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
The development company UDPR (“the Developer”) initiated the project in 2019. The Project is structured under two legal entities (Volyn West Wind-2 LLC and Volyn West Wind-3 LLC) for technical grid connection purposes; however, it is managed and operated as a single, integrated development. On September 23, 2025, the sponsor acquired the project. Under the terms of the acquisition agreement, the developer remains responsible for pre-construction activities and implementation until the Project reaches Ready-to-Build (RTB) status. In 2025, a new national Environmental Impact Assessment (EIA/OVD) procedure was launched, resulting in positive EIA Conclusions issued by the competent authority on February 4 and 6, 2026. Registered users can access this EIA at the national online platform “EcoSystem” website https://eco.gov.ua/.
The developer engaged an environmental and social consultant to conduct an ESIA for the project to align with lenders’ requirements. The Project's E&S impacts were identified through both the national EIA/OVD process, and the additional E&S assessments and plans prepared for the Project.
At the time of disclosure, the ESIA has not yet been finalized, and further assessments are required: a baseline noise and shadow flicker assessment, as well as supplementary biodiversity studies (ESAP #3.1, 3.2. and 6.1. respectively). The ESIA component covering the OHTL, which was not included in the initial national EIA (OVD) process, is also being finalized. The ESIA completion has been delayed due to conditions related to the invasion, including the limitation of available qualified personnel for extended field activities. The sponsor has committed to amend the ESIA to bring it into compliance with IFC PSs (ESAP # 1.1.), which is expected around September 2026. The borrower will implement and maintain a project-specific ESMS, including effective implementation of the ESMP and associated management plans prepared for the Project. The ESMS will also incorporate the findings and mitigation measures of the final ESIA. The implementation will be supported through assignment of qualified E&S and OHS personnel, as well as a designated ESAP owner (ESAP #1.1). Information disclosure regarding the ESIA and activities will be proportionate and strictly adapted to security considerations during martial law, preventing sensitive information related to critical energy infrastructure, locations, or logistics from being publicly disclosed where it may pose security risks. Construction and operations phase E&S management and monitoring responsibilities will be shared between the borrower and its contractors.
To manage the risks, the borrower has developed a comprehensive suite of 19 EHS management plans and will implement the ESMP and associated management plans, updating or improving them to reflect actual site conditions and lenders’ requirements. A project-specified Grievance Mechanism (GM) has been developed, which covers separately GM for the workers and for the communities. The borrower will provide sufficient staff resources to manage E&S performance across the project life cycle.
The project team has been defined with clear roles and responsibilities to oversee project activities. The dedicated E&S team currently includes a Community Liaison Officer (CLO), an OHS engineer, and an E&S specialist, who will collectively manage compliance, contractor oversight, and community relations throughout the Project lifecycle.
Early mobilization works started in January 2026. A general contractor was selected for the Project and the sponsor has included E&S provisions into construction contracts with direct contractors, which will be cascaded down to subcontractors. The project contractors and subcontractors are required to implement the relevant sections of the Project’s ESMS and ESMPs that fall within their scope of work. The inspection and audit system, tracking non-compliances, and the cascading of E&S requirements across the supply chain have been implemented through the presence of the sponsor’s EHS personnel and regular independent monitoring reports. An inspection and audit system will be established and maintained, as well as systematic tracking and closure of non-compliances (ESAP #1.2).
Public consultation and engagement activities have been conducted systematically to meet both national requirements and international lenders’ standards. The Project underwent a Strategic Environmental Assessment (SEA) in 2024 and national EIA processes, which included public disclosures and online public hearings in January 2026, culminating in the positive EIA decisions in February 2026. As part of the ESIA process, 14 meetings and 12 focus group discussions were held in June 2025 across affected territorial communities. These sessions actively engaged community leaders, and local farmers to capture concerns regarding local roads, worker influx, and communication preferences.
Since 2019, the developer has conducted continuous one-on-one negotiations with landowners and land users based on a voluntary agreement approach. These consultations were designed for informed consent, with specific accommodations made to facilitate the participation of women and vulnerable groups. On January 15, 2026, an in-person meeting took place in the Project-affected community to present relevant E&S information, timelines, and introduce the Project Public GM.
