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
Identification and Management of E&S Risks: Enlight has established an E&S Policy with commitments to identifying and managing E&S risks related to its business activities and complying with Mexican E&S regulations. The policy outlines procedures for monitoring and tracking environmental performance. Additionally, Enlight has developed an environmental management program that defines roles and responsibilities for assessing and controlling EHS risks during the installation, operation, and maintenance phases. This program states mitigation measures in accordance with local regulations and provides effective supervision of its business activities. Additionally, Enlight has a procedure to manage and monitor EHS and OHS risks. As per Mexican regulations, the type of projects targeted by NZF III (rooftop solar PV systems, carport solar PV systems and BESS systems) do not require the development of an E&S impact assessment.
As per ESAP #1, Enlight will develop an E&S Management Procedure (ESMP) for the NZF III sub-projects aimed at identifying and managing E&S risks and impacts in line with IFC PS and relevant WBG EHS Guidelines. The ESMP will include specific steps to include legal E&S provisions for contractors and monitor their performance.
Organization: Enlight has an EHS team led by a coordinator that reports to the Process and Operational Excellence Manager, as well as on-site EHS inspectors. To further enhance its E&S capacity, as per ESAP #2, Enlight will develop an E&S Training Plan to ensure personnel competency with IFC PS requirements and applicable WBG EHS Guidelines, including social risk management.
Emergency Preparedness and Response (EPR): Enlight has EPR procedures, including for fire emergencies, photovoltaic panel emergencies, disaster risk management, and emergency situations in the office building and operations. The EPR procedures include vulnerability analysis, emergency organization and brigades, evacuation, coordination with external services, incident analysis, and testing through drills. To further enhance the EPR measures, as per ESAP #3, Enlight will develop an EHS and life and fire safety (L&FS) Procedure for the Project aligned with IFC PS and General EHS Guidelines, specially focused on fire emergency risk associated with BESS, establishing criteria to identify, assess, and manage L&FS risks from BESS and define corresponding control measures. These may include site-specific fire emergency preparedness and response planning and coordination with relevant authorities, communication protocols, restricted access control measures, verification that emergency procedures are adequately addressed by the client, and stakeholder and community collaboration in fire emergency situations.
PS2: Labor and Working Conditions
At the time of appraisal, Enlight had approximately 145 direct employees and around 338 contract workers.
Enlight has internal policies governing labor and working conditions, aligned with national regulatory requirements and IFC PS2 principles. These policies cover key aspects of worker management, workplace relations, terms and conditions of employment, worker rights and obligations, non-discrimination and equal opportunity, disciplinary procedures, and standards of ethical conduct. They are communicated to workers during the onboarding processes, and through internal communication mechanisms, and annual training. Enlight also has policies addressing workplace and sexual harassment, gender-based violence, awareness provisions applicable to employees, contractors, suppliers, and third parties.
Enlight has a formal grievance mechanism for employees that allows anonymous reporting and includes centralized registration, classification, assignment, defined timelines, investigation, confidentiality and non-retaliation safeguards, disciplinary measures, and formal closure and escalation procedures, supported by internal committees as needed.
As part of ESAP #4, Enlight will update its worker’s grievance mechanism to align it with IFC PS2, ensuring applicability to both direct and contracted workers, strengthening communication and awareness across all worker categories and including specific measures to address sexual exploitation, abuse, and harassment (SEAH) grievances.
Enlight has established a formal OHS framework, which defines policies, responsibilities, and procedures applicable to direct employees, contractors, and subcontractors, which are generally aligned with IFC PS2 requirements. The framework includes provisions for risk identification and assessment, mandatory use of personal protective equipment (PPE), safety requirements for high-risk activities, emergency response planning, and incident reporting and investigation, OHS inspections, and corporate-level EHS indicators and training matrices. It also establishes roles and responsibilities across the organization, including EHS management and supervisors, and requires the implementation of project-level safety documentation such as risk analyses, safety files, and training records.
Enlight’s OHS procedures and tools include protocols for accident reporting and investigation, lifting operations, working at heights, and electrical intervention protocols including lockout/tagout (LOTO). In addition, clients share specific EHS requirements, which require Enlight to adapt its safety standard such as the use of scaffolding or lifting equipment.
The OHS framework establishes general provisions to identify transport safety risks, including vehicle inspection and licensing requirements. As per ESAP #5, Enlight will develop a Transport Safety Procedure aligned with relevant WBG EHS Guidelines covering training and licensing requirements, vehicle requirements, incident investigation, speed limits, and operating rules.
