Redevelopment work on the section from

PK24 to PK105 of the Route Nationale

Transgabonaise

Environment and Social management System

Revision sheet: Version R3

Organization Validator Dated Visa

EPC

Partner
SUMMARY

LIST OF TABLES........................................................................................................... 4
FIGURES ………………………………………………………………………………….4
ACRONYMS AND DEFINITIONS ............................................................................... 4
1. INTRODUCTION .................................................................................................. 6
1.1. Context ........................................................................................................ 6
1.1.1. Project display ............................................................................................. 6
1.1.2. Scope of this management plan .................................................................. 6
1.2. Content of the environmental and social management system ................. 7
1.3. Scope ............................................................................................................ 8
1.4. Terminology used ........................................................................................ 8
2. GENERAL APPROACH AND OBJECTIVES OF THE ENVIRONMENTAL
AND SOCIAL MANAGEMENT SYSTEM .......................................................... 9
2.1. Applicable international standards ............................................................ 9
2.1.1. Standard of the International Finance Corporation (IFC) ....................... 9
2.1.2. Standard of the African Development Bank (AfDB) ............................... 12
2.2. Actors involved in the project ................................................................... 14
2.2.1. The Partner: Société Autoroutière du Gabon (SAG) .............................. 14
2.2.2. EPC: Afcons Infrastructure Limited ....................................................... 15
2.2.3. STs: EPC subcontractors .......................................................................... 15
2.2.4. Other external entities .............................................................................. 16
2.3. EPC involvement....................................................................................... 17
2.3.1. EPC policies .............................................................................................. 17
2.3.2. Resources, roles and responsibilities of the EPC ..................................... 18
2.3.3. Governance vis-à-vis subcontractors ....................................................... 20
2.4. Communication with Stakeholders .......................................................... 21
2.4.1. Consultations and information for affected communities ....................... 21
2.4.2. External communications ......................................................................... 21
2.4.3. Mechanism for handling requests and complaints .................................. 22
3. CONTENT OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT
SYSTEM ............................................................................................................... 23
3.1. Step 1: Planning and Goals ....................................................................... 24
3.1.1. Identification of requirements and others ................................................ 24
3.1.2. Assessment of environmental and social risks and impacts .................... 24
3.1.2.1.Appropriation of environmental studies and assessments of
environmental and social risks and impacts ........................................................ 24
3.1.2.2.Change management ................................................................................ 24

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 3.1.3. Action plans ............................................................................................... 25
3.2. Step 2: Implementation and operation ..................................................... 26
3.2.1. Competence, training and awareness ....................................................... 26
3.2.1.1.Recruitment .............................................................................................. 26
3.2.1.2.Training and awareness ............................................................................ 26
3.2.2. Operational control ................................................................................... 27
3.3. Step 3: Verification and measurements ................................................... 27
3.3.1. Control / Environmental and Social Monitoring / Monitoring indicators
27
3.3.2. Field inspection program .......................................................................... 28
3.3.2.1.Inspections carried out by the EPC .......................................................... 28
3.3.2.2.Inspections carried out by the Partner .................................................... 28
3.3.2.3.Inspections carried out by stakeholders ................................................... 28
3.3.3. Management of non-conformities ............................................................. 28
3.3.4. Reporting ................................................................................................... 29
3.4. Step 4: Improvement and update ............................................................. 29
3.4.1. Incident investigation ................................................................................ 29
3.4.2. System audits............................................................................................. 29
3.4.2.1.Internal by the EPC .................................................................................. 30
3.4.2.2.System audit by the Partner ..................................................................... 31
3.4.2.3.External audits carried out by a third party ........................................... 31
3.4.2.4.External audits carried out by stakeholders ............................................ 31
3.4.3. Non-compliance program ......................................................................... 31
3.4.4. Improvement of the environmental and social management system ...... 33
3.4.5. Updating the management system ............................................................ 34
4. DEPLOYMENT WITHIN MANAGEMENT PLANS ....................................... 35
APPENDICES ............................................................................................................... 36
Annex 1 - EPC Health, Safety and Environment policies ................................................. 37

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 LIST OF TABLES
Table 1 - Acronyms and definition .............................................................................................. 5
Table 2 - Planning of works from PK24 to PK105 ..................................................................... 8
Table 3 - Standards of the International Finance Corporation (IFC) ......................................12
table 4 - Operational safeguards of the African Development Bank (AfDB) ...........................13
Table 5 - Classification grid for environmental and social events ............................................32
Table 6 - Environmental and social management plans deployed by the EPC and the Partner
as part of the Project's environmental and social management system ...................................35

FIGURES
Figure 1 - Illustration of the 3 stages of the project ................................................................... 6
Figure 2 - Illustration of the section of road covered by this management plan ....................... 7
Figure 3 - Schematic diagram of the E&S management of the project ....................................14
Figure 4 - Governance scheme for subcontractors by the EPC in the works phase.................20
Figure 5 - Continuous improvement diagram of the EPC ........................................................23
Figure 6 - Diagram of the non-compliance procedure ..............................................................33

ACRONYMS AND DEFINITIONS

The meaning of the acronyms and the definition of certain formulas used in the plan are detailed in
the table below.

ESC Environmental and Social Coordinator

CSESD Departmental Environmental and Social Monitoring Committees
dB Decibel
DESG Social Environment and Governance Director
DGEPN General Directorate for the Environment and Protection of Nature
EPC Construction Contractor
GHG Greenhouse gas
WHO World Health Organization
NGO Non-governmental organization
PK Mileage point
PM Fine particles
ESMP Environmental and Social Management Plan
ESM Environmental and Social Manager
RN National road
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SAG Gabon Motorway Company
AfDB African Development Bank
IFC International finance corporation
SGES Environmental and Social Management System
ST Subcontractor
Table 1 - Acronyms and definition

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1. INTRODUCTION

1.1. CONTEXT

1.1.1. Project display

The SAG consortium, formed by Meridiam and GSEZ (ARISE) has been requested by the
Gabonese government to implement the project to redevelop and operate the so-called
Transgabonaise economic road, linking Libreville to Franceville. The Transgabonaise is Gabon's
major road axis, approximately 828 km long, it follows the national roads RN1, RN2, RN3 and
RN4.
Meridiam and GSEZ (ARISE) both have experience in structuring and delivering large projects
in the country. The project is developed within the framework of a 30-year public-private
partnership contract by which the State grants the Partner the design, redevelopment, financing,
maintenance, operation and maintenance of the Transgabonaise.
Between Libreville and Franceville, the project is divided into three stages, shown on the map
below:
1. Stage 1: Libreville - Alembé;
2. Stage 2: Alembé - Mikouyi;
3. Stage 3: Mikouyi - Franceville.

