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
Environmental and Social Policy and Management System
At the corporate level, the company has policies on Health, Safety, Environment (HSE), social, sustainability, ethics, inclusion, and diversity, demonstrating its commitment to a safe working environment, injury and illness prevention, reducing environmental pollution, and ensuring compliance with statutory and regulatory requirements. These policies align with IFC PS requirements and apply to all Qair projects, including Gafsa. They will be shared with all project personnel, including contractors. Therefore, CSG is not expected to develop its own policies but adopt Qair’s and, where needed, create project-specific procedures and plans.
As per ESAP#1, Qair /CSG will develop and implement a project-level HSE management plan detailing processes and standards for construction, ensuring adequate E&S management and supervision. It will require EPC and O&M contractors to implement a project-specific EHS/OHS management system and ESMPs in line with IFC PSs, WBG EHS Guidelines, Qair corporate policies, and ESIA provisions. Qair has developed procurement and contractor/supply chain management procedures setting minimum requirements to integrate E&S obligations into contracts. These requirements, aligned with IFC PSs and the Contractor Management Guidance Note, have been included in all RFPs and the draft EPC contract. The company also has a code of conduct and sustainability requirements, enclosed in EPC and supplier contracts.
Identification of Risks & Impacts
The company developed an ESIA in accordance with local legislation, IFC PSs, WBG EHS provisions and guidelines, and good international industry practice. The ESIA assessed all relevant baseline conditions (e.g., air quality, noise, traffic, biodiversity), analysis of alternatives, climate change risk, cumulative impacts, relevant mitigation measures, expected residual impacts after mitigation, and a framework ESMP.. The ESIA also covered baseline conditions and impact assessment along the OHTL alignment. Qair assessed the socio-economic baseline and undertook a land tenure assessment. The study included biodiversity and avifauna surveys for the project site and OHTL alignment.
Management Programs
As part of the ESIA study, a framework ESMP was developed summarizing E&S management plans, monitoring requirements, and mitigation measures for construction and operation phases. Per ESAP#2, EPC and O&M contractors will prepare a Construction Environmental and Social Management Plan (CESMP) and Operation Environmental and Social Management Plan (OESMP). These will be based on the ESIA framework ESMP, project-level HSE plan, Qair’s E&S policies, and IFC PSs. Lenders will review and approve both plans before use. E&S management and monitoring responsibilities during construction and operation will be shared between the company and EPC/O&M contractors, who are contractually bound to fulfill ESMP commitments.
The CESMP will include sub-plans such as waste management; pollution prevention (emissions, spill response); water and stormwater management; hazardous materials; occupational health and safety; emergency preparedness; community health, safety, and security; traffic management; accommodation; local recruitment and labor; influx management; environmental monitoring; stakeholder engagement (including grievance handling); contractor management; gender-based violence and sexual harassment; and biodiversity management. The OESMP will include sub-plans for waste management; pollution prevention; water management; hazardous materials; emergency preparedness; community health and safety; road safety; biodiversity management (including reptiles and pests); environmental monitoring; and stakeholder engagement.
For the 12 km greenfield OHTL, construction will be done by Qair’s EPC, while operation will be under STEG. Per ESAP#3, the project will establish an E&S agreement with STEG to ensure access to the OHTL and RoW for implementing OESMP measures, mainly livelihood restoration and biodiversity monitoring. The agreement will outline intervention types, frequency, and steps to ensure STEG and its EPC/subcontractors comply with IFC PSs and WBG EHS guidelines.
Organizational Capacity & Competency
The company has an E&S Head at corporate level, based at headquarters, with overall responsibility for the project’s ESHS and OHS management and also serving as Africa regional E&S coordinator. Local E&S consultants have been recruited to undertake the ESIA and related studies. Per ESAP#4, Qair/CSG will appoint a country-level E&S manager and a dedicated local Community Liaison Officer for the project. EPC and O&M contractors must have qualified personnel to oversee E&S issues, including an EHS manager and EHS/OHS officers based on workforce size.