To formalize these ongoing efforts, a formal SEP was prepared in April 2026. It identifies key internal and external stakeholders, ranging from directly affected landowners and residents to interested parties such as national authorities, NGOs, and the media. The borrower will implement and maintain the SEP across construction and operation for effective stakeholder engagement, the operation of a multi-channel GM, and structured documentation of engagement activities. Furthermore, the borrower will implement ongoing disclosure and community reporting procedures, providing regular updates on Project activities in an accessible format (ESAP #1.4). Crucially, this information disclosure will be proportionate and adapted to security considerations during martial law, so that no sensitive information related to critical energy infrastructure, locations, logistics, or operations is publicly disclosed where it may pose security risks.
The Project is not anticipated to result in significant impacts on cultural heritage. Reviews of the Project area, including the national EIA, the Detailed Territory Plan, and formal confirmation from the Department of Culture, Religion, and Nationalities of the Volyn Regional State Administration, indicate that there are no legally protected sites, UNESCO World Heritage sites, or officially registered archaeological or cultural monuments within the designated land plots. Consequently, receptor sensitivity is generally considered low, and the magnitude of potential impacts from construction-related ground disturbance is assessed as negligible.
Beyond the known areas, there remains a residual risk of encountering previously unknown archaeological or historical materials during ground-disturbing activities across the Project site. To manage this, the borrower will implement a Cultural Heritage Protection and Management Plan. As a core component of this plan, the borrower will apply and enforce the Chance Find Procedure during construction, including contractor awareness, work stoppage requirements, notification of competent authorities, and monitoring of compliance through site inspections (ESAP #1.3).
Supply Chain and Contractor Oversight: suppliers and contractors E&S requirements are in place and confirmed by a commitment letter from Nordex (supplier of turbines), including supply chain mapping and a requirement to notify the borrower and EBRD of any supplier changes. While this demonstrates progress and alignment with lender expectations, the effectiveness of the approach will depend on practical implementation, including maintaining visibility over supply chain changes and for consistent application of E&S requirements across suppliers.
PS 2 – Labor and Working Conditions
The number of workers during construction will vary depending on the phase of activities, with approximately 200 workers expected at peak construction. The majority of the workforce is anticipated to be Ukrainian nationals, including local workers, with potential engagement of a limited number of expatriate personnel for specialized roles. During operation, the workforce is expected to be approximately 20 personnel.
The Project applies a labor management framework (including HR Policy, Labor Management Plan, and Code of Conduct) aligned with Ukrainian labor legislation, IFC PS2, and relevant ILO standards. These documents define terms of employment, working conditions, worker behavior, and interaction with local communities. All workers are employed under formal contracts, and the use of child or forced labor is prohibited, with age and identity verification conducted prior to employment. Compliance with labor requirements is monitored by both direct workforce and contractors, with corrective actions implemented where necessary.
A project-level Workers Grievance Mechanism (WGM) is in place and accessible to all workers, including contractors and subcontractors. The mechanism allows for confidential and anonymous reporting, includes protection against retaliation, and provides dedicated procedures for handling sensitive complaints, including gender-based violence and harassment (GBVH). Information on grievance channels is communicated to workers at Project sites and accommodation facilities.
The WGM includes specific considerations for receiving gender-based violence or harassment (GBVH) grievances via a dedicated and trained focal point, with support mechanisms (corporate GBVH grievance mechanism) also available and documented in the procedure. The borrower will appoint a competent grievance officer (including detailed knowledge of Ukrainian labor law and GBVH) to attend to the worker grievances and coordinate the implementation of the WGM. The borrower will make available information on its WGM communication channels in all facilities accommodating project workers.
Worker accommodation for non-local personnel is provided through a combination of existing local facilities and contractor-operated accommodation units. Accommodation arrangements are managed under the framework of the Project's Worker Influx Management Plan and HR management plan and in line with applicable Ukrainian requirements and international good practice, including health, safety, security considerations and gender-GBVH prevention measures. Periodic checks will be undertaken to verify compliance and identify any necessary corrective measures, for alignment of worker living conditions with Project standards, including IFC guidelines, and minimize impacts on the host community.
