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Liberia 20 MW solar PV – ESMS/ESMP

Liberia-20 MW Solar PV
project
ENVIRONMENTAL AND SOCIAL MANAGEMENT
SYSTEM
(ESMS)
with
ENVIRONMENTAL AND SOCIAL IMPACT MANAGEMENT PLAN
(ESMP)

Responsibility
Hanna Klein, in the role of Gigawatt Global’s HSE Manager for the Project is responsible for the creation
and revision of the ESMS and ESMP.

Revision History

VERSION DATE AUTHOR COMMENTS

00.00 27/10/2020 Hanna Klein First official emission

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Liberia 20 MW solar PV – ESMS/ESMP

Contents
1 DOCUMENT PURPOSE ........................................................................................................................................... 4
2 DEFINITIONS .......................................................................................................................................................... 4
3 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM ...................................................................................... 5
3.1 Policies ................................................................................................................................................................... 5
3.2 Risks and Impacts .................................................................................................................................................. 5
3.3 Management Plans/ Programs .............................................................................................................................. 6
3.4 Capacity and Competency ..................................................................................................................................... 7
3.5 Emergency Preparedness and Response Plan (EPRP) ........................................................................................... 8
3.6 Stakeholder Engagement, Communication, and External Grievance Mechanism ................................................ 8
3.7 Monitoring, Reviews, and Reporting ..................................................................................................................... 8
4 ESMP: ENVIRONMENTAL IMPACT MANAGEMENT PLAN ...................................................................................... 9
4.1 Waste management .............................................................................................................................................. 9
4.2 Use of heavy trucks and machinery ..................................................................................................................... 10
4.2.1 Dust............................................................................................................................................................. 10
4.2.2 Mud ............................................................................................................................................................ 11
4.2.3 Noise ........................................................................................................................................................... 11
4.3 Drainage .............................................................................................................................................................. 11
4.4 Erosion................................................................................................................................................................. 11
4.4.1 Monitoring for erosion ............................................................................................................................... 11
4.5 Material for civil works ........................................................................................................................................ 12
4.6 Biodiversity and endangered species .................................................................................................................. 12
4.6.1 Habitat loss, fragmentation and increased edge effects ................................................................................ 12
4.6.2 Impacts on biota ............................................................................................................................................. 13
4.6.3 Impacts on aquatic ecology ............................................................................................................................ 14
4.6.4 Alien invasive species ..................................................................................................................................... 15
4.7 Cultural Heritage and Chance Find Procedure .................................................................................................... 15
4.8 Visual nuisance .................................................................................................................................................... 18
4.9 Environmental impact during operations ............................................................................................................ 18
4.9.1 Noise ........................................................................................................................................................... 18
4.9.2 Panel Washing ............................................................................................................................................ 18
4.10 Site reinstatement (decommissioning) ............................................................................................................... 18
5 ESMP: SOCIAL IMPACT MANAGEMENT PLAN ..................................................................................................... 19

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5.1 Livelihood Restoration ........................................................................................................................................ 19


5.2 Loss of access to natural resources ..................................................................................................................... 19
5.3 Community Facilities, Access, and Mobility ........................................................................................................ 19
5.4 Occupational Health and safety .......................................................................................................................... 20
5.4.1 Project specific risk ..................................................................................................................................... 21
5.5 Community health and safety ............................................................................................................................. 22
5.5.1 Road safety ................................................................................................................................................. 22
5.5.2 Emergency preparedness and response ..................................................................................................... 22
5.5.3 Grievance mechanism for affected communities ....................................................................................... 22
5.6 Security ................................................................................................................................................................ 23
5.6.1 Disturbance in electrical supply from the plant .......................................................................................... 23
5.6.2 Risk of injury ............................................................................................................................................... 23
5.6.3 Theft ........................................................................................................................................................... 24
5.7 Emergency preparedness and response ............................................................................................................. 24
5.7.1 Roles and responsibilities on site during an emergency ............................................................................. 24
5.7.2 Fire .............................................................................................................................................................. 25
5.7.3 Natural disaster .......................................................................................................................................... 25
5.7.4 Labour unrest (strikes and riots)................................................................................................................. 26
5.7.5 Terrorism and terrorist attacks ................................................................................................................... 26
5.7.6 Bomb threat ................................................................................................................................................ 26
5.7.7 Explosions ................................................................................................................................................... 27
5.7.8 Road transport incidents ............................................................................................................................ 27
5.8 Labour ................................................................................................................................................................. 27
5.9 Workers’ rights .................................................................................................................................................... 28
5.9.1 Working conditions and terms of employment .......................................................................................... 28
5.9.2 Non-discrimination and equal opportunity ................................................................................................ 29
5.9.3 Grievance mechanism ................................................................................................................................ 29
5.9.4 Child labour ................................................................................................................................................ 30
5.9.5 Forced labour.............................................................................................................................................. 30
6 ISSUES LOG .......................................................................................................................................................... 31
7 ROLES AND RESPONSIBILITIES ............................................................................................................................. 31
7.1 Roles and responsibilities during construction ........................................................................................... 31
7.2 Roles and responsibilities during operation ............................................................................................... 33
8 MONITORING AND CONTROL PLAN .................................................................................................................... 35
9 ATTACHEMENTS .................................................................................................................................................. 37

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List of Abbreviations
CLO Community Liaison officer
EHS Environmental, Health, and Safety
ESMS Environmental and Social Management System
ESMP Environmental and Social Management Plan
HSE Health, Safety, Environment
PPE Personal Protect Equipment

1 DOCUMENT PURPOSE
The purpose of this document is to define the system, strategies and plans for how the project will deal
with the potential impacts that the project may have on the environment and on social issues on the site
and in the nearby areas.

The ESMP applies to the 20 megawatt (MW) solar photovoltaic (PV) plant, to be located on the Crawford
Farm in the Montserrado County of Liberia, approximately 4 km south east of the Mount Coffee
Hydropower Plant (MCHPP) and approximately 25 km north of Monrovia.

This document acts as an ESMS – Environmental and Social Management System. This document also acts as
the HSE document for all involved stakeholders, including subcontractors.

In this regard, the ESMP report aims to align itself with the International Finance Corporations (IFC)
Performance Standards (PS), which requires the compilation and implementation of an integrated and
comprehensive system to manage environmental and social risks. The management system will help Gigawatt
Global to assess and control potential project risks, which is essential for sustainable development and
continual improvement.

This document covers the start of the construction until the implementation of the Operations and
Maintenance (O&M) phase and provides the framework for the continued efforts made throughout the plant’s
lifetime (expected to be 25 years).

Gigawatt Global, the developer and the representative of the owners of the project and the Engineering,
Procurement and Construction (EPC) Contractor will come to an agreement on the roles and responsibilities
each party will play out throughout the process of construction. The clear and well-defined roles for the
collaboration between Gigawatt Global and EPC Contractor with regards to all environmental and social issues
enables a proper implementation of the ESMP and its underlaying management plans. The same will be done
for the O&M contractor for the operational phase of the project.

2 DEFINITIONS
Environmental impact is here seen as any physical changes to the area and the surroundings.

Social impact is here seen as any potential impact the project will have on the people being employed by the
project or living and/or staying in the nearby surroundings.

The social impact includes security of the site, health and safety of the workers and the local community and
other social impacts such as social rights of the workers employed.

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3 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM

3.1 Policies

Gigawatt Global’s policies set the foundation of the commitments made towards managing
environmental and social risks and impacts. The policy statements establish the expectations for conduct
in all related aspects of business operations.

