This is a Category B project according to IFC’s 2012 Policy on Environmental and Social Sustainability due to limited and site-specific E&S risks and impacts; which are mainly associated with the operation of Agri Hubs and agri-feedstock production in the three countries. These can be avoided or mitigated by integrating and adhering to Good International Industry Practices (GIIPs), such as the WBG General and Sector-specific EHS Guidelines (ref. Annual Crop production and Vegetable Oil Production and Processing). The E&S risks associated with the sourcing of the agri-feedstock in the three origins are considered limited, with most of agri-feedstock sourced from commercial farms with mechanized operations. The selected commercial farms cultivate agri-feedstock crops in rotation with food crop production, on underutilized farms, or unused or abandoned sections of their lands. The E&S risks in the large farms are therefore contained and reduced due to better work organization and through the application E&S risk management requirements developed by Ene to the commercial farmers. In addition, social and biodiversity risk screening are part of Ene farm selection criteria and ISCC-EU certification process. Any farms that have triggered deforestation and natural habitat conversion (e.g. grasslands) after 2008 are discarded. Similarly, any farms triggering cases of involuntary physical and/or economic displacement are discarded. The presence of Indigenous Peoples (IPs) in the areas of influence of Ene agri-feedstock initiatives is verified through a mapping process, in line with relevant international standards. Eni Internal Regulatory Framework (ESMS) is already aligned with GIIPs both at corporate and country-level regarding its oil exploration and production operations; and Ene is progressively strengthening its ESMS for the Agri Hub operations and agri-feedstock production in the three countries.

Key E&S risks and issues for this investment are: (i) implementation effectiveness of Ene ESMS across its agri-feedstock value chain; (ii) E&S organizational capacity/competency at Ene country level; (iii) management of labor and working conditions (including OHS) for employees, contractors and supply chain workers; (iv) emergency preparedness and response; (v) management of air emissions, noise, waste, hazardous materials and effluent at the Agri Hubs; (vi) management of community health and safety, from agri-feedstock production, Agri Hub operations, road transportation (eg. road safety and gender and sex-related risks to communities) and security operations; (vii) management of food security risks related to competition between agri-feedstock crop and food crop production; (viii) management of biodiversity risks in the agri-feedstock supply chain; and (ix) stakeholder engagement, including community grievance management.