As per ESAP#1, the company will finalize the EHS organogram for Qair and selected EPC and O&M contractors before construction starts. They must have sufficient authority and resources to fulfill responsibilities under the project ESMS, IFC requirements, ESAP, and local regulations
Emergency Preparedness & Response
The main EPC has developed an Emergency Preparedness and Response (EPR) procedure template outlining minimum requirements and guidelines for identifying and responding to possible emergencies. Per ESAP#2, Qair and EPC/O&M contractors will prepare project-specific EPR plans in line with IFC PS1 and PS4 provisions. The plan will address preparedness and responses for potential scenarios including medical emergencies (on-site injuries, pandemic outbreaks, snake/scorpion bites), fire, extreme weather (heatwaves, floods), transport incidents, and major hydrocarbon spills. Security-related incidents such as sabotage, vandalism, or terrorism will be covered under a separate Security Management Plan (ESAP#10). The response plan will include communication protocols to alert local authorities, communities, and management, along with specific responses and evacuation procedures. Regular drills, emergency training, and exercises will be developed per IFC PS requirements and conducted by the EPC contractor for various scenarios.
Monitoring & Review
The company will review and formally audit contractors for HSE performance and compliance with project standards, national requirements, and IFC PSs. As part of its project-level HSE management plan (ESAP#1), Qair/CSG will establish procedures based on corporate guidelines and allocate resources to monitor and measure the effectiveness of its and contractors’ management plans/programs, as well as compliance with Tunisian legal requirements. E&S/OHS monitoring requirements for EPC contractor activities and subcontractors will be defined in their management plans (ESAP#2) and approved by Qair. Implementation will be closely monitored during construction. The HSE management plan will also define minimum monthly reporting requirements for the EPC contractor. Reports will cover E&S/OHS performance per ESIA, ESMPs, and IFC PS reporting standards. Clear KPIs will be developed for reporting.
PS2 – Labor & Working Conditions
The project is expected to employ about 450 workers during peak construction, including 100 skilled and 350 unskilled. During the Operation and Maintenance (O&M) phase, CSG will operate the plant with around 45 employees working in shifts. A few expatriates may be retained for oversight and specialized roles. Given strong expectations for local jobs, Qair and the EPC will coordinate with local authorities to maximize and fairly manage community recruitment.
Human Resources (HR) Policies and Procedures
Qair maintains group-level policies such as the Ethics Guide and Group Code of Conduct, enforcing Human Rights commitments that reject child and forced labor, discrimination, harassment, abuse, or violence, while promoting equal opportunities. These policies apply to all Qair subsidiaries, contractors, and workers and will be implemented for this project. As per ESAP#5, guided by corporate standards, host nation law, and PS2, Qair/CSG will prepare a project-specific HR manual for construction and operations phases. The manual will include: (i) Labor Policy statements on non-discrimination, equal opportunity, prevention of child/forced labor, freedom of association, and GBVSH prevention; (ii) HR procedures for local recruitment, gender equality measures, induction, employment terms, disciplinary actions (including GBVSH), and workforce demobilization; (iii) Workers’ Code of Conduct emphasizing respectful behavior and zero-tolerance for GBVSH; and (iv) Labor Grievance Mechanism for all workers, including contractors, enabling anonymous grievances and gender-related issues handled sensitively. These will apply to all project workers, translated into French and Arabic, easily accessible, and communicated during induction and training. Qair will ensure contractors’ processes align and HR is adequately staffed.
No workers’ accommodation camp will be set up as hiring will focus on surrounding communities. If needed, workers will stay in nearby villages. As part of its HSE management plan (ESAP#1), Qair will develop an Accommodation Management Procedure outlining minimum requirements for housing, basic services, and welfare facilities per PS2 and IFC/EBRD guidance. These provisions will guide any project-specific accommodation plan by Qair or contractors (ESAP#2). Qair will also require its EPC to develop a transportation management plan addressing risks of worker’s transport.
Working Conditions and Term of Employment
The project will ensure all employment contracts comply with Tunisian labor codes and IFC PS2 requirements. Every employee, including those hired by contractors and subcontractors, will receive a contract in French/Arabic specifying employment terms, working conditions (including health and safety), wages and benefits, working hours, overtime and compensation, annual and sick leave, vacation, holidays, and other statutory leaves. Contracts for construction-phase workers will clearly state the short-term nature of the project and expected employment duration. contractual provisions with contractors and suppliers, including verification of identification and age. As per ESAP#6, Qair/CSK will recruit an independent auditor to undertake labor and OHS audit during both construction and operations. The monitoring frequency will be quarterly throughout the first year of the construction phase and will be adjusted thereafter based on the assessed level of risk
Occupational Health and Safety (OHS)
Key OHS risks include slips and falls, hazards from moving machinery, heavy lifting, traffic accidents, electric shocks and burns, bites from venomous snakes and scorpions, and safety concerns during panel assembly. Qair has developed a template HSE construction management plan covering roles and responsibilities; safe work procedures (e.g., work at height); PPE requirements; OHS signage; medical support; access protocols; induction and refresher training; incident reporting; and performance monitoring. Per ESAP#1, similar requirements will be included in the project-specific HSE management plan as part of an OHS plan. The plan will address project-specific risks such as venomous reptiles and high outdoor temperatures and ensure inclusion in CESMPs and OESMPs (ESAP#2). Qair’s risk register, applicable to PV operations, identifies intervention risks and mitigation actions. It will be updated with project-specific risks and included in the OHS plan (ESAP#2).