Figure 1 - Illustration of the 3 stages of the project

1.1.2. Scope of this management plan

Within Stage 1 of the project, the EPC will be in charge of the contract for the design and
redevelopment / construction of PK24 to PK105 of the N1 national road, connecting Nkok to
Kango, passing through Ntoum, Kougouleou and Ndouaniang.
This management plan covers the activities relating to the redevelopment / construction works
corresponding to this segment ranging from PK24 to PK105, illustrated on the map below.

Figure 2 - Illustration of the section of road covered by this management plan

The works consist of the repair or improvement of the roadway, hydraulic works (drainage, etc.),
the installation of safety and signaling equipment.
The EPC will design, build, test and complete all installations and systems necessary to carry out
the work.
The redevelopment and improvement works, as specified, will be carried out within the
framework of the existing right-of-way, avoiding the acquisition of land, except for places where
the width is insufficient and where provisions for correcting the route, d Improvement of
intersections / geometric characteristics of the road are considered necessary, feasible and
affordable. This is the case, for example, of the doubling of lanes planned between PK24 and
PK40,2.

1.2. CONTENT OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT

SYSTEM

The environmental and social impact studies as well as the Environmental Impact Notices
carried out as part of the anticipated permanent works of the National Road from PK24 to PK105
present:
 Assessment of the environmental and social impacts generated by construction activities;
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  The measures to be implemented to reduce and manage environmental impacts;

 Description of the environmental and social management plan which will allow the
implementation of all avoidance, reduction and compensation measures.
In this case, the environmental and social management system is based on the following studies:

 Environmental impact study of section PK 24 to 50.1;

 Environmental impact notice for section PK 50.1 to 75.1;

 Environmental impact notice for section PK 75 to 105;

 Environmental impact notice of the base camp at PK 50;

 Environmental impact notice of the base camp at PK 95.

Taking into account the environmental and social impact studies, the EPC has set up a
management system adapted and sized to the needs of the project, making it possible to manage
environmental and social issues during construction activities.
This document presents the framework and the strategy for implementing the Environmental and
Social Management System set up by the EPC.

1.3. SCOPE

The overall project deadline, including the mobilization period and commissioning, is 18 months
from the issuance of the service order. The detailed chronological plan by stages of the project is
presented below.

Table 2 - Planning of works from PK24 to PK105

1.4. TERMINOLOGY USED

Throughout the document, the following terminology is used with the following meaning:

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  The Project: Extension from PK24 to PK105 of the Route Nationale Transgabonaise;

 The Partner: Société Autoroutière du Gabon (SAG);

 EPC: AFCONS Infrastructure Limited

2. GENERAL APPROACH AND OBJECTIVES OF THE ENVIRONMENTAL AND

SOCIAL MANAGEMENT SYSTEM

The objective of the social and environmental management system put in place by the EPC is to
provide a systematic organization to minitor the potential negative environmental and social
impacts of the project, and to ensure that these negative impacts will be avoided, reduced or
compensated. It thus enables the operational implementation and monitoring of the control
measures identified in the environmental impact studies relating to the project.

2.1. APPLICABLE INTERNATIONAL STANDARDS

The environmental management system is developed in such a way as to comply with the
international guidelines and good practices enacted in this area by various international
institutions, in this case the standards of the International Finance Corporation (IFC), and those
of the African Development Bank ( ADB).

2.1.1. Standard of the International Finance Corporation (IFC)

The International Finance Corporation (IFC) has a sustainability framework whose mission is to
promote sustainable development. The Environmental and Social Sustainability Policy consists
of eight performance standards, which are presented in the table below.

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 Performance
Summary of content
standards