Gigawatt Global have set the IFC Performance Standard 1-8 as a best practice for this project. The performance
standards 7 is excluded since no “indigenous people” are being directly affected.

All Gigawatt Global’s projects are expected to be executed at a high standard, within the applicable law and
regulations. Where the local law is ambiguous or insufficient, Gigawatt Global and the EPC Contractor and the
O&M Contractor will use best practices based on our experience in Africa and other parts of the world.

The policy is summarized in the following statements:

- Zero acceptance for fatalities or major injuries on site during construction. A special care is to be made
related to use of all heavy machines, all saws or cutting equipment, and during all DC and AC
installation.
- Zero acceptance for corruption. A special care is to be taken related to all contact with authorities,
especially related to permits, for instance; building permit, permit for waste disposal from site and
grid connection.
- No damage to neighbouring lands due to storm water/flooding and corresponding erosion is accepted. The
project plan is to take special precautions during the rainy season.
- Zero tolerance regarding child labour, in this project defined as below 18 years of age.
- Zero tolerance for human rights violations.
- Zero tolerance regarding forced labour.
- Follow the guidelines of the International Labour Organization.
- Effective waste management will be implemented and followed across all phases of the project:
construction, operation and decommissioning.
- The use of heavy/noisy machinery is limited to daytime use.
- Will endeavour to manage all environmental and social impacts in such a way as to result in a
residual impact that does not disturb the neighbours.

Gigawatt Global’s Health, Safety and Environmental Policy is the overarching policy for the project. It is
annexed to this document (see Section 09 – Attachments) and management commitment to constantly
improve and refine its HSE commitment and implementation.

3.2 Risks and Impacts


Throughout construction on the worksite, there are many potential risks and impacts that can be foreseen due
to human activity and certain materials used in the process of the construction of the plant and transmission
line. In order to prevent undesired events during construction, a detailed ESMP has been developed in line
with the IFC Performance Standards. This ESMP describes the necessary steps and precautions to be taken in
order to ensure the protection of the environment, as well as for the safety of workers on site and for the
surrounding communities.

Risks regarding the projects influence on the environment have been addressed in the ESMP and the
documents referenced in it. A Livelihood Restoration Plan consistent with national law and international good
practice (specifically the IFC Performance Standard 5 on Land Acquisition and Involuntary Resettlement, 2012)
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will need to be developed (prior to construction) to address the fair, full and prior compensation for all existing
subsistence farmers affected by the project (solar PV plant and transmission line).

A health and safety plan (H&S plan) will need to be developed with detailed strategies and procedures to be
followed. This plan will help provide a clear understanding for employees, contractors, and subcontractors of
the risks and hazards, as well as the training needed to ensure the safe environment Gigawatt Global strives for
as well as compliance with the IFC Performance Standards and other policies. Mitigation measures with be put
in place, in compliance with the H&S plan to deal with accidents, fires or other forms of emergency events. A
comprehensive list of risks relative to the construction will be included in the H&S Plan.

A “COVID-19 Onsite Routines in Liberia” procedure (see Section 09 – Attachments) sets out actions on how to
deal with all issues related to the pandemic.

The project will need to adhere to the IFC performance standard 4-Community Health Safety and Security and
use it as best practice. The detailed implementation of these standards is listed in the ESMP and supporting
documents. The project will evaluate risks and impacts to the health and safety of the affected community
throughout the project life-cycle and implement the appropriate measures.

A Worker’s Management Plan (see Section 09 – Attachments) addresses the risks and procedures related to
workers engaged for construction.

3.3 Management Plans/ Programs

Gigawatt Global’s management plans are centred on action plans and improved procedures to avoid,
minimize or compensate for the risks and impacts that were identified.

Gigawatt Global is committed to follow an effective management plan to guarantee that all E&S
requirements are complied with. The plan is focused on addressing all aspects of managing the shipping,
construction, traffic, drainage, erosion, biodiversity, power machine handling, water management, chance
find of any cultural heritage artifacts and waste management, to name a few.

The detailed management plans have been put together in order to address key issue that can or will be
occurring throughout the construction and operation phases.

The management plans create clear boundaries and focus for all activities relating to environmental, health,
safety and security issues which also assist the project to conduct the implementation and operation of the
plant at a high standard. This prevents accidents and unintended consequences, which can occur if all aspects
of the project implementation have not been planned in advance.

For each social or environmental issue there is a plan that describes the required steps and processes on how
to manage these issues properly. All activities on the site of the solar PV plant and the transmission line will
be monitored to assure that any problem that arises will be dealt with accordingly to the management
programs developed.

The ESMS framework for the project is presented in the figure below.

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All plans will be regularly up for review and refinement. A version control system is in place for each report.

3.4 Capacity and Competency

Gigawatt Global’s organizational capacity and competency is reflected in its ability to implement the
ESMP/ ESMS. This includes commitment from senior management to appropriately allocate and
mobilize the relevant resources to effectively carry out required actions.

Gigawatt Global shall establish the competency requirements and the training needs of all environmental,
health, safety and social staff.

EPC and O&M Contractors will be hired by Gigawatt Global to construct, commission, maintain and
operate the solar PV plant. An EPC Contractors will be hired by Gigawatt Global to construct and
commission the Transmission Line, after which it will handed over to the Liberia Electricity Company (LEC)
for operations and maintenance. The EPC Contractor, O&M Contactor and the LEC will be responsible for
the implementation, maintenance, monitoring and reporting of the ESMP and all associated activities
outlined in the management plans attached and connected to it.

Gigawatt Global, is ultimately responsible for the solar PV plant and the building of the transmission line.
As such Gigawatt Global’s Health, Safety and Environmental (HSE) manager and a Community Liaison
Officer (CLO) will work in close collaboration with the EPC and O&M Contractors to achieve the project’s
goal regarding Environmental and Social (E&S) issues. The Roles and Responsibilities are clearly defined in
the ESMP in Section 7.

All the managers involved in the project will be trained in the ESMS and ESMP before construction starts.
The HSE Managers from Gigawatt Global and the EPC/O&M Contractors will design the training and lead
the training sessions.

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3.5 Emergency Preparedness and Response Plan (EPRP)

Gigawatt Global acknowledges that accidents and emergency situations can occur on site. An Emergency
Preparedness and Response Plan (EPRP) found in Section 5.7 below has been developed to ensure there is
adequate emergency control and personal protective resources available.

Gigawatt Global is responsible for all stakeholders on the solar PV site and transmission line corridor in the event
of an emergencies or disaster. Gigawatt Global will strive to take the best course of action for any type of
emergency that could potentially occur during construction and operation of the solar PV plant. A clear and
systematic system has been designed in order to execute a given response plan in case of need.

For each emergency a defined procedure is followed, and the roles and responsibilities are clear.

There are clear procedures for incidences in the response plan and defined steps described to prevent the
escalation of a given event in an emergency.

The project will constantly make risk assessments and update the EPRP if needed. All people being present at the
site shall be informed of the EPRP when they first enter the site, or at first convenience.

Any incidents are tracked in the projects Issue Log by the Site or Project manager.

The Emergency Preparedness and Response Plan (EPRP) is described in detail in chapter 5.4.

3.6 Stakeholder Engagement, Communication, and External Grievance Mechanism

Gigawatt Global aims to ensure that fluent and inclusive communication and consultation process are in
place for all stakeholders. In this regard, the company is implementing a Stakeholder Engagement Plan
(SEP) and an External Grievance Mechanism (see Section 09 – Attachments) to facilitate open and
transparent communication.