EPC and O&M contractors will be contractually required to deploy qualified Health and Safety supervisors to ensure compliance with OHS provisions. An H&S Committee with worker representatives will provide feedback and recommendations per Tunisian regulations.
Labor risk within the supply chain
Qair assesses its suppliers through a structured process that begins during pre-qualification and tendering. Suppliers are screened for environmental and social risks, labor standards, and compliance with Qair’s Code of Conduct and Sustainability Requirements. Contracts include clauses on child and forced labor, gender-based violence, and health and safety, and suppliers must cascade these obligations throughout their supply chains. High-risk suppliers are identified using internal tools and undergo due diligence to evaluate their capacity to mitigate labor risks. Monitoring is conducted during production and testing, often with external auditors, and non-compliance can lead to disqualification or contract termination.
Additionally, Qair requires full traceability of photovoltaic module components, including cells, wafers, ingots, and polysilicon, with third-party verification when necessary. While Qair maps its supply chain up to Tier 1 suppliers, traceability obligations extend to Tier 2 through contractual requirements. Audits are conducted by certified bodies, and Qair reserves the right to terminate contracts in case of breaches. As per ESAP#7, Qair will engage an independent, reputable and experienced third-party consultant, to conduct an audit of its solar supply chain. This audit will be undertaken to verify labor and working conditions’ compliance with the local regulations and international best practices. The audit report and any suggested corrective actions will be made available to IFC.
PS3 – Resource Efficiency & Pollution Prevention
Resource Efficiency – Greenhouse Gases
Greenhouse gas emissions during construction are expected to be minimal, mainly from fuel use in generators, transport, on-site equipment, and machinery. Although quantities have not been calculated, they are expected to be low and well below 25,000 tCO2eq/year. However, the Project is expected to result in about 122,000 tCO2eq/year GHG emission avoidance.
Resource Efficiency – Water Consumption & Availability
Estimated water requirements are 4350 m³ during construction and 1100 m³/year during operations. Construction water will mainly be for dust suppression, concrete production, minor batching for substation, control and admin buildings, and domestic use. During O&M, water use will focus on panel cleaning, prioritizing dry brush-cleaning. Wet cleaning may be needed when dust adheres due to rain or humidity, estimated at no more than four times per year. Qair will consider water conservation when selecting efficient cleaning technology and refine the regime to avoid unnecessary use. Due to high salinity in underground water, the project will source water from the nearest municipality via trucks within 10 km of the site. Per ESAP#2, Qair /CSGwill develop a Water Management Plan for construction and operations, ensuring efficient use, proper storage and quality monitoring.
Pollution Prevention
During construction, minor pollution to air, water, and soil, and increased noise are anticipated; these will be mitigated through standard measures in environmental plans. Wastewater will be stored in impermeable tanks and transported by licensed contractors to municipal treatment plants. During operations, impacts are limited to wastewater from panel cleaning and household waste. No flooding risk has been identified.
The project will generate non-hazardous waste (paper, wood, plastic, scrap metals, glass) and limited hazardous waste (transformer oils, paints, batteries, electronics). Volumes during both phases are expected to be low. Per ESAP#1 and #2, CSG and EPC/O&M contractors will develop a waste management plan aligned with local laws, IFC PS3, and WBG EHS provisions. The plan will focus on waste reduction, reuse/recycling, and processes for storage, segregation, tracking, transport, and disposal. It will include traceability, criteria for third-party selection, management of broken PV panels, hazardous storage, disposal solutions per international standards, and licensed contractors..
A water stream (wadi) lies on the northwest side of the site. It has poor water quality due to industrial discharges and is not used for irrigation. The ESIA includes baseline water quality. The project will not abstract water from the stream, though the OHTL will cross it. A 100 m buffer will be maintained per national law, and water quality monitoring will occur during construction.