No. Assessment In this standard, the importance of good management of the environmental
1 and and social performance of a project is highlighted. The standard calls it an
management Environmental and Social Management System (ESMS). This must involve the
of client, workers, local communities affected by the project and other
environment stakeholders. The standard establishes objectives including: the identification
al and social and assessment of the environmental and social risks and impacts of the
risks and project, the adoption of mitigation or compensation measures when necessary,
impacts the effective dissemination of environmental and social information to
communities affected by the project. The standard defines and details the
content of an ESMS:
(i) Policy statement; (ii) identification of risks and impacts; (iii) management
program; (iv) organizational capacity and skills; (v) emergency preparedness
and response; (vi) stakeholder engagement; and (vii) monitoring and
evaluation.
No. Labor and This standard works in favor of several objectives: promoting equal
2 working opportunities for workers as well as respect for national labor and employment
conditions law, establishing-maintaining-improving relations between workers and
management, protecting workers (children, migrants, etc.), promote safe and
healthy working conditions, protect workers' health and avoid the use of forced
labor. The applicability of this standard is defined during the realization of the
ESMS defined in standard n ° 1.
The standard applies to workers directly employed by the customer and to
workers employed through third parties and workers employed by the
customer's primary suppliers.
No. Rational use The objectives of this standard are to avoid or reduce negative impacts on
3 of resources human health and the environment by avoiding or reducing pollution resulting
and from the project, to promote a sustainable use of resources and to reduce GHG
pollution emissions linked to the project. . To meet these objectives, measures must be
prevention taken in particular concerning GHGs, water consumption, waste management,
hazardous materials and pesticides.
No. Community The standard aims to foresee and avoid negative impacts on the health and
4 health, safety of affected communities throughout the project, but also to ensure the
safety and protection of personnel and property which must comply with applicable
security human rights principles. Achieving these objectives requires taking into
account the risks during the design and safety of infrastructures and
equipment, the secure management of hazardous materials, the identification
of risks and potential impacts on ecosystems, exposure communities for disease
as well as emergency preparedness.
No. Land Involuntary resettlement is recognized when affected people or communities do
5 acquisition not have the right to refuse the acquisition of their land or their use restrictions
and to lead to physical or economic displacement. The relative objectives are to
involuntary avoid or limit involuntary resettlement as well as forced eviction, but also to
resettlement anticipate, avoid or limit the negative social and economic impacts resulting
from the acquisition or restriction of use. of land. Regarding this last point,
compensation as well as appropriate communication, consultation and
participation of those affected are necessary. In addition, improvements are
also recommended in terms of restoring the livelihoods and living conditions of
displaced persons. From the design of the project, the client must explore all
the possible alternatives in order to limit or avoid physical or economic travel.
When displacement cannot be avoided, compensation and benefits for the
displaced must be put in place. In addition, the client must interact with
Affected Communities through the stakeholder engagement process (see
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 Standard # 1) and will put in place the grievance mechanism. Finally, the
planning and implementation of resettlement and livelihood restoration should
be implemented by the client through the census of baseline socio-economic
data. Physical displacement should be differentiated from economic
displacement. the customer must explore all possible alternatives in order to
limit or avoid physical or economic travel. When displacement cannot be
avoided, compensation and benefits for the displaced must be put in place. In
addition, the client must interact with Affected Communities through the
stakeholder engagement process (see Standard # 1) and will put in place the
grievance mechanism. Finally, the planning and implementation of
resettlement and livelihood restoration should be implemented by the client
through the census of baseline socio-economic data. Physical displacement
should be differentiated from economic displacement. the customer must
explore all possible alternatives in order to limit or avoid physical or economic
travel. When displacement cannot be avoided, compensation and benefits for
the displaced must be put in place. In addition, the client must interact with
Affected Communities through the stakeholder engagement process (see
Standard # 1) and will put in place the grievance mechanism. Finally, the
planning and implementation of resettlement and livelihood restoration should
be implemented by the client through the census of baseline socio-economic
data. Physical displacement must be differentiated from economic
displacement. When displacement cannot be avoided, compensation and
benefits for the displaced must be put in place. In addition, the client must
interact with Affected Communities through the stakeholder engagement
process (see Standard # 1) and will put in place the grievance mechanism.
Finally, the planning and implementation of resettlement and livelihood
restoration should be implemented by the client through the census of baseline
socio-economic data. Physical displacement should be differentiated from
economic displacement. When displacement cannot be avoided, compensation
and benefits for the displaced must be put in place. In addition, the client must
interact with Affected Communities through the stakeholder engagement
process (see Standard # 1) and will put in place the grievance mechanism.
Finally, the planning and implementation of resettlement and livelihood
restoration should be implemented by the client through the census of baseline
socio-economic data. Physical displacement should be differentiated from
economic displacement. the client must interact with Affected Communities
through the stakeholder engagement process (see Standard # 1) and will put in
place the grievance mechanism. Finally, the planning and implementation of
resettlement and livelihood restoration should be implemented by the client
through the census of baseline socio-economic data. Physical displacement
must be differentiated from economic displacement. the client must interact
with Affected Communities through the stakeholder engagement process (see
Standard # 1) and will put in place the grievance mechanism. Finally, the
planning and implementation of resettlement and livelihood restoration should
be implemented by the client through the census of baseline socio-economic
data. Physical displacement must be differentiated from economic
displacement.
No. Conservatio Performance Standard 6 recognizes that the protection and conservation of
6 n of biodiversity, the maintenance of ecosystem services and the sustainable
biodiversity management of living natural resources are of paramount importance for
and sustainable development. This standard aims to protect and conserve
sustainable biodiversity, maintain the benefits derived from ecosystem services and
management promote the sustainable management of living natural resources. The measures
of living necessary to meet these objectives are implemented via the ESMS defined in
natural standard No. 1. Standard No. 6 applies to projects with a potential impact on
resources biodiversity and ecosystem services.

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No. Indigenous The standard aims to ensure that the culture, knowledge and practices of
7 Peoples Indigenous Peoples are respected and preserved and to anticipate and avoid
the negative impacts of the project on the communities of Indigenous Peoples
or to reduce, restore or compensate for them. During the project, maintain a
permanent relationship with the Peoples, based on Informed Consultation and
Participation (CPE).
No. Cultural In order to protect heritage against the negative impacts of projects and to
8 Heritage support its preservation as well as to promote the equitable distribution of the
benefits of the use of cultural heritage, the standard requires procedures
relating to the ESMS (cf. standard n ° 1) and consultations with affected
communities. The standard recommends mitigation measures if it is not
possible to avoid the impacts.

Table 3 - Standards of the International Finance Corporation (IFC)

2.1.2. Standard of the African Development Bank (AfDB)

Mention should be made of the African Development Bank's Repository, in particular: the
Integrated Safeguard Policy Declaration; a set of operational safeguards (called SOs) supported by
environmental and social assessment procedures and revised integrated environmental and social
impact assessment guidelines (SO1 to SO5).
The objectives of the ADB's operational safeguards are:

 To avoid, as far as possible, the negative impacts of projects on the environment and the
people concerned, while maximizing the potential benefits of development;
 To minimize, mitigate and / or compensate for the negative impacts of projects on the
environment and the people affected, if not avoiding them;
 To help borrowers / clients to strengthen their safeguard systems and develop their capacity
to manage environmental and social risks.
Operational Safeguards (SO) Summary of content
It governs the process of determining the environmental and social
Environmental and Social
SO 1 category of a project and the resulting environmental and social
Assessment
assessment requirements.
It consolidates the political conditions and commitments set out in
Voluntary resettlement: land
the Bank's policy on involuntary resettlement.
SO 2 acquisition, displacement and
It also incorporates improvements intended to increase the
compensation of populations
operational efficiency of these conditions.
It sets the objectives to conserve biological diversity and promote
the sustainable use of natural resources.
Biodiversity and ecosystem
SO 3 It also translates the political commitments contained in the
services
Bank's policy on integrated water resources management and
operational requirements.
It covers the full range of impacts related to pollution, waste and
Prevention and control of
key hazardous substances, for which there are international
pollution, greenhouse gases,
SO 4 conventions in force, as well as comprehensive industry-specific
hazardous materials and
or regional standards, which are applied by other Multilateral
efficient use of resources
Development Banks
It defines the Bank's requirements towards its borrowers or clients
Working conditions, health regarding workers' conditions, rights and protection against abuse
SO 5
and safety or exploitation. It also ensures better harmonization with most
other multilateral development banks.

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table 4 - Operational safeguards of the African Development Bank (AfDB)

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2.2. ACTORS INVOLVED IN THE PROJECT

The organization of the environmental and social management system is part of the general
organization that will be given to the Project both during construction and operation. The main
actors of the project and their respective roles are detailed in this chapter. The general
organization is shown in the figure below.

Figure 3 - Schematic diagram of the E&S management of the project

The entities with responsibility for the environmental and social management system are:
 The partner ;

 The main construction company (EPC);

 EPC subcontractors;

 “External” actors.