Gigawatt Global takes all matters seriously when it comes to our internal and external stakeholders involved in
the project. In order to achieve the best strategies and methods for awareness and communication between
stakeholders, we have a developed Stakeholder Engagement Plan including a defined Grievance Mechanism.
This assures a system for constant stakeholder involvement and shows the stakeholders that the project is
respecting their need for information and their right to express their opinion and file their grievances. All
grievances are logged in the Grievance Log for the project together with all supporting material. The Grievance
Log includes both the complaint and the solutions and actions taken to resolve the grievance.

By ongoing stakeholders’ engagements throughout the project GWG can avoid stakeholder related risks.

Stakeholders on site and in the surrounding communities will be informed by the Community Liaison Officer how
to best stay informed of the project development and to get in contact with the project to file grievances, if
necessary. More detail on the Grievance Mechanism is provided in Chapter 5.3.3.

3.7 Monitoring, Reviews, and Reporting

Gigawatt Global aims to establish a robust system of continual learning and improvement, which includes
internal and external reporting, monitoring, auditing and integrated performance reviews.

Continuous monitoring and reporting will be carried out throughout the construction and operation in order to
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establish a system in which we can track and verify our goals and tasks in a systematic manner. The reporting
keeps the overall project clear and organized and creates a system in which we can evaluate the effectiveness of
our applied methods.

Weekly site inspection reports and monthly E&S reports will be provided by the EPC Contractor during the
construction period (including both the construction of the PV plant and the transmission line). An issue log
together with the grievance log will be available for all parties online, together with reports and training records.
The incident and accident reports will be available to all project partners.

Gigawatt Global’s HSE manager will have a weekly update meeting with the EPC/O&M Contactor’s Project
Manager, Site Manager, HSE Officer and the Gigawatt Global Community Liaison Officer to discuss E&S issues
surfacing on site.

The EPC/O&M Contactor’s HSE manager will prepare the monthly E&S report with input from HSE officer(s). All
issues relating to E&S will be detailed. This report will also include: a) electricity consumption (kWh), b) diesel
consumption, c) water consumption, d) a list of the volumes of waste removed from site (m 3), e) number of
accidents/incidents reported, f) numbers of workers on site/day, g) average working hours per worker over the
month, h) average wage paid per/hour, i) % of female works on site that month. This report will be sent to
Gigawatt Global’s HSE manager for review.

Following the issuing of the monthly report Gigawatt Global’s HSE manager and EPC/O&M Contactor’s HSE
manager will have a meeting to discuss the report and adjust processes/docs if necessary.

All grievances logged by stakeholders will be made available online on a project specific shared drive.

Gigawatt Global’s HSE manager, the Engineer and external auditors will make planned and unplanned
appearances on site to inspect that all E&S procedures are being followed.

The project has a Monitoring and Control Plan provided in Chapter 8.

4 ESMP: ENVIRONMENTAL IMPACT MANAGEMENT PLAN

4.1 Waste management


The project will handle all incoming waste materials, all waste generated on site and both the disposal, and
potential recycling of such materials. A separate Waste Management Plan will need to be developed by the
EPC and O&M Contractors with clear directions of how to deal with and waste and a registry for the
movement of the waste within the site and off-site. The exact quantities will be detailed once at the
packaging and quantities of incoming material is identified. All solid wastes generated (hazardous and non-
hazardous) will be disposed of through contracting an approved waste handling company for the
disposal/recycling at appropriately licensed landfill site/s.

The project waste is primarily related to civil works, and packaging of incoming materials. The following
principles are put in place to reduce the amount of waste generated:

- Packaging will be optimized to reduce non-recyclable content.


- All subcontractors delivering goods to the site will be encouraged to take the packaging material back with
them post-delivery, i.e. we try to not keep packaging on site at all, but let the delivery truck take it back
with them as they leave the site.
- Orders of cables and other consumables will be kept to a minimum.
- The amount of earth works is kept to a minimum, including optimized road works to reduce required
import of material to site.
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Typical waste being generated on the site and appropriate handling is identified in the table below:

Waste Recommended handling


Organic waste such as plants, trees and grass during Wood: made available for locals. Grass and smaller
clearing of the site plants and wood: to be disposed at an agreed place

PV panels and cabling will be by far the biggest Collected and recycled by logistics supplier
component brought onto site that will generate
significant waste – wooden pallets, paper, plastic
Cardboard from packaging of shipped parts Collected in separate containers, recycled if possible
Sewage and grey water from sanitization Collected by service provider for disposal at effluent
treatment works
Other waste, garbage etc Collected in separate containers and disposed
according to local legislation
Cables; PVC, copper and metal Collected in separate containers for recycling
Photovoltaic Panels Panels that a malfunctioning during operation will also
be stored (on-site or rented locate off-site) until the
volume is feasible to send abroad or recycled/disposed
of locally.

Broken panels will be stored in their used crates in the


lay down area and will be returned to the
manufacturer.

4.2 Use of heavy trucks and machinery


The project will use heavy trucks and other heavy machinery in a way that minimizes the potential negative
effects of such use.

A Traffic Management Plan will need to be developed to further manage and mitigate the impact of heavy
machinery and trucks arriving on site.

All goods are expected to be brought to Monrovia for custom’s clearance. The 40 ft containers will be
unpacked by the freight company in Monrovia. The panels and other equipment will be reloaded on 20 ft
containers to be transported to the site. During a 3-month period the container truck will make 3 trips a day
from Monrovia to the project site to deliver all equipment imported for the solar PV plant.

The effect and mitigation of dust and noise are described below.

All use of heavy machinery will be done at low speeds to ensure safety on site and reduce any negative impact
they might have.
4.2.1 Dust
Suitable measures will be adopted to manage fugitive dust from vegetation clearing during the construction
phase. This will include a programme of dust management that limits both occupational and community
exposure to dust.

During dry periods sprinkling of water on the roads and construction areas will be done if required avoid dust
spreading. Any transport of soil to and from the site will be covered to avoid dusting.

Construction vehicles will be limited to speeds of 20 km/hr on-site. An appropriate speed must be adopted
along the unpaved areas on the access roads to the site to ensure limited dust generation.

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Gigawatt Global will ensure that fugitive dust emissions will be actively managed during the operational life of
the project.

The grievance mechanism will be used throughout the construction and operation phases to address any
community complaints regarding dust.

4.2.2 Mud
During wet seasons the use of heavy machinery will be avoided if possible. During random showers the water
will be allowed to drain before machinery is moved across the site.

4.2.3 Noise
Heavy and noisy machines will be used during daytime wherever possible. If night time work is required
the CLO should inform nearby residents 24 hours in advance of undertaking the required noisy activities.
Noisy machines are machines which leads to measurable noise levels above 50dB at the outer perimeter
of the site.

All employees in the proximity of machines producing noise above 70dB shall wear ear protection such as ear
plugs.

Construction vehicles and plant will be serviced according to manufacturer’s specifications, and maintenance
records must be kept up to date and presented for inspection as required.

Noisy work on Sundays, around the southern portions of the site, should be avoid as far as possible due to
the close proximity of the church

The grievance mechanism will be used throughout the construction and operation phases to address any
community complaints regarding noise.

4.3 Drainage
During the construction phase, part of the site will at times consist of loose and/or uncompacted soil and
removed or compromised vegetational cover. During this phase temporary drainage systems will have to be
installed. This will consist of landforms, both trenches, and deep pits to collect and dissipate water. The
temporary drainage will either be converted into permanent drainage with masonry (where co-located) or
closed off after completion of construction.

