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
The Company completed national EIAs in 2019 and 2023 to account for evolving Project designs for the WPP. A full ESIA in line with lender requirements was completed in February 2025. Following a positive EIA conclusion dated December 22, 2023, the Company obtained construction permits for the overhead high-voltage power transmission lines (February 19, 2025), main power transmission substation (December 30, 2024) and for the windfarm itself (May 5, 2025). The State Institution “Marzeyev Institute of Public Health of the National Academy of Medical Sciences of Ukraine” conducted a scientific assessment of the materials for compliance with sanitary requirements and approved the size of the Sanitary Protection Zone (SPZ) of 700 meters for the WTG on May 7, 2024.
The Project ESMP outlines general requirements for E&S performance and assigns roles to Notus (as developer and EPC) and the Company. A construction-phase Environmental and Social Management System (ESMS) is under development, with commitments for the EPC contractor to finalize and implement detailed management plans. Within the current ESMP, responsibility is allocated to the Company to develop, review and update the Project ESMP including required plans (e.g. Biodiversity Management Plan, Emergency Preparedness and Response Plan, and Traffic Plan and Waste Management Plan). The Project’s social plans and procedures (including labor rights, influx, engagement, and grievance mechanism) were less well defined than the environmental plans within the ESMP. Commitments are in place to complete all these Project plans in alignment with national and lender requirements. The preparation of these plans, together with a Contractor Management Plan for the construction phase, is a requirement of ESAP #1 and #2. Additionally, ESAP #3 requires a commitments register that clearly assigns responsibility for each E&S commitment to the appropriate party (Company, contractor, or multiple contractors).
E&S responsibilities are assigned to Notus and the Company, and an E&S manager has been appointed by developer (Notus) who is based in Germany. Notus is in the process of hiring a new E&S manager in Ukraine who will provide oversight and E&S monitoring during construction and operation. The full E&S organigram, staffing plan, and training program are to be developed. The Project EPC Organizational Chart is developed and broadly adequate at this stage. As the Project progresses, additional positions will be required to ensure E&S oversight, including HR and on-site labor monitoring manager (see ESAP #4). The Sponsor will include legally binding obligations in its construction and O&M contracts (and subcontractor contracts) to aim for compliance with Project standards including IFC’s PSs and national legislation (see ESAP #5).
The SEP outlines a formal grievance mechanism accessible to all stakeholders, including landowners. The system permits anonymous submissions, commits to a response time of 15 days, and assigns responsibility to the Community Liaison/Land Manager and E&S Manager. For land-related matters (e.g. crop damage, access restrictions), grievances can be submitted through phone, email, suggestion boxes, or in-person.
In preparation for operational activities, the Company will develop and implement an Operations Environment and Social Management Plan (OESMP) consistent with IFC PSs, relevant WBG Environmental, Health and Safety (EHS) Guidelines, national requirements, and ESIA commitments. The main O&M contractor(s)’s plans will be aligned with the OESMP (see ESAP #6).
PS2: Labor and Working Conditions
During construction the project will employ 10-20 local low skilled workers, 60-70 skilled personnel from Odesa region or other regions in Ukraine, and 10-15 expatriate staff. During operations the Project will employ four local dispatch engineers. There is an opportunity for women to become a substantial part of the workforce, benefitting from the vocational training and earned income.
Notus has a Human Resources (HR) Policy that ensures compliance with Ukrainian legislation and International Labour Organization (ILO) conventions, addressing key topics such as terms of employment, recruitment, working hours, non-discrimination, and employee benefits. The Project ESMP defines relevant KPIs and monitoring measures and commits to developing project-level HR procedures prior to construction, including a worker grievance mechanism, worker code of conduct (CoC), and accommodation standards. The Project’s ESMS, through the Construction Management Plan, is expected to establish clear labor management and monitoring requirements, including the minimum labor standards applicable to all project workers, such as minimum wages, working hours, and overtime. All subcontractors are required, under the Project’s ESMP, to adhere to the HR Policy standards in their labor contracts.
The ESIA details the use of mobile modular shelters for workers to provide protection against external threats if required at the time of construction. The ESAP, as outlined in the ESDD, specifies the establishment of a project-level worker grievance mechanism addressing gender-based violence and harassment (GBVH), a worker code of conduct (CoC), and defines minimum requirements for off-site worker and subcontractor accommodation. These requirements are detailed in ESAP #7 and #8.