2.2.1. The Partner: Société Autoroutière du Gabon (SAG)

The Partner acts as the contracting authority according to the terms and conditions of the
partnership contract signed with the State on October 24, 2019. The Partner will be responsible
for the proper execution and implementation of the environmental and social measures included
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in the studies. environmental, and declined within Project construction operations through the
present environmental and social management system of the EPC.
The Partner will set up a team within itself which will be responsible for overseeing the
implementation of the environmental and societal management system by the EPC.

 The Managing Director of the Partner

It ensures the availability of the necessary resources for the Partner's team will be
responsible for overseeing the implementation of the EPC's environmental and societal
management system.

 The Director of Social Environment and Governance (DESG)

It is placed under the authority of the Managing Director of the Partner. It is responsible
for coordinating the environmental, social and health and safety activities related to the
Project, and in particular it ensures the implementation of this management plan. The
DESG will have and manage an environmental and social section (SES) with dedicated
environmental, social and health and safety experts.
It collaborates if necessary with the EPC for the determination of action plans, and it
ensures relations with the central environmental authorities (Ministries) and decentralized
(departments, municipalities, towns and villages and districts).

2.2.2. EPC: Afcons Infrastructure Limited

The EPC will be responsible for deploying the environmental and social management system
across its entire scope of action within the project. The EPC will have to comply with the
requirements and principles of this management system, and will ensure the environmental and
social requirements of its subcontractors.
This document is a guideline for all employees of the EPC as well as its subcontractors to ensure
a minimum impact on the environment, property and employees and neighboring communities as
well as road users.
The EPC will develop the environmental and social management system and all associated
documents and plans according to new situations or problems encountered and the conclusions
of the audits carried out.
The EPC, responsible for detailed design and construction, establishes within its team an
environmental and social unit (UES) dedicated to establishing the environmental and social
management system, as well as monitoring its level of performance.

2.2.3. STs: EPC subcontractors

The EPC subcontractors will each appoint an environmental and social coordinator (CES) in
charge of the interface with the environment and social unit (UES) of the EPC.

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The CES will be responsible for the implementation and monitoring of the recommended
measures and compliance with the environmental, social and health and safety specifications at
work as mentioned in their subcontracting contract, in line with this management plan. The CES
will be responsible for ensuring that at all levels of subcontracting, companies comply with
environmental, social and health and safety obligations.

2.2.4. Other external entities

 DGEPN and administrations

In its role as instigator of the environmental procedure, the DGEPN will oversee the
development of the environmental and social management system, and will be
responsible for providing administrative supervision and technical control of its
implementation in the field. .

The DGEPN will be responsible for verifying the periodic environmental and social
monitoring reports transmitted by the Partner, and monitoring the project's compliance
with the legislation and the requirements of environmental and social impact studies.
In addition to the DGEPN, other administrations will also be involved in this process,
namely the Ministry of Public Works and Infrastructures, the High Commission for the
Environment and the Living Environment (HCECV).

 Decentralized Water and Forestry Services

The mission of Gabon's Ministry of Water and Forests is to ensure sustainable and
responsible management of the country's forest resources. One of the areas of
intervention required to achieve this mission lies in monitoring and controlling the strict
application of the regulations in force.
The General Directorate of Water and Forests is divided into several technical
departments, each with specific missions:
o The Forest Production Department (DPF) draws up forest management guidelines
and controls their application, monitors forest production, monitors requests and
allocation of permits;
o The Forest Resources Inventories and Development Department (DIARF) draws
up guidelines for forest inventories and management and their application,
monitors inventories and developments;
o The Direction des Industries et du Commerce du Bois (DDICB): manages
industrial permits, monitors the processing and marketing industries of forest
products;
o The Department of Wildlife and Hunting (DFC) draws up guidelines and
monitors activities relating to the management and conservation of wildlife,
delimits and develops conservation areas;
o The Department of Studies and Documentation (DED) prepares economic studies,
centralizes statistics from the departments and decentralized services, monitors
the settlement of forest disputes, centralizes activity reports.
 Stakeholders (local authorities, NGOs, neighboring communities, CSESD, etc.)

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 Stakeholders may be involved in the implementation of the ESMP through mechanisms
ensuring that their comments are taken into account and / or complaints are filed
regarding the proper functioning of the planned measures.

They will also be involved in various awareness programs (health, road safety, etc.), and
the daily application of good practices in these areas.

 The Ministry of Equipment, Infrastructure and Public Works (MEITP)

The General Directorate of Transport Infrastructures will have general responsibility for
the management of the new road infrastructure.

 The Ministry of Transport

The General Directorate of Land Transport (DGTT) is responsible for the regulation of
road transport, the issuance and control of transport documents, transport authorizations
and the coordination of road freight.

 The General Directorate of Road Safety (DGSR)

The General Directorate of Road Safety is a Public Administration operating in the field
of land transport. She is in charge of monitoring safety aspects with regard to the
Gabonese regulatory framework.

2.3. EPC INVOLVEMENT

2.3.1. EPC policies

The commitment of the EPC to deploy the environmental and social management system is
formalized in the policy established at the top of the Management, and which applies to all the
functions concerned and the activities of the construction operations. Thus the policy is
implemented and maintained through the environmental and social management system.
The EPC is also certified according to ISO 45001 and ISO 14001: 2015 standards, which gives
the environmental and social management system the following benefits:

 The system is appropriate for the purpose and context of the organization, including the
nature, scale and environmental impacts of its activities and services;
 The system provides a framework for setting environmental goals;
 The system includes a commitment to environmental protection, including pollution
prevention and other specific commitments related to the context of the organization;
 The system includes a commitment to fulfill its compliance obligations;
 The system includes a commitment to continuously improve the environmental
management system in order to improve environmental performance.

The EPC policy is divided into two parts which are detailed in Annex 1.

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2.3.2. Resources, roles and responsibilities of the EPC

The EPC will provide resources on site for the establishment and implementation of the
Environmental and Social Management System (ESMS). Resources include human resources,
specialized skills, infrastructure (office, training room.), equipment (vehicle, computers...),
training, information system, etc.
The EPC has set up an organization which enables it to deploy the environmental and social
management system.

 The EPC Project Manager :

He organizes and leads the project from end to end in accordance with the requirements
of this plan. He assumes responsibility for the various stages, from the translation of
needs, to the realization and completion of construction operations. He ensures the
availability of the necessary resources for all the teams of the EPC and its subcontractors.