4.4 Erosion
The erosion of the site is avoided and/or reduced by the following main measures:

- The project is dedicated to make every effort to retain the top soil within the solar PV site during
construction.
- The drainage system is in place to avoid water streams over the areas with highest risk of erosion.
- The drainage system is in place at the perimeter stopping and/or redirecting any water flow directed
out of the site.
- Vegetation is kept in place to a maximum extent on the entire site.

During construction some vegetative cover will be damaged by heavy machinery compacting the land.
Replanting of ground cover and low bushes is prioritized to secure a vegetation cover during the rainy
season.

4.4.1 Monitoring for erosion


During the weekly site inspections in the construction phase, the HSE Officer will look for evidence of
erosion. Additional inspections will take place after heavy rain fall events. Once the site has been restored
with a grass cover the inspections is required to be done monthly and after heavy rain fall events.

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The monitoring shall include the correct shape of the land surface, the roads, and the fence line. If the
monitoring shows damages in the grass layer, it will be repaired. If the monitoring shows wash outs or gullies
deeper than 10 cm, they will be filled up by a mixture of gravel and sand and covered with cohesive soil. After
that grass is sown. The gravel can also be covered by patches of grass including roots and soil. Blockages,
clogging, and vegetation clusters, especially along the fences, must be removed regularly.

If the erosion problem continues further mitigating actions may be required. The highest risk for erosion is
considered to be directly under the edge of the solar panels and along access roads. This is where water will
concentrate. Bushes and more heavy vegetation, or stones could be considered if local erosion is identified.

4.5 Material for civil works


New access roads will be required leading from the amin access road running along the southern boundary of
the solar PV site.

A limited amount of soil will be moved at the project site and along the transmission line. The moved soil will
be stored on site and re-spread on site when the construction is completed.

The delivery station and the transformer will have foundations. The sub-contractor building the foundations
will have to specify where the gravel and sand originates from before the start of the work and the HSE Officer
will approve the origin of the material.

4.6 Biodiversity and endangered species


The project will not use material made from anything on the endangered species list. This includes
suppliers’ packaging of incoming goods to the site.

The project will not use pesticides on the site.

Areas will be thoroughly checked by a local biologist prior to site clearing to locate and identify small animals (such
as tortoises, chameleons, lizards, frogs, small mammals, snakes etc.) unable to escape from the site and relocate
them to an appropriate location for their safety. The project has a fauna protection policy. This policy prohibits any
forms of hunting, consumption of bush meat or trade in animal products from the project site and surrounding
areas. Drivers will be instructed to watch out for animals on the road and to take measures to avoid unnecessary
road kills. All staff and contractors required to abide by has a fauna protection policy.

4.6.1 Habitat loss, fragmentation and increased edge effects


No activities are to take place in the wetland areas or “Young Bush” areas (i.e. historically disturbed areas indicated
as having low sensitivity should be used for the proposed development). Peg out and demarcate these areas as no-
go areas before commencing with site clearing activities.
The solar PV site shall be fenced off at the start of construction.

Upgrade and use existing roads where possible. Where possible a ring road system should be implemented as the
rounded shape of roads will decrease potential edge effect. Existing roads which will not be used for the proposed
development should be removed/de-compacted and allowed to revegetate naturally.

Revegetate any temporary roads as soon as possible after use. Additionally, width of roads should be kept to a
minimum.

Loss of riparian vegetation associated with streams and creeks should be avoided.

Harvesting of plants and hunting of animals will not be allowed.

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Indigenous grasses could be removed from development footprint areas as sods but planted in temporary flower
beds, should be watered if required, while stored until such time that it could be used for rehabilitation.

Run-off control measures on either side of roads must be constructed to allow for small terrestrial animals to cross.
Ditches/trenches should have slopes of less than 45° rather than vertical sides.

Plan for placement of material stockpiles (topsoil and subsoil and excavated rock) within the areas designated as
low sensitivity. Do not leave the soil or rock mounds in place after construction, but rather spread these out over
the area of low sensitivity after construction.

Where areas not targeted for development are inadvertently impacted and/or damaged, clear any material
dumped and rehabilitate the site as soon as possible, by levelling, ripping compaction and allowing to revegetate.
Where excessive damage has occurred to the inland wetlands, creeks bed, stream banks or riparian zones, this
must be rehabilitated immediately under the guidance of an aquatic specialist.

Locate transmission line pylon outside of high sensitivity areas along the route.

Minimise construction footprints within creeks and wetlands along the transmission line by demarcating vehicle
access routes and clearing the minimum required servitude width. Loss of riparian vegetation associated with
streams and creeks should be avoided. Construction in and around wetlands and creeks should be limited to the
dry season as far as possible.

4.6.2 Impacts on biota


No activities are to take place in the wetland areas or “Young Bush” areas.

Harvesting of plants and hunting of animals will not be allowed. If any protected or endangered plant species are
encountered during site clearing, they must be relocated to suitable habitats.

Avoid unnecessary drainage line crossings and design site drainage and stormwater runoff to minimise risk of
contaminated water entering the stream course or aquatic features (e.g. seasonal pans).

Conduct clearing and construction activities during the drier months of the year if possible.

Ensure chemical storage and use complies with standard good practice and be stored in an enclosed restricted
access area (to prevent human re-use) and disposed of at an approved waste facility or by approved waste service
providers. Hazardous chemicals, including fuels, should be stored in a bunded and fenced area located at least 150
m from the seasonal drainage line or other surface depressions or pans.

Conduct site inspections to check for oil spills and leaks on soil surface and water bodies (if any form in the wet
season) and implement remediation as required.

Vehicle maintenance shall be done on an impermeable surface to prevent soil and water contamination.

Transmission line configuration should be designed to minimise electrocution risks to birds perching on the pylon
structures by implementing the following types of measures where practically possible:
• Configure the insulators and conductors in such a way that birds landing, perching or taking off cannot
connect them by keeping as many elements as possible under the cross-arm; and
• Insulate all the live elements of the structure sufficiently to ensure that birds cannot connect exposed, live
elements.

Bird diverters: Consideration could be given to installing bird diverters on the line, particularly where the
transmission line crosses streams, creeks and wetlands.
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4.6.3 Impacts on aquatic ecology


No activities are to take place in the wetland areas. Peg out and demarcate these areas as no-go areas before
commencing with site clearing activities.

Locate transmission line pylon outside of wetlands and creeks along the route.

Where vehicle access and work within a wetland or creek is unavoidable along the transmission line, demarcate the
access route using temporary markers. Limit disturbance along edges, monitor edges for any emerging alien
invasive species and ensure that these are rapidly removed.

If wetland areas are disturbed they must be revegetated with locally indigenous vegetation.

Concrete mixing must occur on impermeable surface and more than 50m away from any wetland area or drainage
lines. If ready-mix is available, it would be preferable to use rather than mixing concrete on-site.

Provision must be made for adequate sanitation facilities located at least 150 m away from the wetland areas and
drainage lines. Toilets and general plumbing will be regularly checked for leaks which will be attended to
immediately.

Ensure the necessary spill kits are available on site. All hydrocarbons spills on bare ground will be cleared
immediately. This will include the lifting of the contaminated soil for bio-remediation or disposal to a hazardous
waste facility.

Develop soil and storm water management plan for the entire surface area of the solar PV plant that will prevent
concentrated runoff into the wetland areas, including the use of diversion trenches, berms, flow control dams, silt
traps etc. Run-off from the developed areas need to be redistributed evenly over large areas well away and outside
of the wetlands through appropriate modelling and design.