The SEP, ESIA and ESMP set out general commitments to prevent GBVH, including providing information about zero tolerance toward harassment and ensuring access to anonymous grievance channels. The ESDD identified the need to strengthen the grievance mechanism to effectively address GBVH cases, by establishing a dedicated procedure and appointing trained female focal points to manage sensitive cases such as discrimination, mobbing, harassment and GBVH. The mechanism should also provide multiple reporting options (in person, by phone, email, and anonymous) and ensure clearly defined and accessible referral pathways to medical, psychological and legal aid services for all workers. In addition, the ESDD highlighted the need to conduct a GBVH risk assessment and update the ESMP accordingly and provide training to all workers on the GBVH policies and regulations during induction and periodically thereafter.
The Sponsor has developed a Supplier Assessment Questionnaire which includes questions related to child and forced labor, occupational health and safety, and business ethics. Notus’s German Supply Chain Due Diligence Act Policy commits to respecting ILO Core Conventions across supply chains, and a supply chain procedure is under development which will apply to all projects and companies in the Notus Group.
The ESMP includes a key performance indicator (KPI) that all employees will have a written contract, compliance of which will be monitored through biannual HR audits. Notus will provide induction and regular training to all workers, supervisors, and managers on the Worker Code of Conduct, occupational health and safety (OHS), human rights, and anti-harassment policies. It will track OHS performance through incident reporting and training records. ESAP #9 requires comprehensive coverage of all project workers, including subcontractors, and mandates labor monitoring on child and forced labor, discrimination, and unionization rights.
PS3: Resource Efficiency and Pollution Prevention
The Project is estimated to generate about 331.6 GWh per year net energy output, with greenhouse gas (GHG) emission reductions of ca. 213,000 tCO2 equivalent per year. Once in operation the Project’s GHGs will be minimal. The development of a resource efficiency management plan for all phases of the Project, including specific targets, metrics, and monitoring requirements, will be developed as part of the ESMS.
During both construction and operations, the Project’s water supply will be sourced from licensed offsite providers and managed in accordance with a dedicated Water and Wastewater Plan. Industrial or process wastewater is not expected to generated. Sanitary wastewater will be managed and collected by licensed companies. Water use during operations will be negligible. Concrete for the foundations will be delivered to the Project by truck. Alternatively, to optimize logistics, an on-site batching plant will be installed, which will be included in the wastewater management plan. Water demand for the batching plant will be determined based on the EPC detailed design and a water resource assessment and management plan. Unsealed roads will be watered as needed to minimize dust emissions. The Project is expected to generate minor pollution to air, water, and soil, as well as manageable volumes of waste, all of which will be addressed through standard pollution prevention and control measures defined within the Project’s ESMS.
Noise and shadow flicker impact assessments were conducted as part of Project’s ESIA. Shadow flicker modelling for the operational phase indicated that a total of 21 receptors could be potentially affected with either flicker impacts of over 30 hours per year or 30 minutes per day. The maximum effect on a property was calculated as 47:37 hours per year. The Project plans to implement a shadow flicker module that will mitigate the impacts on sensitive receptors. The requirement for this Shadow Flicker Management Plan is included in ESAP #1.
Noise from construction activities is not expected to be a significant issue for this Project, as there are no residential receptors close to the turbine location, and construction activities will be limited to daylight hours. Noise modelling shows operational noise levels will remain within Ukrainian and WBG noise thresholds at the nearest sensitive receptors. A noise management plan will be developed detailing the monitoring to be undertaken during Project construction and operations as part of the ESMS (ESAP #1).
Limited volumes of hazardous materials will be used during the Project’s construction (e.g., fuels, lubricants, transformer oils, paints) and less will be required for operations. The Project will develop a Hazardous Materials Management Plan within the ESMP which will detail the hazardous materials management such as storage in bunded areas with spill response kits and dispose of its hazardous waste at an off-site licenced facility. Construction and operational waste will be segregated on site, stored in secure containers, and removed by licensed contractors in line with national legislation as laid out in the Waste Management Plan within the ESMP developed for the Project.
The ESIA considers climate variability factors, including wind strength, temperature, and extreme weather events. Climate related risks identified included changes to wind patterns, higher temperatures and soil erosion. A climate change risk assessment aligned with an international framework was not conducted for the Project, the requirement for this is captured in ESAP #10.
PS4: Community Health, Safety and Security
The Project will involve the upgrade of existing agricultural access roads and the use of public roads to transport materials and workers to the site. To manage the potential community safety risks associated with the construction phase of the Project, the EPC will develop a Traffic and Transport Management Plan (TTMP) that will cover the lifecycle of the Project. The Project is required to conduct a road conditions survey to establish the existing state of any public roads before the start of construction (ESAP#11). This will include a road safety campaign for children and obtaining approval from relevant authorities for transportation of abnormal loads (i.e. blades), details of which will be included in the Project’s Stakeholder Engagement Plan (SEP) as per ESAP #12 and SEP discussion below. The TTMP will also integrate measures to prevent and respond to risks of GBVH and child protection and safeguarding (CPS), to address potential risks arising from worker-community interactions along transport routes.