 The Environmental and Social Manager (RES) of the EPC :

It is placed under the authority of the EPC Project Manager. It oversees the design of the
Project's environmental and social management system, with a view to implementing
measures from all management plans for the construction phase, and their monitoring.
The Environmental and Social Manager (RES) of the EPC is responsible for the
application by the EPC and its subcontractors of the implementation of the measures, and
he determines the corrective actions in the event of non-compliance with the plan.
He is assisted by engineers and technicians responsible for environmental aspects directly
related to construction activities and social aspects related to complaints expressed by the
population, nuisances suffered, compensation claims for temporary events taking place
during construction activities. and relations with local authorities or representatives of the
State. He coordinates with the EPC human resources team on labor rights measures.
The Environmental and Social Manager (RES) of the EPC is also in charge of the
following tasks:
o Coordinate with the Partner's Environmental Engineer reporting to DESG;
o Organize the preparation of monthly reporting with the EPC manager;
o Ensure, in consultation with the Partner, relations with external organizations and
local communities concerned for all social, environmental, and public health /
safety aspects;
o Organize the environmental and social documentation generated during the
construction phase of the project;
o Prepare staff availability as well as the required documentation prior to
environmental and social audits.

 The EPC Environmental Engineer and the EPC HS Engineerare under the
supervision of the EPC HSE Manager. They are in charge of operational implementation
and monitoring of management plan measures. They can interrupt a construction activity
in the event of non-compliance with measures to protect the environment, workers,
communities or safety, and in the event of serious and imminent danger.

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  Liaison officer with local communities
It develops and maintains dialogue and consultation with individual and collective actors
interested in the project. It identifies local development actions and possible partnerships
and monitors ongoing actions and research.
Its functions are mainly:

o Meet regularly with local authorities, public services, customary chiefs / district
and village chiefs and keep them informed of the progress of the Project;
o Identify and develop a network of partnerships with the stakeholders concerned
by the Project;
o Establish appropriate communication media to inform the population about the
progress of the Project;
o Carry out public awareness interventions and draw up an assessment of the
actions;
o Identify and implement local development actions and analyze the impacts of
these actions.
HSE Departement flowchart

Project Manager

Manager HSE

Environmental Ingeneer Safety Ingeneer

Focal point with local communities

Safety Officer

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2.3.3. Subcontractors management

The control of subcontractors by the EPC is a key point of the environmental and social
management system.
This section therefore explains the main roles of each actor involved and specifies the key
functions within each structure, the diagram below of which represents the general organization.
Each subcontractor or group of subcontractors appoints an environmental and social coordinator
(CES) responsible for deploying the requirements of the environmental and social management
system.

Partner:
Director Environment Social and
Governance (DESG) /E&S Unit

EPC:
E&S Manager E&S Unit

Contractor 1 & its Contractor 2 & its Contrator 3 & its

subcontractors : subcontractors : subcontractors :
Environmental and Social Environmental and Social Environmental and Social
Coordinator (ESC) Coordinator (ESC) Coordinator (ESC)

Figure 4 - Governance scheme for subcontractors by the EPC in the works phase
The environmental and social coordinator (ESC) of each subcontractor or group of
subcontractors is in direct contact with the Environmental and Social Manager (RES) of the
EPC, he ensures that the teams of subcontractors are appropriate organizational measures
developed in the environmental and social management system are integrated and applied.
The ESCs will be responsible for the effective implementation of the recommended measures
and for compliance with all the environmental specifications as mentioned in the subcontracting
contracts. The ESCs have hierarchical powers allowing them to impose their decisions on the
works supervisors. In particular, the possibility of stopping a construction activity, for reasons of
protection of the environment, workers, communities or safety, remains a fundamental measure
for the effectiveness of monitoring.
The ESCs will be responsible for:
 To place the construction activities in accordance with the environmental and social
obligations defined in the contractual specifications;
 To ensure that all the subcontractors of the companies respect the environmental and
social obligations of the environmental and social management system;
 Prepare the environmental plans and programs as required by the specifications of the
subcontractors, in particular the monitoring programs;
 To monitor environmental and social activities on all construction sites used by the
company or by its subcontractors, by carrying out regular visits;
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  Respond to non-conformities issued by the RES and immediately apply the necessary
corrections to the construction teams;
 To prepare weekly and monthly activity reports presented to RES.

2.4. COMMUNICATION WITH STAKEHOLDERS

Communication with stakeholders and in particular with local populations is a key issue for the
Partner's objectives, Gabonese regulations and IFC standards.
As a result, the environmental and social management system provides for the establishment of
stakeholder consultation mechanisms.
The Partner and the EPC are intimately concerned and linked by this subject. The Partner has set
up a communication system with the Stakeholders, particularly during the preliminary stages of
the Project. This system is updated before the implementation of construction operations, the
EPC appropriates and integrates into this communication system.
It is then reciprocally up to the Partner and to the EPC to provide the information necessary for
communication with the stakeholders.

2.4.1. Consultations and information for affected communities

The communication system with stakeholders deployed within the environmental and social
management system during construction operations makes it possible to:
 Have a permanently updated list of Project Stakeholders;

 Define appropriate communication and participation strategies and processes;

 Plan actions;

 Guarantee the Partner's transparency towards stakeholders, and in particular those who
may suffer the negative or positive impacts of the project;

 Allow all complaints to be raised;

 Have means of implementation, monitoring and evaluation, including meeting minutes;

which will include in particular monthly, quarterly and annual activity reports including
monitoring of indicators (progress of actions, corrective actions in the event of deviation
and measurement of their effectiveness).

2.4.2. External communications

The Partner will communicate regularly on the progress of the Project and in particular the
environmental and societal aspects.
The EPC only intervenes to feed the Partner's communication at the latter's request, to provide
him with the data necessary for carrying out the external communication.

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2.4.3. Mechanism for handling requests and complaints

The mechanism for collecting and effectively processing requests and complaints constitutes an
amicable remedy available to local stakeholders to express their incomprehension or
dissatisfaction with the impacts of the project which concern them.
This mechanism deployed by the Partner aims to

 Inform affected populations and external groups or other stakeholders of their rights to
communicate their concerns to project representatives;

 Encourage the free expression of requests, grievances, claims, problems and concerns
relating to the project by the communities and those affected;

 Promote the use of non-judicial procedures for questions related to the project;

 Provide individuals and communities with an accessible and culturally acceptable

mechanism to enable them to express their concerns in a transparent manner;

 Deal effectively, fairly, impartially and transparently with requests and complaints from
people affected by the project;

 Contribute to establishing and improving over time a relationship of trust and mutual
respect with stakeholders.
Stakeholder engagement will be carried out in close collaboration with departmental committees
called “Local Environmental and Social Monitoring Committees (CSESD)” and made up of
representatives of the prefect, decentralized technical services and the municipalities and villages
crossed.
For its part, the EPC also deploys the corresponding process for the attention of its employees
and subcontractors, enabling them to express their concerns regarding working conditions.