The Project implements an Occupational Health and Safety Management Plan (OHSMP) applicable to all workers and contractors. At the project level, the borrower will implement and maintain a comprehensive OHSMP covering both construction and operation, which includes hazard identification, safe work procedures, training, incident reporting, and the oversight of contractor and subcontractor OHS performance. The borrower will appoint a dedicated competent, experienced, senior OHS Manager responsible for managing the implementation of the OHSMP and will supervise that operational safety requirements for infrastructure and equipment are clearly defined, implemented, and enforced, including the review of contractor-provided safety documentation. To support the appointed OHS Manager during construction phase, the borrower will mobilize additional competent, experienced OHS supervisors in line with the OHSMP, with the number of supervisors (2-3) adjusted to the volume and intensity of construction activities (ESAP #2.1). Furthermore, the borrower will implement and maintain an Emergency Preparedness and Response Plan (EPRP) for the construction and operation phases, and will coordinate with local emergency services, define response procedures, communication protocols, and conduct periodic drills. Contractors are required to adapt and implement site-specific OHS procedures aligned with GNG ESMPs, Project requirements and PS2. The adequacy of contractor OHS arrangements is reviewed prior to mobilization and monitored throughout Project implementation, with corrective actions applied where gaps are identified.
PS 3 - Resources Efficiency and Pollution Prevention
The project is estimated to generate about 487 GWh per year, with greenhouse gas emission reductions of c. 300,000 tCO2 equivalent per year.
Water consumption for the Project’s construction phase is determined to be 1.8 m³/day. Water of drinkable quality will be utilized and will be delivered by external providers. The final ESIA will assess the proposed water supply option for the Project’s construction phase and its ancillary facilities (e.g., offsite batching plant). Because water is delivered externally, there will be no direct abstraction impacting third parties. Water usage will be negligible during project operations as personnel will not be located full-time onsite.
The project is expected to generate minor pollution to air, water, and soil, and volumes of waste which are anticipated to be readily mitigated through the implementation of standard pollution prevention and control measures defined within the project ESMS. The project will establish a temporary concrete batch plant by the civil works General Contractor to provide concrete for the turbine foundations. Management plans have been developed to control and monitor pollution, in compliance with the national regulation and the IFC PSs, namely: Pollution Prevention and Control Management Plan, Waste Minimization and Resource Efficiency and Conservation Management Plan, Water Conservation Minimization Plan and Wastewater Management Plan. These plans will be implemented and maintained during construction and operations, providing effective control of waste segregation, storage, transport, disposal, hazardous materials handling, and spill prevention/response. Furthermore, the Borrower will maintain and enforce a strict pesticide ban across all Project activities.
Noise and shadow flicker impact assessments are being conducted as part of the ESIA. Noise from construction activities is not expected to be a significant issue for this Project, as there are no residential receptors within 700 m of the nearest turbine location, and construction activities will be limited to daylight hours. Noise modeling should demonstrate how operational noise levels will remain within Ukrainian and IFC EHS guidelines noise limits at the nearest sensitive receptors. Noise will be monitored during project operations. If the monitoring identifies elevated noise levels at sensitive receptors above the noise thresholds, the Borrower will design and implement adaptive mitigation measures. To define and implement proper noise mitigation measures, the Borrower will complete 24h baseline noise measurements at the 8 closest sensitive receptors and update the noise impact assessment in line with IFC EHS Guidelines, including comparison of baseline and predicted levels. Where exceedances are identified, appropriate mitigation measures, including potential operational adjustments, will be defined (ESAP #3.1).
The borrower completed a shadow flicker assessment, which identified exceedances of the IFC Guidelines for Wind Energy threshold limits of 30 mins/day or 30 days/year (worst case scenario), which could be expected at nearby settlements; however, the number of residential receptors potentially impacted is yet to be quantified by the assessment. As the initial assessment did not fully include detailed analysis and corrective actions, the Borrower will conduct a supplementary shadow flicker assessment and identify all sensitive/residential receptors that would be exposed to flicker effect beyond IFC guideline for Wind Energy (30hours/30 minutes rule). For these receptors, the Borrower will agree and document mitigation measures with the affected stakeholders and will implement such mitigation measures. Curtailment will be applied where no mutual agreement or satisfied measures are reached with the affected stakeholders (ESAP #3.2). For appropriate implementation of mitigation measures implementation and potential relevant adjustments to operational measures, the GM developed by the Borrower will capture, track, and investigate complaints related to noise and shadow flicker (ESAP #3.3).