Workers will be accommodated in nearest city, and no workforce influx into the local villages is anticipated. The potential for negative impacts of the presence of the workforce on the local communities is low and will be managed through the worker code of conduct and measured under the ESMP through the community grievance mechanism.
Risks for community exposure to hazardous materials during the construction phase are considered low due to limited community interaction with the construction sites and Project’s commitment to safety measures such as fencing, and warning signs will safeguard the community.
No residential households are located within the safety buffer zone for blade throw risk – around 300 meters from each wind turbine (defined as 1.5 times the length of the WTG blade) - or the overhead transmission line. No communities live within the Project site, which is situated on agricultural land. During operations, agricultural activities will continue between the WTGs. However, during winter, when snow and ice throw could occur, specific mitigation measures will need to be in place. Appropriate mitigation measures will be defined within the OESMP (ESAP #6), in line with the relevant EHS Guidelines, including installing warning signs and active engagement to inform local people of the risks posed by the Project.
A Security Management Plan (SMP) (for construction and operations phases) will be developed by the EPC contractor in accordance with IFC good practice handbook. The SMP will include measures to address GBVH risks, ensuring that all security personnel receive appropriate training and adhere to a Code of Conduct that prohibits any form of GBVH. Security personnel, which are likely to be sourced from the local communities, will be unarmed. The requirement for the SMP is captured in ESAP #13.
PS5: Land Acquisition and Involuntary Resettlement
The Company minimized land acquisition impacts by prioritizing alternatives that ensured landowners and land user consent to lease agreements, thereby avoiding displacement. All land access agreements have been negotiated according to a “willing seller, willing buyer” principle.
From July 2020 to January 2025, the Company secured the land rights for a total area of 10.8 ha (an average of 0.2- 0.76 ha per installation) with Land Lease Agreements between the Company and the landowners for periods from 25 to 49 years. The plots needed for the construction of wind power plants are free from buildings and located outside the boundaries of settlements and were used for agricultural activities. All land within the Project area is either owned and cultivated by small landowners with 19 plots cultivated directly by 11 landowners— or leased to one of three large commercial agricultural enterprises that conduct large scale farming. There are no informal land users affected (including no informal use of roadside verges).
The 22 land plots for the turbines have been acquired through voluntary lease agreements with private landowners. The land required for the internal roads and cables covers 68 land plots, the OHL poles cover 36 land plots, and access to these areas will be secured through servitude agreements with the village councils and private landowners. The land for the substation will also be secured through a servitude agreement with a private landowner. The required land access is summarized in the Company’s internal land rights register. No landowner will lose more than ~8% of their total land plot, with many owners losing less than 5%. No households have been identified as disproportionately affected due to reduced access to land.
Notus’ Land Manager, farmers and the agricultural enterprises who lease the land were involved in tri-party agreements with owners and farmers regarding compensation for loss of income and crops during the construction and operations phases. The agreed rates reported by Notus reflect market rates and have been mutually accepted following negotiations with affected parties. The Project’s land compensation rates were determined using multiple benchmarks, including normative land value calculations for the area, an independent expert valuation based on average market prices, and regional land sale data. Consideration was given to the permanent loss of agricultural productivity due to topsoil removal, the legal restrictions imposed by easements that limit landowners’ full use and transfer rights, and the disproportionate transaction costs associated with acquiring small easement plots. Therefore, the agreed compensation approach is considered fair and consistent with the principles of full replacement cost and equitable treatment of landowners
Based on the above, PS5 does not apply to the leasing of land from private owners for the purposes of establishing the turbines as the land acquisition was completed and verified. Regarding the servitude on land needed for the substation, internal access roads cables, and OHL poles, PS5 applies. The client will develop a Land Acquisition and Compensation Plan/Procedure describing the land acquisition process and the approach for potential further land acquisition in line with PS5. A formal protocol should be established for compensating infrastructure and crop damage during construction, based on a pre-construction land condition survey conducted in collaboration with landowners and users, in accordance with ESAP #14.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project site lies within the Pontic steppe ecoregion of the temperate grasslands, savannas, and shrublands Biome. The WPP site is in a mix of Natural and Modified Habitat comprising shelterbelts of trees and scrubs with narrow areas of grassland, ruderal habitats, agricultural areas, and the OHL also crosses a river and its riparian habitat. The Project does not overlap with Legally Protected or Internationally Recognized Areas, but Emerald Site is located approximately 750 m from the nearest OHL pylon.