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3. CONTENT OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT
SYSTEM

The content and development of the environmental and social management system are developed
according to a principle of continuous improvement in 4 stages:

 1st step: Plan define the problem in general and develop an action plan;
 2nd step: Implement achieve the various deliverables while ensuring good
communication;
 3rd step: Measure the results assess performance indicators and diagnose areas for
improvement;
 4th step: Improve and evolve capitalize on the development potential and act on the
basis of the measures identified.

Continuous improvement is a process which thus enables the EPC to constantly evolve and
improve processeswork by implementing simple changes.

EPC Policy

Management
system review Planning

Continuous
improvement

Verification and Implementation and

corrective actions operation

Figure 5 - Continuous improvement diagram of the EPC

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3.1. STEP 1: PLANNING AND GOALS

3.1.1. Identification of requirements and others

Legal requirements refer to all requirements issued by government authorities or regulatory

bodies. The legal requirement includes laws, rules, regulations, permits, licenses, authorization,
consents, etc. Other requirements generally refer to the requirements set out in the contractual
requirements.
The EPC will put in place a mechanism to identify the legal and other requirements applicable to
the activities and services during construction operations on the site.
The regulatory watch system enables the Project activities to be permanently in compliance with
the requirements applicable at all times to the Project construction activities. If new regulatory
requirements emerge during the execution of the project, they are analyzed by the EPC, then the
necessary actions to develop the environmental management system accordingly.

3.1.2. Assessment of environmental and social risks and impacts

3.1.2.1. Appropriation of environmental studies and assessments of environmental and

social risks and impacts

An environmental and social assessment will be carried out to assess the environmental and
social risks and impacts of construction activities. This analysis will make it possible to:
 Prioritize risk in order based on likelihood, severity (on objectives, monetary
consequences, loss of clients, legal exposure and impact on interested parties);
 Identify what is acceptable and what is unacceptable.

The risk prioritization is determined on the basis of the following criteria:

 Severity of the result (on a scale of 1 to 5 where 1 is the lowest and 5 is the highest).
 Probability (probability) of harm on a scale of 1 to 5 where 1 is the lowest and 5 is the
highest).
The assessment of environmental and social risks allows the implementation of risk reduction
measures, so that the level of residual risk is reduced to the lowest possible level.
This criterion scale is established by the EPC and validated by the Partner, and its content will
have to be adapted (in terms of criteria or in terms of scale intensity) continuously according to
the progress of the site.

3.1.2.2. Change management

During the realization of the Project, it is probable that elements of design and / or construction
will be modified compared to the definition of the Project as described in the environmental and
social studies.

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The process of identifying risks, assessing risks and issuing procedures is an ongoing process
and should be repeated / performed whenever significant changes occur or new work operations
or new types of machinery occur. are used for the purposes of the project.
These modifications must lead, if necessary, to an adjustment of the measures according to the
evolution of the resulting significant impacts.
To do this, a process is set up to assess the E&S consequences of the modification.
If significant changes are identified on the environmental and social impacts, the risk analysis
specifies the additional actions to be planned as well as the entity responsible for their
implementation. This analysis is subject to a decision by the Partner. If the proposed
modifications do not imply any significant modification of the impacts, the modification sheet
and its analysis are simply archived.

3.1.3. Action plans

The EPC will define an action program allowing the implementation of the measures defined in
chapter3.1.2. The program specifies for each action:
 The different tasks or actions that must be implemented;
 The timeframe for implementation;
 The manager ;
 Resource allocation;
 Actual date of completion of assigned tasks or actions.
The Environmental and Social Manager (RES) of the EPC is in charge of overseeing the
implementation of this action plan.

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3.2. STEP 2: IMPLEMENTATION AND OPERATION

3.2.1. Competence, training and awareness

The skills of those involved are decisive for the proper functioning of the environmental and
social management system. The challenge is to have the knowledge adapted by each person
according to their position, activities and responsibilities.
The EPC ensures that all personnel are competent and trained in the requirements of the site.
To this end, various training and awareness programs will be conducted for all EPC staff,
including subcontractor staff and visitors.

3.2.1.1. Recruitment

The EPC establishes a recruitment procedure including the transmission of its environmental and
social policies to new hires and an awareness of its E&S objectives and commitments.
The recruitment of staff attached to functions having an impact on environmental and social
issues is carried out by integrating their existing skills:
 Their initial training;
 Their professional training;
 From their professional experience.

3.2.1.2. Training and awareness

The EPC also sets up and follows a training plan for its staff and subcontractors according to
contractual requirements and the needs necessary for the proper functioning of the environmental
and social management system.
For all stakeholders and in particular for the various positions and trades involved in the work
phase, the EPC establishes a detailed training / awareness plan, plans training and records the
participation of people in these training. The categories of personnel concerned by the training
plan are at least:
 Coaching involved in policy formulation and resource allocation;
 Auditors and inspectors;
 The different specialists;
 Members of the E&S teams;
 All the employees working on the site (training or awareness raising).
The trainers selected must themselves have the necessary skills and experience in the field of
training.
In addition to training, and as needed, awareness sessions are implemented to upgrade staff.
These sessions are organized in particular when:
 Changes concern the project or the environmental and social management system;

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  Non-conformities are noted due to bad practices justifying an upgrade.

3.2.2. Operational control

The EPC will implement the necessary processes for the deployment of the environmental and
social management system.
Construction operations are organized and carried out by the EPC contractor and the
subcontractors.
Work procedures and instructions will be developed for workers and supervisors. These
procedures must be appropriate to the nature and scope of the project and must provide
preventive and protective measures.
This operational control also implies a perfect control by the EPC of the exercise of each
subcontracting, and the organization of all the activity of the construction operations.