Cut-off drains should be located in such a way that the zone of influence (the area affected by the drain – these
drains divert surface and subsurface flow in a certain direction, and lead to drawdown over a wide area) is well
away from the wetland areas. The area of influence should be determined by a hydrogeologist. The construction of
surface stormwater drainage systems during the construction phase must be done in a manner that would protect
the quality and quantity of the downstream aquatic systems.

Where applicable, the use of swales, which could then be grassed for the operational phase, is recommended as
the swales would attenuate run-off water. Stormwater outflows should not enter directly into a wetland or
drainage line or their buffer zones. The velocity and quality of water that may reach wetland and drainage line
buffer zones should be the same or similar as the predevelopment scenario through using siltation and erosion
control structures.

Abstraction of water from wetlands areas must not be allowed for any purpose.

Repair all erosion damage as soon as possible.

Avoid impeding the natural drainage the wetland systems in order to prevent ponding and subsequent loss of
biota.

Avoid impeding the flow of the creeks along the transmission line.

Ensure chemical storage and use complies with standard good practice and be stored in an enclosed restricted
access area (to prevent human re-use) and disposed of at an approved waste facility or by approved waste service
providers. Hazardous chemicals, including fuels, should be stored in a bunded and fenced area located at least 150
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m from the seasonal drainage line or other surface depressions or pans.

Conduct site inspections to check for oil spills and leaks on soil surface and water bodies and implement
remediation as required.

Maintenance on vehicles/diesel powered equipment will be conducted off-site or within a designated, paved and
bunded area.

4.6.4 Alien invasive species


Monitor for any emerging Alien Invasive Species and ensure that these are rapidly removed. Care should be taken
when using chemical sprays. Preferably use them well away from the wetlands and “Young Bush” areas. Ensure
that if herbicide has to be used they are specific to the targeted Alien Invasive Species and not a broad spectrum
herbicide. If this is unavoidable, take notice of wind direction to prevent drift and be aware that chemicals could
runoff or leach through the soil into the habitat and cause extensive damage.

Herbicides shall not be used within 50m of wetland and creeks (i.e. only manual clearing is allowed). The use of
herbicides for plant maintenance should be avoided but if essential only environmentally approved brands that
comply with Liberian legal requirements and relevant international conventions should be used. Persistent Organic
Pollutants (POPs) and Pesticides as listed by UNEP will not be allowed.

All alien invasive species seedlings and saplings must be removed as they become evident for the duration of
construction.

Staff at the plant must be educated and made aware of alien vegetation that could be present and that must be
eradicated.

Sourcing of fill material: any requirement for fill material to create a level platform for site development should be
sourced from weed free areas to minimise the risk of spreading alien invasive species and to reduce the ongoing
maintenance requirements.

All construction vehicles and equipment, as well as construction material should be free of plant material when
leaving the site to avoid contamination of road reserves. Therefore, all equipment and vehicles should be
thoroughly cleaned prior to leaving the site.

On-site alien invasive plant monitoring and control (removal and disposal).

Alien vegetation management: ongoing monitoring will be required during operation to ensure the site is kept free
of alien invasive species and any species are removed on a regular basis (before flowering or seeding occurs.

4.7 Cultural Heritage and Chance Find Procedure


The IFC performance standard 8 cultural heritage (January 2012) is to be used as a reference for best practice.
The projects’ chance find procedure is found below.

The site must be fenced off at the start of construction.

The two graveyard sites located near the solar PV site shall be demarcated as no-go areas and all project staff
(including contractors) shall be made aware of this.

A “Chance Find” refers to any cultural heritage site or associated material encountered during the course of
construction works, as opposed to finds made in the course of intentional archaeological investigation.

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Chance Finds include, but are not limited to artefacts, archaeological deposits, ruins, monuments, and human
remains.

The Chance Find Procedure presented in this document serve as international best practice policy for the
accidental discovery of cultural and heritage resources as well as burial grounds/graves. Based on the
definitions provided within this document and the proposed lines of communication, Gigawatt Global will
be able to mitigate the accidental discovery of these items through the various phases of the project

The Gigawatt Global HSE Manager will act as the “owner” of the Chance Find Procedure and to ensure that
compliance is enforced through this person.

All intrusive site activities such as land clearing, open pit excavation and earth works within the Solar PV site
and along the transmission line will be carefully monitored.

All personnel involved in land clearance and excavation will be responsible for managing archaeological
protection, including the adoption of this Chance Finds Procedure.

Gigawatt Global will provide training for EPC Contractor personnel to help identify archaeological objects and
make them aware of how to implement the Chance Finds Procedure. Gigawatt Global and the EPC Contractor
will make all employees aware of the cultural and social significance of any chance finds during the life of the
project and ensure that they understand that they will be strictly prohibited from interfering with or disturbing
cultural heritage sites and artefacts. This will be included in induction training, as well as provided for in any
third-party contracts.

Excavation in and around sites of known cultural interest (notably local graveyards) will be entirely avoided.
Gigawatt Global will define these areas as exclusions zones and will place suitable boundary makers. Where the
disruption of such sites is unavoidable, prior discussions must be held with the relevant authorities to undertake
pre-construction excavation or assign an archaeologist to log discoveries as construction proceeds.

Gigawatt Global will ensure that all records and reports of any fortuitous finds are made available to the national
institution responsible for the management of cultural heritage.

Chance Find Process:

Where historical remains, archaeological artefacts (relics, tools, bones, ceramics, graves, etc.) or any other
object of cultural or archaeological importance are unexpectedly discovered during construction in an area
not previously known for its archaeological interest, the following procedures should be applied:

1. Stop construction activities and inform site supervisor/foreman;

2. The site supervisor/foreman will notify the Gigawatt Global HSE Manager immediately.

3. The EPC HSE Manager will delineate the discovered site area, and secure it to prevent any damage or loss
of removable objects.

4. Gigawatt Global will appoint a qualified archaeologist to assess the significance of the suspected chance
find.

5. The Gigawatt Global HSE Manager will liaise with the relevant ministry/authority to determine the need
for further investigation and appropriate action.

6. In the case of human remains the local authorities and police must be notified and an autopsy process
may be triggered. Where it is confirmed that the remains are unclaimed graves, Gigawatt Global will
ensure their relocation.

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7. Decisions on how to handle the findings will be reached based on the above assessment and could
include conservation, preservation, restoration, or salvage. The final action will be established in
agreement between Gigawatt Global and the relevant authority.

8. Any subsequent investigation or excavation works will be conducted by a suitably-qualified


archaeologist/palaeontologist.

9. Construction work can resume only when permission is given from the relevant authority after the
decision concerning the safeguard of the heritage is fully executed.

If further detailed excavation works are required (as determined under the guidance of the relevant national
and regional authorities), Gigawatt Global will ensure that:

1. Any necessary permits and licenses for archaeological investigation and removal will be obtained from
the relevant authorities.

2. Archaeological chance finds will be discussed with the local community to establish local significance,
and community buy-in in terms of any actions to be undertaken.

3. Mapping will be carried out to identify the likely spatial extent of archaeological site, and trial pits will
be dug by hand excavation.

4. The excavation process and the different archaeological material (ceramics, stones, charcoal, seeds,
bones, etc.) will be registered in detail using photographs and field diaries.

5. Any material found in the pits will be treated (washed and tagged) and later classified in accordance
with accepted criteria.