PS 4 - Community Health, Safety, and Security
Risks and impacts to host communities and the public were assessed during the ESIA process across the construction, operation, and decommissioning phases. During construction, the primary impacts include increased traffic, localized noise and dust, and potential emergency situations. Traffic-related risks, driven by the transport of oversized wind turbine components and heavy construction machinery on local roads, are considered a high-priority risk due to the potential for accidents and congestion. Construction sites will be strictly fenced and guarded by security personnel to restrict public access. Emergency scenarios, including fires, chemical spills, and contextual risks related to the ongoing war (e.g., missile attacks), have been evaluated, with sufficient and appropriately equipped civil protection shelters and medical facilities mapped in the Project area for rapid access during emergencies.
The influx of construction workers presents potential social risks, including GBVH and Sexual Exploitation and Abuse/Sexual Harassment (SEA/SH). To mitigate these risks, the borrower will enforce a Worker Influx Management Plan regulating worker accommodation, behaviour, and community interactions. All workers will receive induction training on a strict Code of Conduct, and accessible grievance channels will be established for reporting incidents.
The closest residential properties are located over than 700 m from the nearest WTG. Operational risks, such as ice throw from turbine blades during winter, are considered negligible due to the substantial buffer distances (over 700 m); however, the Project will install warning signs and actively inform local residents of potential hazards.
To consolidate and enforce the management of these risks throughout the Project lifecycle, the Borrower will apply and monitor community health and safety measures as defined in the ESMP and associated management plans (including, as applicable, Traffic and Transport Management Plan (TTMP), Community Health and Safety Plan (CHSP), Worker Influx MP, and EPRP), providing effective control of site access, interaction between workers and communities, and communication of construction-related risks. Implementation by contractors will be supervised through site inspections and corrective actions where required. (ESAP #4.1)
PS5 - Land Acquisition and Involuntary Resettlement
Securing land rights for the project commenced in 2019, led by the developer through amicable negotiated agreements with municipal authorities and private landowners. PS5 is applicable because the Ukrainian legal framework provides the possibility for the government to compulsorily acquire land for energy projects in the event that amicable negotiations undertaken by the borrower fail. The borrower’s land acquisition approach is based on a negotiated amicable agreements model, with full consent of landowners and no objections, disputes, or overlapping rights reported to date.
It is expected for the Project to cause marginal impacts of economic displacement defined as the loss of assets or access to assets that leads to loss of income sources or means of livelihood, but no physical displacement of residential households or businesses. Potential economic displacement risks are primarily associated with the construction phase, involving temporary land access and use restrictions, disturbance of agricultural activities, or localized crop damage related to turbine foundation works, access road construction, or cable installation. Permanent infrastructure will only cause (partial) loss of crops on a fraction of affected agricultural land plots and the PAPs’ total landholdings which will be compensated in cash at replacement cost. The extent and scale of these impacts on PAPs’ livelihoods, however, remain limited and will be compensated in cash. To manage these impacts, the borrower has approved a formal Regulation on Determination and Compensation of Losses Caused to Owners and Users of Land Plots. This regulation dictates that compensation for land use or damages is calculated based on fair market values, with input data updated annually based on local agricultural crop prices. Replacement or compensation at replacement value will be provided to any person who suffers economic losses caused by loss of land use, crop damage, or loss of access to fields. No additional livelihood restoration measures are expected to be required. Residual risks due to permanent economic displacement are expected to be low given that the lease and easement contracts stipulate that affected landowners and legitimate land users (such as agricultural tenants) are entitled to continue cultivating the land, except exactly where the permanent infrastructure is located.
