling; (v) grievance logging, tracking, and reporting system; (vi) communication and awareness for all parties; (vii) compliance requirements for contractors, wholesalers and agents associated with the Company, and; (viii) integration with HR management and overall GRM system.
Occupational Health and Safety; The key OHS risks in this project include electric shock and arc flash, battery fires or explosions, falls from heights, heat stress, manual handling injuries, excavation accidents, vehicle incidents. Maskh has established an OHS framework within its HSEQ Guidelines, which covers; hazard identification, incident reporting, training, emergency procedures, and workforce responsibilities across project activities. Also, the guidelines include a suite of operational safety controls and workplace practices. As part of its ESMS update (ref. ESAP #1), Maskh will develop and implement a comprehensive Occupational Health and Safety Management Procedure including: (i) site-specific hazard identification and risk assessments; (ii) Standard Operating Procedures (SOPs) for high-risk tasks (electrical work, battery handling, maintenance); (iii) PPE provision, enforcement, and monitoring system; (iv) structured OHS training program with documented records and refresher training; (v) formal incident reporting, investigation, and near-miss tracking system; (vi) OHS performance monitoring and reporting across all sites; (vii) contractor OHS management and enforcement; and (viii) integration of security-related risks and safe field operations into OHS practices. The company will integrate OHS topics in the annual E&S training program.
Workers Engaged by Third-Party: Maskh directly undertakes most of its mini-grid construction and oversees the wholesalers and agents involved in the SHS activities. The Company has established a Contractor Code of Conduct which establishes behavioral standards and obligations for contractors, focusing on prevention of social risks including GBV, child labor, and unsafe practices. Requirements for labor compliance audits will be included in the E7S monitoring and reporting procedures (ESAP #1). To enhance compliance with labor and OHS requirements, the Company will integrate specific E&S and labor compliance clauses including and the Environmental, Health and Safety (EHS) Guidelines – Minigrid Renewable Energy Project (2025) document into all third-party contractor agreements. (ESAP #6).
PS 3: Resources Efficiency and Pollution Prevention
Water and Energy use. Water resource needs during construction and operations will be limited, primarily for periodic cleaning of solar panels, construction activities (e.g. dust suppression) and workers’ welfare – with supply from site boreholes for independent mini-grid sites, and clients’ water supply systems for sites build within client premises. Energy use during construction is associated with transportation, logistics and equipment deployment, which are temporary and limited in scale. During operations, the Company's mini-grid systems will rely primarily on solar generation with battery storage, supplemented by backup diesel to ensure system reliability during periods of low solar generation or peak demand. The E&S monitoring and reporting procedure required per ESAP #1 above will include water and diesel consumption monitoring.
Air and greenhouse gas emissions. 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 through the site-specific HSE management plans. Greenhouse gas (GHG) emissions are expected to be limited and primarily associated with construction activities and occasional operation of back-up generators. Annual GHG emissions are expected to remain below 25,000 tons of CO2 equivalent (tCO2eq/year).
Wastewater. Wastewater from the washing of solar panels using biodegradable soaps drains into the soils on-site. The project sites have ventilated improved pit (VIP) latrines which can be emptied by a sewerage contractor when required, for offsite disposal. The latrines are sited at least 30 meters from known water sources and do not reach the groundwater table to avoid microbial contamination. Given that these are occasionally used by the few staff who visit or operate these sites, soil and groundwater pollution related to their usage is not expected to be material.
Hazardous Materials and Waste: Hazardous materials associated to Maskh’s activities include; (i) lithium-ion and/or lead-acid batteries used in energy storage systems; (ii) solar PV components and inverters classified as electronic waste at end-of-life especially associated with SHS; (iii) diesel and associated storage; (iv) used oil, lubricants, and generator maintenance waste. Maskh’s activities generate typical construction non-hazardous waste like wooden boxes, cardboard wrappings, plastic, electric cables and domestic waste. Maskh has developed and is implementing a generalized, template-based Waste Management Plan. The plan defines general requirements for waste minimization, segregation, storage, handling and disposal. Non-hazardous waste is disposed of via local municipal systems with volumes not consistently captured. The Waste Management Plan also has specific provisions for battery recycling under Extended Producer Responsibility frameworks. In addition to the update of the Waste Management Plan to include a basic lifecycle and decommissioning approach for key components (batteries and PV panels) (ESAP #1), the Company will i) document hazardous material inventory and train the site workers on hazardous materials handling and emergency response; ii) formalize agreements with waste management companies and document waste transfer and disposal process to ensure compliance with the Waste Management Plan, national regulatory requirements and IFC PS3 at all Project sites (ESAP #7).
PS 4: Community Health, Safety and Security
Infrastructure and Equipment Design and Safety: Risks associated with battery energy storage systems and the distribution network include fire, electrocution, pole collapse, falling conductors, and public exposure to energized equipment. To mitigate these risks, the Company designs, installs and operates the mini-grids and power distribution system in line with the Nigeria Electricity Distribution Code and Nigerian Electricity Supply and Installation Standards, and has obtained requisite regulatory approvals. In addition, the Company undertakes routine inspection and maintenance of the mini-grid infrastructure and distribution network and conducts community sensitizations on electrical safety within the catchment communities.
Road Safety & Traffic Management: Maskh’s community health and safety risks are expected to be limited and site-specific, given the small footprint of the mini-grid infrastructure and its location within already modified community settings. Community engagement and consultation is front-loaded as part of the project design as stakeholder and customer information as well as site selection relies on widespread community acceptance of the project. Maskh’s current community safety risk management practices include; (a) basic safety controls such as community-level engagement front-loaded during site selection; (b) risk assessments and use of standard electrical equipment; and, (c) installation of safety signage and physical barriers around work zones to prevent unauthorized access. However, Maskh does not operate a large fleet transporting materials or personnel through rural communities, but its fleet is expected to grow including that of its contractors, wholesalers and agents associated to their SHS business. As part of the CESMP development and implementation (ref. ESAP #3), Maskh will: (i) will develop a community health, safety, and security framework that covers both mini-grids and the SHS business; (ii) mandate contractors to prepare and implement a Traffic/Journey Management Plan to govern the movement of project vehicles including bikes and equipment delivery, aiming to minimize risks to community members, particularly vulnerable groups like children; (iii) develop site-specific emergency preparedness and response plans that outline procedures for communicating relevant emergency information to the surrounding community in a timely and effective manner in line with IFC PS4 and GIIP; and.(iv) prepare and deliver training to all drivers including to contractors, wholesalers and agents on safe driving approaches and code of conduct including GBVSH/SEAH risks.
Security Management: Maskh’s current operations cover areas with complex security context especially in Northern Nigeria. Also, Maskh relies on a highly localized but pragmatic approach to site security including the utilization of local vigilante groups and community-based security personnel to protect project assets with no formal security management procedure. As part of this financing, Maskh will complete a security risk assessment and develop a Security Management Plan (ref. ESAP #1) that would include structured vetting and screening processes for all security personnel and mandatory, documented training on human rights and rules of engagement for all community security personnel and vigilantes utilized by the project, consistent with IFC PS 4.