3.3. STEP 3: VERIFICATION AND MEASUREMENTS

3.3.1. Control / Environmental and Social Monitoring / Monitoring indicators

Monitoring the effectiveness of the environmental and social management system is essential to
ensure that the objectives are achieved within the time limits set and that the impacts are
therefore well controlled.
Environmental and social performance will be monitored and measured to ensure compliance
with applicable Gabonese and international regulatory requirements, international standards, as
well as the requirements of the project's environmental and social studies.
A series of indicators to ensure this monitoring will be established, and accompanied by an
observation period.
The indicators will be continuously monitored; they can be modified during project execution in
order to remain relevant to the progress of operations.
As detailed in chapter 0, the environmental and social management system will be deployed by
the EPC through various management plans, each dedicated to a specific theme. Each of these
management plans therefore details a series of indicators making it possible to ensure specific
monitoring of each environmental and social issue.
Monitoring of indicators will be the responsibility of the EPC for the construction period and of
the Operator for the operating period. This one will set up a reporting system with in order to
forward the information necessary for the compilation of the proposed indicators. This system
will allow rapid identification of deviations and necessary actions.
The indicators can be modified during the execution of the project.
At the upper level, the " Monitoring and follow-up program for the environmental and social
impacts of the project ”from details the internal and external monitoring measures.

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3.3.2. Field inspection program

The objective of field inspections is to ensure that environmental and social requirements are
implemented and operational in the field, and allow the effectiveness of management measures
for environmental and social aspects to be judged.
Field inspections will be carried out and the necessary measures will be taken if deficiencies are
observed during the inspections.

3.3.2.1. Inspections carried out by the EPC

The EPC is responsible for verifying that works activities comply with the requirements defined
in the various environmental and social management plans. The EPC will develop a site
inspection program to verify compliance with these requirements.
A team of site inspectors will be responsible for the inspections, which may be supervisors or
other designated competent persons. They will perform the following operations:

 Organize regular visits to construction sites and parking areas;

 Establish files of detected non-conformities and monitor their treatment by the company;
 Regularly feed the environmental and social database with non-compliance files, non-
compliance closure files and supporting photographic documents.
The inspections will be carried out regularly on the site, at a daily, weekly or monthly rate
depending on the subjects to be inspected (the frequency will be adjusted according to
environmental risks, the sensitivity of the environment and the performance of the company).

3.3.2.2. Inspections carried out by the Partner

In order to optimize the coordination between the Partner and the EPC (and its subcontractors),
joint visits to the worksite areas will be set up at an average monthly frequency, from the start of
the works, which will allow exchanges direct to the places where there are any problems. These
inspection visits may also be carried out unexpectedly.

3.3.2.3. Inspections carried out by stakeholders

Likewise, in order to allow coordination with between external stakeholders (donors, ISO
auditors, DGEPN, etc.), inspection visits will be carried out in order to concretely observe the
progress of construction operations and observe the implementation of the management system.
environmental and social. These inspection visits will be organized on a case-by-case basis, or
may take place unexpectedly.

3.3.3. Management of non-conformities

An important element of the communication process between the parties concerns the
prioritization of events that will not meet the environmental obligations and objectives assigned
to the project. These situations detected on the site must then be transmitted to a higher level, but
according to procedures which must vary according to the importance of the risk and the urgency
to remedy it.

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The EPC will develop a procedure for managing non-conformities. If any nonconformities are
identified, they are flagged and analyzed to determine the root causes. Corrective and preventive
measures are taken, then incorporated into the chapter's environmental and social action
plan.3.1.3. The effectiveness of corrective and preventive measures is verified during internal
audits.

3.3.4. Reporting

Each month, the EPC will draw up a summary environmental and social report for the Partner,
including:

 The main activities of the month;

 The results of monthly audits and inspections;
 The synthesis of the different registers;
 Summary of non-conformities and corrective actions;
 The improvement objectives for the following months and recommendations;
 A monitoring grid for management plan indicators.

3.4. STEP 4: IMPROVEMENT AND UPDATE

3.4.1. Incident investigation

Incidents are assessed according to four criteria:

 The environmental impact;

 Media attention,
 Legal sanctions
 The impact on the community.
All incidents will be reported to the Partner and they will be recorded, investigated and analyzed
in order to:
 Determine the causes of the incident;

 Identify the need for corrective measures and the possibilities for preventive measures;

 Identify opportunities for continuous improvement as well as corrective / preventive

measures.
Corrective and preventive measures will then be implemented to prevent such incidents from
recurring. The results of incident investigations will be communicated to the staff and functions
concerned.

3.4.2. System audits

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3.4.2.1. Internal by the EPC

The environmental and social management system will be assessed by internal audits carried out
by the EPC. The EPC will set up an internal audit system at the EPC and periodically verify:
 The compliance of project implementation with Gabonese regulatory requirements, EIA
commitments and international performance standards including those of the International
Finance Corporation (IFC);

 Correct implementation of EPC Policies;

 Compliance with the requirements of the environmental and social management system;

 The correct implementation of the EPC Management Plans detailed in the chapter 0.
Failure to comply with a requirement will generate a non-compliance which will be dealt with by
preventive or corrective actions.

Audits will be carried out every month and will include at least:
 Review of the procedures and systems in place with regard to this plan;

 Exchanges with EPC staff on actions in progress;

 On-site inspections;

 Meeting with internal and external stakeholders;

 Review of indicators;

 The conclusions in terms of compliance and corrective actions to be taken.

The audit areas will include:

 The plans and procedures in place;

 Reporting and keeping records and indicators;

 The follow-up of corrective actions;

 The complaints register;

 Reports of information, awareness and training sessions (materials and attendance sheets)

 Measurement and analysis reports;

 Schedules and follow-ups for preventive maintenance and compliance;

 Internal and external control and monitoring sheets.

 The inspection program

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Each EPC audit will cover a number of aspects of the environmental and social management
system. The audit program established by the EPC must ensure that each element of the
environmental and social management system is reviewed with a frequency in line with the
challenges of construction activities. This internal audit all of the activities of the ESMP within a
six-month period. This program will be validated by the Partner.

3.4.2.2. System audit by the Partner

A biannual audit planned and carried out by the Partner. The scope of these audits covers the
entire management system and applies to the activities of the EPC and to companies working on
the site.

3.4.2.3. External audits carried out by a third party

An external audit carried out on the basis of at least one audit per year will be carried out by an
audit company selected by the Partner.

3.4.2.4. External audits carried out by stakeholders

Audits on all or part of the environmental and social management system may be carried out by
project stakeholders on construction activities. Stakeholders can be represented by:

 The DGEPN conducts audits on a quarterly basis; for this it will rely on the skills of
various ministries;

 Donors who conduct their own audits.