Land required for the project is either owned by the Company or secured (will be secured) for 5, 10, 20, 45 or 49 years via voluntary lease or easement agreements concluded with communal landowners (village councils) and private landowners. Private land within the project area is currently used for crop agriculture. The Project’s WPP component will affect around 72.19 ha (based on the information from the sponsor and the developer from April 2026). The permanent WPP facilities occupy about 56.95 ha, and the temporary land needs make about 15.25 ha. In addition, a small area may be needed for the construction camp. The plots designated for the construction of wind turbines and the substation are free from prior development, located outside of settlements, and are classified specifically as energy lands (land category 14.01). For the WPPs, land rights were obtained for 641 land plots based on ownership, lease, and easement agreements concluded with municipal/community and private landowners. Of these, 26 plots were fully acquired by the Company from private owners and 11 leased from Zaturtsi village council. Easement rights are obtained for 445 privately owned land plots and 159 community-owned plots. The latter include 51 land plots with ‘unclaimed” rights, and they are in provisional communal ownership (NB: These land plots will be permanently transferred to communal ownership if the land ownership rights are not claimed by 1 January 2028 ). As such, easement rights have been established on the land of 341 Project-Affected Persons (PAPs). The total number of affected land plots differs from the number of landowners, as some individual owners hold many plots, and several plots are co-owned.
With regards to the OHTL, the database of landowners is being updated almost daily along with the evolving design and ongoing negotiations and analysis of cadastral data and land ownership documentation. OHTL will traverse 200-210 land plots, of which around 25% (55-60 plots) are community-owned, and the rest are privately owned. Roughly 45% - 80% of the land plots (both private and community-owned) are leased by ten farming enterprises. Only one of the farming companies, with several hundreds owned and/or leased land plots, is affected by land acquisition for both, the WPPs and OHTL. Private land-leasers have not been identified via the cadastral analysis.
No informal users have been identified on the WPP and OHTL-affected areas during the PAP identification process and site visits held by the borrower, the developer responsible for land acquisition and lease, and design contractors.
In addition to these core plots, the Project requires land rights for associated infrastructure, such as access roads, underground electrical cables, and overhead transmission lines. These rights are being secured through servitudes (easements). As of January 2026, the Company’s land register indicates that a total of 386 servitude agreements has been concluded with private owners and municipalities, covering an area of 18.62 hectares.
The Borrower prepared and will update and implement a Land Acquisition and Livelihood Restoration Plan (LALRP) prior to the completion of all land acquisition (ESAP #5.1). This LALRP defines clear cut-off dates, establish eligibility criteria and entitlements for compensation and livelihood restoration (including for informal users, if identified), and detail procedures for identifying and supporting vulnerable households.
While the current ESIA and Project documentation cover the fundamental risks and compensation mechanisms associated with economic displacement, a formalized framework is required to ensure full, ongoing compliance with the lenders’ standards. Land acquisition and compensation practices will be implemented and maintained by the Borrower in line with IFC PS5. To fulfil this requirement, the Borrower will maintain a comprehensive land and stakeholder register.
To support the LALRP and manage community relations, the Borrower will undertake targeted community engagement for the awareness of all affected landowners and land users of the Regulation on Determination and Compensation of Losses and have clear, unhindered access to the Project's GM to address any concerns related to land acquisition, compensation, or temporary access restrictions. Should it become apparent that any additional land rights need to be acquired for any future expansion of the Project, the LALRP will be updated alongside a comprehensive census and socio-economic survey of all Project PAPs.
Three years after the completion of LALRP activities, the borrower will engage a third-party consultant to undertake a completion audit. The audit will include a review of the LALRP mitigation measures implemented by the borrower, a comparison of implementation outcomes against agreed objectives, and a conclusion as to whether livelihoods have been restored to pre-project levels or better or whether supplemental action is required (ESAP#5.2.).
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project is situated in the Central European mixed forests ecoregion of the temperate broadleaf and mixed forests biome. The wind farm site, and its associated OHTL, are located in a heavily human-modified landscape, dominated by crop agriculture, and project infrastructure is sited within Modified Habitat, per the IFC definition. Neither the wind farm nor its associated OHTL overlap Key Biodiversity Areas (KBA) or Legally Protected Areas (LPA), nor do they have significant potential to adversely impact the biodiversity values in any such areas. There are no nature reserves or legally protected areas within the Project site. Nearest Emerald Network nature conservation area 3.42 km from the closest turbine. The nearest Key Biodiversity Area (KBA) is Styr’ River Valley (Site ID 9568). It is located at a distance of more than 16 km from the site and will not be directly affected by construction or operation.