If archaeological/paleontological excavation or retrieval processes are required for chance finds of cultural
sites within the project footprint the following additional procedures will apply:

1. Work must be completed by a qualified archaeologist/ palaeontologist.

2. Activities may be monitored by representatives of the local communities.

3. Consideration will be given to supplementing excavation work with non-destructive means of


investigation (e.g., geophysical survey, remote sensing, geochemical survey, field scanning).

4. Arrangements will be made with local communities and authorities if storage or relocation of the
artefact is required.

5. Records (written, graphic, electronic, and photographic as appropriate) will be made for all works.

6. A post-excavation assessment report will be produced.

Some types of cultural heritage resources (e.g., ethnographic stone pits) cannot be excavated, salvaged and
relocated. Procedures for documenting these sites will involve the following:

1. Consultation with all relevant parties (e.g., local communities and authorities) to determine if these
items should be destroyed.

2. Prior to destruction, the items will be documented to record the physical extent of the item and the
physical environment in which the item is located.

3. Photographs may be taken and added to Company records.


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4.8 Visual nuisance


To reduce the visual impact of the Project on road users and nearby residents, a vegetated buffer or screen
of vegetation along the perimeter is recommended where technically feasible without restricting solar
radiation and project performance.

For the construction phase the following minimum requirements are listed:

• Site rules are communicated through signs at site entrance.


• The main storage area will be well organized with clearly marked locations for equipment,
machinery and various types of waste.
• Machines leaving the site should be cleaned before exiting the site.
• Garbage bins are placed in all areas where needed, and these are emptied as needed.
• No littering is accepted.
• Sleeping, resting or staying within the construction site is not allowed.
• Speed limit on site is 30 km/h, and within the laydown area 10 km/h.

The EPC Site Manager is the main person responsible for enforcing these rules. The EPC HSE officer will be
including these descriptions of the site rules at all trainings and tool box talks.

The site’s rules for operations are developed before project commissioning.

4.9 Environmental impact during operations


The Environmental Management Plan developed for the construction phase will be used for the Operational
Phase as well, though a number of items will be adjusted to reflect the drastic reduction of activities during
the Operational Phase. The reduced version of the EMP for operations will be completed before project
commissioning. The volume of water and solid /liquid waste will be drastically reduced, but the management
of these issues will remain unchanged. The water requirement on site during operation is expected to not
exceed 1 m3 per month. For water usage for panel washing during operation, see section 4.9.2 below.

The following items operational requirements are considered to be important during sourcing and planning
for the project and are therefore specified here:

4.9.1 Noise
During operations the plant will have the following noise targets related to inverters, tracker tables or other
use of PV plant installation.

• Daytime: <50dB measured at outer perimeter of the site.


• Night time: <35dB measured at outer perimeter of the site.

The noise requirement is in force both during construction and operation, though it might be temporarily exceeded
as large construction machinery are entering the site.

4.9.2 Panel Washing


The solar panels will be professionally cleaned twice a year. Approximately 80 m 3 will be used for each cleaning.
The water will be brought to the site by the same provider that was used during the construction.

4.10 Site reinstatement (decommissioning)


The PV plant will be decommissioned through five main activities:

• Disassembly and recycling of the modules, inverters, sub-station and tracker tables.
• Removal and recycling of AC and DC cabling in the ground.
• Remove ramming poles by pulling these out by the use of excavator, crane or similar.

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• Removal of trenches and drainage system by the use of excavator, bulldozer or similar.
• Replanting of vegetative cover.

The site is expected to have little or no visible traces of the installation after decommissioning and rehabilitation.

The decommissioning of the plant is expected between 30 and 35 years post-construction. A detailed
decommissioning plan with environmentally sound waste management will be developed 1 year prior to
decommissioning. Gigawatt Global and its investors takes responsibility for the developing the decommissioning
plan according to national laws and the IFC performance standards.

5 ESMP: SOCIAL IMPACT MANAGEMENT PLAN


Due to the timing of the implementation of this project, during an outbreak of COVID-19 virus, a COVID-
19 Contingency Plan will need to be developed to prevent the spread of the virus and to provide an
action plan when/if a suspected case of the virus has been detected. The Workers’ management plan to
be developed must specify all aspects of interactions between the project and workers for the project.
The Stakeholders Engagement Plan and Grievance Mechanism specifies how the project will deal with all
the different stakeholders.

5.1 Livelihood Restoration


Prepare a Livelihoods Restoration Plan (LRP) consistent with national law and international good practice
(specifically the IFC Performance Standard 5 on Land Acquisition and Involuntary Resettlement, 2012) to
compensate for the loss of small-farming undertaken in the Project site, as well as pay special attention to affected
vulnerable households (female headed households, elderly headed households, landless-households etc).

The LRP will address the fair, full and prior compensation for all existing small-scale farm plots as well as investigate
the provision for in-kind replacement farmland outside the solar PV site.

The LRP will provide measures that allows for continued harvesting of natural resources from the solar PV site
(prior to site clearing).

Undertake a Social Due Diligence of the CLSG Transmission Line to determine past land acquisition, compensation,
and resettlement activities, as well as existing land use restrictions in the CLSG Transmission Line wayleave.

5.2 Loss of access to natural resources


Establish a Corporate Social Responsibility (CSR) plan that will support investment into community services,
facilities as well as livelihoods of neighbouring households.

Ensure that local households will be permitted to collect cleared trees, bamboo or other economically valuable
materials during vegetation clearing that will occur during the construction phase.

Biomass removed from the project site during site clearing should be made available for the local community to use
as building material, firewood or to refine and sell.

5.3 Community Facilities, Access, and Mobility


Prioritise to use of the Monrovia-Careysburg tarred road during construction where feasible for the powerline and
substation and minimise the use of the gravel roads surrounding the solar PV site. Where the gravel roads are
regularly used by construction traffic, endeavour to maintain the gravel roads in good working condition.

Avoid the use of local public facilities, services and infrastructures, and the construction contractor will establish

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their own internal infrastructure (water, sanitation etc.) or establish agreements with suitable private service
providers (emergency response, health, sanitation etc.). In the event where a Project activity or equipment causes
an emergency or incident with any member of the public or local communities, the Project will ensure that their
emergency response plans will cater and support any affected person.

Establish suitable traffic safety measures or traffic management plans that address (1) road usage and
maintenance, (2) continued public access to roads during construction and (3) public commuter and pedestrian
traffic safety

During the operational phase, do not acquire any existing public roads, nor seek to obtain any exclusive access
rights to any gravel roads surrounding the Project site, and explore supporting the local road authorities in terms of
ongoing maintenance of existing gravel roads near the site.

Community Development, Local Employment and Local Content


As noted above, establish Corporate Social Responsibility (CSR) plan. The CSR plan should provide annualised funds
for the investment with a focus on energy and sustainability in local community development projects, for the
duration of construction and operational of the solar PV project (a minimum of 20 years).
Establish suitable Human Resources and Recruitment Procedures that establish rules for local recruitment and
preferential employment. These procedures will be issued to the construction contractor for adoption with the
own internal recruitment procedures during the construction phase. The procedures will also apply to the
operational workforce.

Establish suitable local content procedures as part of their overall procurement system. The procedures will be
issued to the construction contractor for adoption with the own internal procurement procedures during the
construction phase. The procedures will also apply to local procurement of materials and services during the
operational life of the solar PV project.

For the purposes of the CSR, as well as local recruitment and procurement, the terms local shall be defined by
multiple levels, and priority will be given to household and community in the order below:
• Priority Level 1 – Households immediately surrounding the Project site and final transmission line, with
specific focus on residents of Crawford Farm.
• Priority Level 2 – Communities nearest to the Project site and final transmission line, covering Crozierville,
Bensonville, Harrisburg, and Mount Coffee.
• Priority Level 3 – Persons and businesses based in Monrovia, and thereafter nationally

5.4 Occupational Health and safety


The IFC General EHS guidelines, chapter 2 will be used as best practice.