Pollution Prevention – Hazardous Materials
Hazardous materials during construction and operation include hydrocarbons, oils, lubricants, and paints. Leaks from contractors’ vehicles and equipment may affect soil/subsoil. An impermeable storage area with restricted access will be established onsite per local legislation. A project-specific hazardous material and spill prevention management plan will be developed for both phases by EPC and O&M, based on the corporate hazardous material policy (ESAP#2). The plan will cover transport, storage, refueling, emergency response, community awareness, training, inspections, maintenance, monitoring, reporting, and compliance with national legislation, aligned with IFC PS3 and WBG EHS Guidelines.
PS4 – Community Health, Safety & Security
Community Exposure to Disease
The project is in a sparsely populated rural area, with the nearest residential area, Gafsa, about 3 km from the site. While the project aims to maximize local recruitment, the large construction workforce may lead to worker influx. As stated earlier, no workers’ accommodation camp will be set up. Any accommodation by the company or contractors must meet IFC/EBRD guidance on Worker Accommodation: Process and Standards.
Per ESAP#8, the project will develop and implement a Community Health and Safety and Worker Influx Plan. The plan will assess cumulative influx considering other developments and include: (i) a communicable disease awareness and prevention program (including HIV/AIDS and STIs) for workers and local communities; (ii) adequate on-site medical facilities; (iii) a community grievance mechanism (CGM); and (iv) provisions for periodic monitoring of social impacts from migrant influx. Implementation of this plan, along with the Code of Conduct, measures to maximize local recruitment, and the Worker Accommodation Plan (if needed, ESAP#2), will help manage risks and impacts of population influx.
Road Safety & Traffic Management
During construction, most vehicle movements will involve transporting materials and equipment over the 18-month period. Increased traffic may pose safety risks for other road users and nearby communities. The last 6 km of the access road runs along an existing railway managed by railway authorities. A school is also located along the access route.
Per ESAP#9, Qair/CSG will undertake a Transportation and Traffic Risk Assessment and, based on the findings, develop a Project Traffic and Transport Management Plan. The plan will define transport routes for equipment deliveries using risk assessments to minimize impacts, establish a safety inspection program (especially for local subcontractors), and implement ongoing monitoring of vehicles and safety measures. The assessment will also address risks related to the school and railway.
The new 12 km OHTL will cross the railway at two points: near the site and midway along the alignment. The railway transports phosphate commercially, and per STEG requirements, a minimum clearance of 12 m will be maintained. The OHTL will also cross several untarred tracks. The risk assessment will cover these crossings, and related safety risks during construction will also be addressed under the OHS management plan (ESAP#2).
Security Personnel
A permanent fence will be installed around the site. Security and access control will be provided 24/7 by a third-party company during construction and operations. Guards will not be armed. Per ESAP#10, the project will prepare a Security Risk Assessment and Management Plan for both phases, based on HSE procedures, assessment findings, and PS4 requirements, including IFC’s Good Practice Handbook and Voluntary Principles on Security and Human Rights. The plan will ensure security procedures are communicated to communities to foster understanding and minimize conflicts. CSG will conduct regular audits of security provisions as part of PS1 monitoring and reporting (ESAP#1 and #4)
PS5: Land Acquisition and Involuntary Resettlement
The project will be established on a 224 hectares area of four parcels. The parcels are privately owned and Qair/CSG will lease the plot for a period of 25 years from the owners. The plot is uninhabited and was previously used for large scale plantation, however, has been abandoned for the past four years, due to unavailability of fresh water. A few structures that have been found on the project land such as a well and temporary shelters mainly used by the land owners. The project plot is also used on seasonal basis by herders.
For the 12 km 150 kV OHTL, as per the laws in Tunisia, a permanent RoW of 14m on either side, with associated land use restrictions will be established. Based on the current routing of the OHTL, the RoW will pass through state land, collective land and private land parcels. No structures have been identified on the RoW; therefore, physical displacement is not expected. Parts of the RoW are being used for agriculture. The land use restrictions along the RoW are expected to lead to economic displacement.
The access track of 12 km is an existing track crossing through collective land and railway authority domain. The last 6 km of the track leading to the project site will be enlarged from 3m to 6m to allow safe access to the site. It is estimated that this will lead to temporary land occupation for an area of around 3.5 ha, within the existing railway authority domain. No structures have been identified on the plot for the access track; hence no physical displacement is expected.