The surrounding landscape is largely shaped by intensive agricultural use, with occasional shelterbelts and small wooded features. No protected natural habitats are present within the Project construction area.
Initial surveys of bird activity show that the site is not located in an important migration corridor or bottleneck and is not located close to any spot likely to attract congregatory or migrating birds.
Bat surveys confirm that protected bat species are present in the wider area; their activity is mainly concentrated near water bodies and forest edges.
Following initial baseline work, the Project has initiated a comprehensive multi-season bird and bat survey programme aligned with GIIP and international methodologies. Surveys commenced in November 2025 and will continue through winter 2025-2026, spring, summer, and autumn 2026, for achieving full seasonal coverage (ESAP #6.2). The programme includes ornithological and bat field surveys, in line with Scottish Natural Heritage guidance for onshore windfarms (birds) and Eurobats guidance for windfarms (bats), analysis of available data, and application of recognised methods, including:
• Vantage Point (VP) surveys (at intervals exceeding the Scottish Natural Heritage guidance);
• Transect surveys along the approximately 40 km proposed overhead transmission line route;
• Static acoustic monitoring for bats, with data analysed following industry-standard procedures.
The local presence of common hamster (Cricetus cricetus, IUCN CR) in the Project area was noted, in locations where unmanaged steppe habitat prevails. A formal assessment of its status relative to IFC thresholds will be required as part of the Critical Habitat Assessment and impact assessment. For now, the borrower is applying precautionary mitigation and monitoring measures (e.g., pre-construction surveys and burrow setbacks) to minimize impacts during the construction phases.
Intermediate reports will be prepared after each seasonal campaign, with a final report consolidating all baseline data and analysis in line with international requirements. Supplementary assessment will cover common hamster (Cricetus cricetus) as well. Based on the supplementary assessment results for various species, the borrower will revise the Critical Habitat Assessment (CHA) to align with IFC PS6 requirements (ESAP #6.1 and ESAP 6.2.).
To prevent impacts on any sensitive biodiversity receptors during construction, the borrower will finalise and implement the Biodiversity Management Plan (C-BMP), incorporating updated baseline data and CHA findings, including pre-construction surveys, species-specific mitigation (e.g. hamster burrow management), and application of the mitigation hierarchy (ESAP #6.1).
Based on field surveys and risk assessments conducted for the project, to date, no bird or bat species of national or international conservation interest was identified that could be significantly affected by the Project. However, some fatalities due to bird and bat collisions could be expected during operation of the wind farm, and these impacts may affect some sensitive species, including bats (all bat species are protected species under EU Habitats Directive Annex II), eagles and other raptors, cranes, storks, and others. Although the project is located in Modified Habitat for its terrestrial environment, IFC Natural Habitat No Net Loss (NNL) requirements will apply to the biodiversity values using the air space (birds and bats) that are susceptible to collision impacts with WTGs and OHTL (ESAP #6.2).
The project’s associated OHTL does not pass through or near any KBA or LPA, though it passes through agricultural field which may host seasonal concentrations of bird species prone to collisions with OHTL, including birds of conservation interest (e.g., cranes, black storks). In order to mitigate bird collision risk with the Project-associated OHTL, the Project will install, and maintain for the life of the Project, bird flight diverters (BFD) on any sections of the OHTL that are identified in the final baseline studies as presenting high collision risks to sensitive bird species. The selection of BFD model, installation, and maintenance parameters will follow GIIP. To address impacts to bats, the borrower has committed to feathering the blades when wind speeds are below the cut-in speed, in order to avoid “freewheeling”. Furthermore, a cut-in speed curtailment regime will be implemented. Initially, this regime will entail the curtailment of all turbine operations when wind speed is below 6 m/s between June 1 and September 1 for the first 4 hours after the sunset, subject to adjustment through adaptive management (ESAP #6.3).
For the Project’s operational phase, the borrower will implement the Operational Biodiversity Management Plan (O-BMP), including the blade feathering (below cut-in speed), cut-in speed curtailment regime, and BFD installation/maintenance elements described above, as well as Post-Construction Fatality Monitoring (PCFM) and an adaptive management protocol (AMP) (ESAP #6.3).