3.4.3. Non-compliance program

All non-conformities identified during audits or inspections follow the non-conformities

treatment process below and are:
 Formalized in a non-conformity sheet type document;

 Prioritized so as to establish 3 categories of events according to their severity as detailed

in the Table 5, and involving hierarchical levels and adapted communication strategies to
deal with them (see Figure 6).

Communication and handling procedures will depend on the level of non-compliance.

Incidents are assessed according to four criteria: potential or observed environmental impact,
media attention, legal sanctions and impact on the community. The criterion with the most
serious consequences determines the score and the classification of the incident (see examples in
the table below.

TYPE D'INCIDENT / NON-COMPLIANCE

CRITERES
MINOR (I) MODERE (II) MAJOR (III)

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Environmental Spill, discharge, noise,
incident waste, or almost one-off
incident confined to a
building or an
establishment, causing no
release into the
environment.
Event related to a violation
of standards (for example:
ISO 14001)
Media No local or regional media
attention coverage; internal
communication
Legal sanctions No attention - actual or
and attention potential - from the
paid by the authorities
authorities No cases of non-
compliance with laws
Impact on the No complaints or impact
community on the community
Table 5 - Classification grid for environmental and social events
The diagram below illustrates the harmonized criteria for classifying non-conformities into 3
levels, the highest criterion being used to classify the event:
Spill, discharge, noise,
waste, or one-off on-site or
off-site incident resulting
in negligible damage or no
damage to people, wildlife
or habitat. Impacts, if any,
are temporary and full
restoration can be
completed in the short
term
Local media coverage
Minor attention - actual or
potential - from the
authorities (questions,
letters, phone calls) about
the incident, for example
notice of violation
accompanied by a request
for an action plan or local
investigations (accidental
spill in river for example)
Small number of
complaints; the incident
was not reported to
external emergency
response services
Spill, discharge, noise,
waste, or on-site or off-
site incident resulting in
damage; this damage to
people and the
environment is however
temporary and limited to
a certain area and the
total restoration can be
completed in the short or
medium term
Significant national or
regional media coverage
Minor conviction or
significant attention -
actual or potential - on
the part of the
authorities, e.g. offense
notice accompanied by
threats of sanctions,
police investigations
High number of
complaints and incident
reporting to external
emergency response
services or external
emergency response plan
implemented and
evacuation of citizens
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 Figure 6 - Diagram of the non-compliance procedure

All identified non-conformities are the subject of recorded corrective actions as described above
depending on the severity level of the event. For levels 2 and 3, the corrective measures are
subject to an effectiveness evaluation by the Partner.

National authorities and donors may be notified of non-conformities, if relevant.

3.4.4. Improvement of the environmental and social management system

The improvement of the environmental and social management system will be carried out on the
basis of its performance, measured from the feedback of the following elements:
 Results of audits;

 Results of the assessment of compliance with legal and other requirements;

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  Relevant communications from workers, external interested parties, including complaints;

 Monitoring indicators;

 Status of incident investigations, corrective and preventive actions;

 The process for managing non-conformities;

 The evolution of construction operations.

3.4.5. Updating the management system

The environmental and social management system, as well as the associated plans (chapter 4), is
updated and reviewed each time it is observed:

 A modification of the aqueous emissions management procedures agreed with the Partner;

 The appearance of an unanticipated problem in environmental and social studies or a new

activity not taken into account not appearing in the current plan;

 An evolution of the regulatory context;

 An audit, process review or management review finding that an amendment is necessary to

achieve the objectives set;

 Number of deviations observed during internal and external controls.

The updating of the environmental and social management system and the associated
management plans is overseen by the Environmental and Social Manager of the EPC.

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4. DEPLOYMENT WITHIN MANAGEMENT PLANS

This Environmental and Social Management system is made up of different plans each dealing
with a specific subject, defined by the environmental studies relating to the project. They are
articulated in a coherent manner in order to address all the risks and potential impacts of
construction activities. These different plans are listed in the following table:
Environmental and social management plans
Environmental and social policies and management system Partner
Environmental and social policies and management system EPC
Water quality and discharge management plan EPC
Air emissions, dust and noise management plan EPC
Erosion control and restoration plan for temporary sites EPC
Hazardous and non-hazardous waste management plan EPC
Hazardous materials management plan EPC
Network travel management plan (electricity, water, optical fiber) EPC
Response plan in the event of an emergency EPC
Traffic interruption plan EPC
Site facilities access and safety management plan EPC
Occupational hygiene, health and safety plan (including COVID program) EPC
Community hygiene, health and safety plan (including COVID program) EPC
Archaeological and cultural heritage management plan EPC
Subcontractor management plan EPC
Safety management plan EPC
HR management plan (working conditions and training of EPC workers) EPC
Local recruitment plan and local outsourcing strategy EPC
Training plan for Partner workers Partner
Stakeholder engagement plan Partner
Mechanism for managing requests and complaints from internal communities EPC
Mechanism for handling requests and complaints from external communities Partner
Resettlement Action Plan Partner
Monitoring and follow-up program for the environmental and social impacts of the Partner
project
Community development plans - Master plan Partner
Community development plans - Detailed plan EPC
Gender action plan EPC
Rules of procedure Partner
Rules of procedure EPC
Compliance records (list of local permits required by national regulations) EPC

Table 6 - Environmental and social management plans deployed by the EPC and the Partner as
part of the Project's environmental and social management system
The various plans mentioned above must be implemented in a coordinated manner. Each of the
Environmental and Social Management Plans (ESMP) clearly identifies the objectives to be
achieved, describes the impact reduction measures, responsibilities and associated indicators.
Through these plans, the EPC will implement all the measures identified in the EIA and which
aim to preserve the integrity of the physical, biological and human environment in the area of
influence of the Project.

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APPENDICES

Page | 36
ANNEX 1 - EPC Health, Safety and Environment
policies

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Page | 38
Annex 2 - NON-CONFORMITY FORM

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 NOTIFICATION FORM FOR A NON-CONFORMITY EVENT
Date :
Name :
Fonction :
Exact location of the Non-
conformity

Description of the Non-conformity:

Immédiate corrective action :

Suggestion :

Final correctives actions :

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 REGISTER OF RECORDING AND MONITORING OF NON-CONFORMITIES

Description Final
Exact location of the Immediate corrective Owner of
Date of the Non- Suggestion correctives Due date Statuts
Non-conformity action implementation
conformity actions