Qair has developed a Livelihood Restoration Policy Framework (LRPF) defining Qair’s approach, principles and objectives towards economic displacement, including provisions for a grievance mechanism and vulnerable groups. Based on detailed socio-economic and inventory survey, an LRP (ESAP #11) will be developed and implemented in accordance with the requirements of PS5 to address economic displacement following the principles set under the LRPF. As part of ESAP#12, Qair will recruit an independent consultant, approved by lender; to undertake a completion audit after the full implementation of the LRPs.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project site lies in the “Saharan Halophytic Ecoregion” (WWF) and is relatively flat, with elevation below 300 m and an average slope of 1% trending northeast to southwest. Minor elevations and depressions punctuate the site. Soil is mostly halomorphic and salty, causing drainage and salt accumulation challenges, unsuitable for cultivation. The landscape has sparse vegetation adapted to water stress and high salinity. Nearby infrastructure includes access tracks, a railway, agricultural activities, and phosphate mining and processing plants. The project will connect to the grid via a new ~12 km overhead 150 kV powerline southwards. The OHTL alignment is nearly final; any changes will be minor with no significant ESIA impact. A semi-permanent wadi lies south of the PV site and will be crossed by the OHTL.
The PV site is not within any internationally recognized or Protected Areas, but two such areas lie within ~20 km. Chott Elguetar (Ramsar, KBA, IBA) is a seasonal saline lake important for breeding and wintering water birds when water is present, about 12 km east from the PV site and OHTL. Steppe de Gafsa (IBA, KBA), about 16 km north, is a steppe area supporting 16 steppe passerine bird species such as sandgrouse, larks, warblers, and wheatears.
Tunisia has 42 Ramsar sites, many of which have dried significantly in recent years due to climate change—the Mediterranean region is a climate hotspot—and no longer perform their original ecological function. No long-term hydrology or avifauna data exists for these sites. Local ornithologists believe these sites now rarely hold water and are no longer significant avifaunal receptors.
Flora surveys on site, and satellite imagery identify the vegetation of the site as typically steppe, with very sparse plant cover and an unremarkable floristic diversity. The site is characterized by species adapted to dry and saline conditions. No IUCN threatened or protected plant species were recorded, and all other fauna recorded on site is Least Concern nationally and globally. Several poisonous snakes and scorpions exist in the area, including the highly venomous Yellow Fat-tailed Scorpion Androctonus australis. This poses a risk to construction and operational workers and to the animals themselves through persecution as a result of fear. A protocol will be prepared for the safe management (capture and local relocation) of these animals when encountered, and training and awareness will be conducted for all staff.
Avifaunal surveys conducted on site have recorded 33 bird species, including mostly passerines such as wheatears and larks. Raptors recorded include Athena's Owl (Athene noctua), Common Buzzard (Buteo rufinus), Marsh Harrier (Circus aeruginosus) and Montagu's Harrier (Circus pygargus). Recorded bird species on the national Red List include: Southern Grey Shrike (Lanius meridionalis, IUCN -VU, National – VU); Marsh Harrier (Circus aeruginosus, National – NT); Long-legged Buzzard (Buteo rufinus, IUCN - LC, National - NT); and Lanner Falcon (Falco biarmicus, National - EN). The reed bed and surrounds at the semi- permanent wadi were specifically surveyed twice during the baseline surveys, and hold congregatory species such as Black-winged Stilt (Himantopus Himantopus). No evidence of migration routes was identified from baseline data on site or literature sources. The national Red List for birds does not fully comply with IUCN standards and criteria.
The vegetation on site is classified as Modified Habitat, with land use to date primarily grazing by livestock and large-scale farming in the past. The ESIA has adequately assessed the impacts of the proposed project on the identified receptors. Qair/CSG will develop a standalone BMP (ESAP #13) in accordance to the requirement of PS5 for the project site and OHTL
As for the OHTL, Qair/CSG will ensure that the installation of Bird Flight Diverters on the full length of the OHTL in line with GIIP (ESAP#14). As part of ESAP#15, Qair/CSG will develop and implement a Post Construction Fatality Monitoring (PCFM) procedure for the OHTL for at least the first three years of operations, in line with the IFC-KfW-EBRD PCFM Handbook. During operations, chance find procedures as part of BMP, will be used to capture data on any incidental mortality of birds and other wildlife at the PV facility.