The various subcontractors are responsible for practical HSE issues and will be appropriately trained and will
have to sign that they are dedicated to adhering to the H&S plan. A person with knowledge of local HSE
regulations will be integrated in the team. The EPC HSE Officer, to ensure that all obligations as an employer are
fulfilled and that EPC’s vision on HSE is attained.

All accidents and injuries will be documented and investigated. Alerts will be sent to the whole HSE team when
anything is logged, including near-misses. Zero accidents is the goal.

Any incidents and non-conformity, will be logged on a shared drive, web-based system together with
grievances, training records and statistics for H&S.

If dangerous situations are encountered the EPC HSE Officer, in coordination with the EPC Project Manager
and/or the EPC Site Manager, has the authority to stop the works in the relevant area until the issue is
solved.
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5.4.1 Project specific risk


The following is a summary of expected HSE related risk. The main H&S risks and primary mitigation measures
are presented in the table below. The full risk evaluation for construction phase needs to be included in the
H&S Plan. The “safe work method statement” is to be used on all work to develop correct mitigating actions.

Activity Primary Mitigation


Welding (UV light and temperature) Personal Protective Equipment (PPE)
Require documented training
Manual work (shovels, axes etc) PPE
Sufficient spacing
Continuous supervision
Chain saw PPE
Require training in use
Clearing of trees; falling trees PPE

Excavation/ Bulldozer use (being near machines) PPE


– safety around bulldozers Site rules
Safety rules
Procedure for use of machines
Procedure for work on site around machines
Manual handling (transport of heavy objects) PPE
Trenches and ponds (risk of falling) PPE
Marking of all ponds and open holes
Snakes (poisonous snakes on site) PPE
Snake bite procedure
Kinetic/mechanical energy from tools, rocks PPE

Ramming; risk of injury if hit by moving parts of PPE


ramming machine Safe work planning
PV module assembly manual
Falling objects: heavy beams up to 10 meters long PPE
being transported and laid down on site Continuous supervision
PV module assembly manual
Loose parts, while assembling the steel parts may PPE
be loosely fitted or not yet fastened PV module assembly manual
Live DC current. The PV modules cannot be PPE
turned off and will produce electricity at all times. PV module assembly manual
All wires are hot, with up to 1000V
Medium voltage; the site will consist of MV Require certified training, and experience
equipment and cables with 15kV. Risk of electric Define in the H&S plan
shock
DC cables 1000V being connected Define in the H&S plan
Concrete used for foundations; risk of acid burns, PPE
eye damage while mixing
Welding PPE
Require documented training
Load handling (up to 30T loads) PPE
Load handling procedure
Require certification for handling crane
Require closed off area, no one to enter

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5.5 Community health and safety


The IFC performance standard 4-community health safety and security (2012) is to be used as best
practice. Below are the mandatory requirements in the project.

The project will evaluate (and record) the risks and impacts to the health and safety of the affected
community during the project life-cycle.

5.5.1 Road safety


The project is governed by a Traffic Management Plan. The project will limit the use of heavy
machinery. The transport routes between Monrovia and to the site will be subject to transportation
control. Project personnel will direct the project related traffic as well as the non-project related
vehicles to make sure that transportation is safe for all.

The speed limit for all project related traffic on site will be 20 km/h. All project employees (including
subcontractors) are receiving safe driving training.

5.5.2 Emergency preparedness and response


The project will involve the local community in the emergency preparedness and response plan (5.4) and
inform them about how the project will respond if an emergency event should occur.

Communities located near the TL route shall be made aware of what to do in the event of discovering a
broken powerline and in the event of a fire.

Safety signage shall be placed on pylons near communities, farming areas and graveyard sites warning of
the dangers associated with high-lift/excavation work under powerlines as well as provide emergency
contact details.

5.5.3 Grievance mechanism for affected communities


The Gigawatt Global’s Community Liaison Officer (CLO) will interact with local, regional and national
stakeholders concerning the project. Any grievances will be reported straight to the CLO in person, by
phone or in written form. All grievances and response actions must be logged in a Grievance Log.

The local community, neighbours and other relevant stakeholders will be invited to an information meeting
as described in the Stakeholder Engagement Plan. For details about the grievance mechanism see section
5.6.3.

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5.6 Security
The security concept for the solar PV site consists of the following:

• Outer perimeter security fence.


• Access control.
• The security staff will secure the site entrance and monitor all passage through the gates. No
unauthorized entrance/exit will be allowed. Site manager will keep lists of all visitors. Visitors
attempting to enter will have to be approved and registered with the Site Manager if the visit is
not communicated to site security beforehand. For more details see the H&S Plan.
• The security staff will be present at site continuously (24/7) and will patrol the site at all times. The
minimum requirement is a manned entrance gate and patrolling capabilities at all times.
• The site will have lights at the gates and along the main access road.
• The site will be equipped with surveillance cameras (CCTV) with pan/tilt functionality.

Security regulations are to be followed at all times. No security personnel will be allowed to bear arms on site.

Gigawatt Global will implement as security screening procedure.

The security staff will collaborate with local law enforcement. A coordination meeting will be held during the
early parts of the building phase to align the security staff procedures and inform about the measures being
put in place. The EPC HSE Officer will train all security personnel in the environmental and social
requirements attaining to their work.

The security personnel on site is required to be trained according to local requirements and experienced in
securing large land areas like the solar plant.

All workers on site will wear identification tags or uniforms to clearly document their belonging to the project.
This includes all visitors and guests.

During the initial civil works the security staff’s primary objective is to manage the entry to site and stop any
un-authorized entry. The security staff is also authorized to reject entry to anyone under the age of 18, or
under the influence of drugs or alcohol. The staff is an 8 man crew on 12 hour shifts leaving 4 people on site at
all times. 1 by the main gate and 3 patrolling the perimeter.

The site entrances will have a register where all visitors, workers and others entering the site is to be
registered. The name of each visitor has to be submitted to the security staff when the site opens in the
morning. If no record is found the guest/visitor/worker is not to be allowed on site. The EPC Site- and Project
Manager is authorized to register new visitors. Any un-scheduled visitor has to be registered before entry is
allowed.

5.6.1 Disturbance in electrical supply from the plant


To avoid any disturbance in the electrical supply from the plant the site will need adequate protection from
theft, sabotage, terrorism or other external threats. This protection will be consisting of an outer fence and a
balanced combination of other counter measures such as electrical fence and/or guards.

5.6.2 Risk of injury


The site consists of high voltage systems and mechanical structures. In addition to the above-mentioned
protection from external threats the plant will have internal signs, fencing and other measures to avoid anyone
on the site, rightfully or not, to be harmed by the site installations.

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5.6.3 Theft
The site consists of a large number of solar panels easily adaptable to domestic use or easily marketable in
second-hand market. The site also consists of precious materials like copper cables. The security concept will
protect the site from theft by having an outer fence with climb over protection and 24/7 security on site.

5.7 Emergency preparedness and response


The project has developed a plan for handling emergencies that may occur during the construction phase. All
people being present at the site shall be informed of about the Emergency Response Plan when entering the
site.

Any incidents are tracked in the project’s Incident registration system by the EPC HSE Officer, the EPC Site Manager
or the EPC Project Manager.

Gigawatt Global will assess the capacity/capability of local emergency services providers and ensure contingency
plans are in place where required.