Biodiversity baseline surveys were conducted in 2019/2020, 2023/2024 and 2025. Priority biodiversity values include the Saker Falcon (IUCN Red List – Critically Endangered), Common Pochard (IUCN Red List – Vulnerable), Northern Lapwing and Pallid Harrier (IUCN Red List – Near Threatened), and other migratory bird species. Of these, the Common Kestrel, Greater White-fronted Goose, Rook and Yellow-legged Gull (IUCN Red List – Least Concern) were predicted to experience more than one collision per year based on the collision risk modeling representing a negligible mortality relative to their European populations. Priority biodiversity values also include the shelterbelts, a river and its riparian habitat, the Eurasian Otter (IUCN Red List – Near Threatened), Common Hamster (IUCN Red List – Critically Endangered), the Lesser Blind Mole Rat (IUCN Red List – Least Concern), and bat species, including the Greater Noctule (IUCN Red List – Vulnerable). The Project is not in Critical Habitat (CH) for any of the identified priority biodiversity values. While the turbines will be located on agricultural land, IFC Natural Habitat (NH) No Net Loss (NNL) requirements will apply to all these priority biodiversity values.
The Sponsor will revise the biodiversity impact assessment to include baseline surveys for identification of high-risk areas for bird and bat species to inform a post-construction fatality monitoring (PCFM) program for the OHL, and a residual impact assessment for areas of Natural Habitat and priority biodiversity values (ESAP #15). A construction-phase Biodiversity Management Plan (BMP) has been developed for the Project, which incorporates requirements for pre-construction surveys for the Common Hamster, Lesser Blind Mole Rat and ground-nesting bird species. Per ESAP #16, the revised impact assessment and pre-construction surveys will inform an updated construction-phase BMP to set forth all relevant measures for identified priority biodiversity values, including timing of construction works, establishing exclusion zones, as well as rescuing and relocating individuals. The Sponsor will appoint a Biodiversity Specialist, who will be responsible for the surveys and overall management and reporting of all mitigation activities relating to the Project. Along with the OHL, to minimize risks of impacting priority biodiversity values using the airspace, which are also subject to Natural Habitat NNL requirements, bird flight detectors (BFDs) will be installed and staggered along the entire OHL to ensure maximum coverage. The BFDs will be installed following good international industry practice (GIIP) for the BFD model and spacing interval. (ESAP #16).
In the operations-phase of the Project, per ESAP #17, the Sponsor will implement the PCFM program for both the turbines and OHL, based on GIIP to monitor bird and bat activity, which at the minimum, will include (i) systematic carcass searches conducted at weekly intervals year-round under all turbines with transects 6-m in width, (ii) implementation of an adequate number of industry-standard bias correction measures for searcher efficiency (detectability), carcass removal (scavenging), and unsearched and unsearchable areas, (iii) industry standard statistical calculation of total, bias-corrected bird and bat fatality using GenEst software on a semi-annual (2x/year) basis. For bats, in addition to carcass searches, bat monitoring will also include acoustic bat detectors installed at the nacelle to determine bat activity and inform smart curtailment, if needed. The PFCM program will take place for at least a three-year period with semi-annual reporting following a standardized template, but the actual timeframe of the PCFM program will depend on fatality results. The first strategic review of the PCFM program will take place 6 months after the start of the operations phase and then continue on a semi-annual (2x/year) basis. The company will contract an internationally recognized and specialized consultancy to design and develop PCFM, collaborating with a local consultancy for its implementation.
In addition to the PCFM program, the Sponsor will develop an operations-phase BMP (ESAP #18), which will include: i) blade feathering up to the turbine cut-in speed for all turbines with the exception of WTG6, WTG7, WTG24, and WTG27 (which are located > 200 m from woodland habitat) for 4 hours from sunset from 1 July to 20 September to minimize collision impacts to bats; (ii) measures for dimming, avoiding light trespass and adapting lamp spectra for all lighting to minimize impacts of light pollution specifically on bat species; (iii) confirmation of priority biodiversity values based on the PCFM results; (iv) threshold setting for priority biodiversity values following the potential biological removal method; and (v) an adaptive management strategy. As per the adaptive management strategy, if the PCFM review identifies that any of the defined thresholds are exceeded, the Sponsor will take additional mitigation measures in consultation with IFC. These will include observer-led shut-down on demand for birds, and smart curtailment for bats, as needed.