Enlight engages workers through an Engineering, Procurement and Construction (EPC) contractor model, where contractors are responsible for the recruitment, employment, supervision, payroll, and management of their own workforce, while Enlight is responsible for procuring solar PV panels and BESS. Enlight has established a contractor management framework for the selection, evaluation, and oversight of EPC contractors. This framework requires contractors to demonstrate compliance with applicable legal and labor requirements. In addition, a formal due diligence process for contractors is in place, requiring submission of detailed information on social security obligations, workforce composition, training, and OHS-related documentation, including risk analysis by job position and PPE requirements.
Enlight has established a Supply Chain Policy covering E&S risks such as child labor, human trafficking, excessive working hours, withholding of worker documents, and protection of vulnerable and migrant workers.
As part of ESAP #6, Enlight will strengthen its current solar PV panel and BESS supply chain management process and procurement system by creating and implementing a robust Supply Chain Management System (SCMS) aligned with IFC PS2 requirements. The SCMS will integrate solar PV panel and BESS supplier evaluation criteria within existing qualification and performance assessment processes to explicitly incorporate child labor, forced labor, and significant OHS issues considerations, and introduce tools designed to enable the tracing of key equipment suppliers. Specifically for solar PV panel suppliers, these tools will make best efforts to enable traceability of the silicon materials and components stream up to at least polysilicon and where feasible, tracing will extend further to the sources of metal grade silicon or quartzite. Additionally, the framework will include thorough mechanisms for evaluating and verifying compliance, ensuring ongoing oversight and accountability throughout the solar PV panel supply chain.
PS3: Resource Efficiency and Pollution Prevention
Even though Enlight is not a significant user of water and energy, it has procedures to promote their efficient use in its offices. The water used for maintenance activities is provided by the clients, sourced from the municipal system.
The NZF III sub-projects are expected to avoid approximately 75,017 tCO2e per year over the investment period, calculated based on projected net electricity generation and displacement of grid and on-site fossil-fuel electricity.
Enlight uses limited quantities of hazardous materials, and its environmental management program establishes protocols for their safe handling, temporary storage, transport, recycling, or final disposal, in compliance with applicable Mexican regulations. In addition, Enlight includes contractual requirements for contractors to manage hazardous materials and waste. These requirements include inventorying requirements, labeling materials, providing material safety data sheets (MSDS), restricting access to storage areas, defining storage requirements, and ensuring proper waste segregation, collection, storage routing, recycling/valorization, and final disposal. During installation activities, broken or damaged solar PV panels are collected by the supplier. To strengthen waste management practices, as part of ESAP #1, Enlight will develop a Waste Management Procedure aligned with IFC PS3 and applicable WBG EHS Guidelines. This procedure will include a review of permits, verification of chain-of-custody records, and confirmation of compliance at final disposal sites. It will: (i) establish or formalize arrangements for solar PV panel waste management and recycling; (ii) confirm the use of licensed contractors and authorized facilities; and (iii) integrate solar PV panel end-of-life management consistent with WBG EHS Guidelines on waste handling and tracking.
PS4: Community Health, Safety, and Security
The Project presents limited E&S risks to community health and safety (H&S), as activities are primarily developed within areas in client-owned facilities that are normally not accessible to the public. Potential risks to communities, if any, are related to transportation of personnel, equipment, and materials; minor civil works and installation activities; and interaction between workers and contractors and the community in certain sites (e.g., commercial centers or hotels).
As part of the rooftop solar PV sub-project design, Enlight has established procedures to assess the structural integrity of the project sites. Internal structural engineers review each proposed site and determine the maximum carrying capacity of rooftop solar PV installation. Enlight activities present no or limited life and fire safety risks to neighboring communities.
For projects involving BESS, including lithium-ion batteries, Enlight applies the manufacturer’s safety recommendations and operating requirements, together with internal emergency and EHS procedures, to reduce the likelihood and consequences of incidents.
As part of ESAP #7, Enlight will develop a Community H&S Procedure to identify and mitigate community H&S risks, including criteria to identify sub-projects with potential interaction with community members and define corresponding control measures such as communication protocols, workers’ and contractors’ code of conduct, including SEAH provisions, aligned with IFC PS requirements and applicable WBG EHS Guidelines.