A detailed list of emergency numbers must be obtained and will be prominently posted at the site.

The following sections document the main procedures during the construction and operations of the solar PV
plant, however a more detailed account will need to be provided in the H&S Plan.

Emergency preparedness and response during Operation


The site presence at the time of operation will be low. An Emergency Coordinator (EC) will be assigned during
the operational phase. The EC will have full authority and responsibility to act according to the emergency
preparedness plan stipulated below.

5.7.1 Roles and responsibilities on site during an emergency


The following roles are identified as important during any type of emergency for the construction phase.

Role Name Main responsibility Company


Project Manager TBD Full authority over site TBD
Site Manager TBD Full authority over site TBD
Security Manager TBD Site security, including TBD
control of site entrance
Community Liaison Officer TBD Deal with issues relating TBD
to the local communities
Emergency Coordinator TBD Coordination of TBD
evacuation, head count
and any actions taken
during emergencies
HSE Manager TBD Monitor and control TBD
HSE related issues
HSE Officer TBD Monitor and control TBD
HSE related issues

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Role Name Main responsibility Company


Emergency Committee EPC Project Address concerns and TBD
EPC Manager Site issues
EPC Manager
EPC Security Investigation of
Manager emergency incidents
EPC Emergency
Coordinator HSE Review and revision
Manager of emergency
GWG HSE Manager response
plans/procedures

5.7.2 Fire
In case of fire the person detecting a fire must inform and let other personnel evacuate the area immediately
following the evacuation routes to the demarcated assembly point and sound the alarm.

The EPC HSE Manager and Site Manager must be notified immediately and, if it is safe to do so, try to fight
the fire with the nearest relevant fire extinguisher.

At the assembly point(s):


• Take a roll call
• Should an employee or visitor be found missing during the roll call the emergency coordinator must
immediately search for him.
• Do not attempt to enter areas where there is an accumulation of smoke or possible accumulation of
gasses.
• Assist and apply first aid to any injured.
• Notify the clinic sister and call out the ambulance if any injuries are discovered.

During evacuation the EPC Site Manager or his delegate must contact the fire brigade (if required) and
supply the following information:

• Exact location of fire;


• Type of fire and material involved; and
• Magnitude of fire.

The EPC Site Manager will decide if a full evacuation of the site is necessary, and if a systematic shut down of
the site is recommended.

The security personnel are to give the fire brigade immediate access to the site at arrival.

All reported fires are to be reported and recorded in the Issue log. All fires are to be investigated by Gigawatt
Global, the EPC Contractor and/or local fire department, and mitigating actions to be in place before the site
returns to normal operations.

5.7.3 Natural disaster


Natural disaster includes but not limited to the following:

• Earthquakes
• Tornados
• Storms & Lightning
• Floods

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These are acts of providence and cannot be prevented, although impact of such acts may be reduced.

The nature and extent of the natural disaster will dictate the appropriate actions, but the following general
rules may apply:

• The EPC Site Manager, in consultation with EPC Project Manager must take immediate control and
decide on the action required, inter alia, a complete evacuation of the entire area and sending
personnel home may be needed.
• In case of a thunder storm, close all windows, and isolate / switch off all non-essential electrical
appliances.

As soon as possible after the natural disaster the emergency committee must assess firstly injury to
personnel and then damage to buildings and equipment. The EPC Site Manager or his deputy after the
assessment must declare the area safe and allow personnel to return to work.

5.7.4 Labour unrest (strikes and riots)


When any confrontation exists, the EPC Site Manager must attempt to contain the confrontation to the
affected area and immediately contact Gigawatt Global’s Community Liaison Officer (CLO), who is responsible
for dealing with any issues related to local labour. The EPC Site Manager must obtain a list of the grievances or
reason for the labour unrest. The services of the Gigawatt Global HSE Manager may be requested when
required.

The EPC Site Manager will on receipt of any grievance(s) or demand(s) from employees consult with the
emergency committee and decide on what action to take. The EPC Site Manager, in close coordination with
the CLO will have the full authority to:
• Communicate with any aggrieved person(s); and
• Liaise with employee representative or trade union.

The EPC Site Manager may, at his discretion, also inform the Police Services and ask them to remain at a
distance and monitor proceedings.

The EPC Site Manager will discuss the grievance(s) and attempt to resolve the issue(s) whilst the employees
return to their working areas. If this cannot be done project management support may be requested.

5.7.5 Terrorism and terrorist attacks


In the case of a terrorist attack the following procedure must be followed:

• The EPC Site Manager or his nominee must inform the Police Services and National Security immediately.
• If possible, the Safety personnel must assist with the evacuation of personnel from the affected area
and assist the injured.
• If not possible to evacuate; personnel to be informed to remain calm and find cover.
• All employees to co-operate and not try to attack any perpetrator.
• The Police Services/National Security to take charge on arrival.
• The EPC Site Manager in consultation with the Police Services, to declare the site safe and allow
personnel to return to work.

5.7.6 Bomb threat


The operator receiving the call/notice must:

• Stay calm and not confront the caller.


• Note the time of the call.
• Try to recognize the voice (aggrieved or dismissed employee).
• Listen for any background noises.
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• Should call identification/tracing be available, note the number and inform security.
• Calmly ask where the bomb may be planted.
• Notify the EPC Site Manage immediately.

The Site Manager must:

• Evacuate all the personnel immediately.


• Get the Police to conduct a plant search and take control of situation.
• Demarcate any area containing suspect parcels with “black and yellow” barrier tape.
• Police Services to defuse or remove any suspect parcels.
• The EPC Site Manager, in consultation with the Police Services, will declare the affected area
safe and allow employees to return to work.

5.7.7 Explosions
In case of an explosion, the area must be evacuated immediately and the EPC Site Manager to be
notified immediately by doing the following:

• Sound the alarm.


• All personnel to evacuate the area immediately and follow the escape to the demarcated assembly
point.
• Take roll call.
• Assist and apply first aid to any injured. Do not attempt to enter areas where there is accumulation of
smoke or possible accumulation of gasses.
• Notify the emergency response services (if required).

When the situation is under control the EPC Site Manager and EPC HSE Officer to investigate and ensure
that the area is safe and no additional explosions will occur.

The Site Manager must ensure to demarcate the area with yellow and black barrier tape and ensure that
nobody enters the area and that no evidence is removed from the scene.

The Site Manager or his delegate must report the explosion through his chain of command to the Local
Authorities. Operations will only resume after consultation with the Local Authorities and permission granted
by them.

The emergency committee to launch a full investigation immediately and implement an action plan.

5.7.8 Road transport incidents


Any contractor involved in a vehicle accident related to the project must report this to the EPC Site Manager (if able
to do so). A card with contact details of project personnel to contact in the event of a vehicle accident must be
maintained in vehicles.

The EPC Site Manager must immediately commence an investigation. Depending on the nature of injuries,
the injured personnel (and any other persons involved) must be treated by medical emergency service
providers/paramedics or suitably qualified first aid staff.

A full investigation must be held with the relevant Traffic Services (and if required, Police Service)
should the accident occur on a public road.

5.8 Labour
The project will target to use local workers for a significant part of the work however influx of migrant
workers is possible.
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The final number of people to be employed is likely to be up to 200 people during peak construction
activities, with an estimated 100 unskilled and semi-skilled jobs likely to be available. However, the number
of people employed at one time may vary as different contracts and subcontracts are completed on-site.
Fewer staff will be required during the operations and maintenance phase, with potential employment
numbers being up to 20 people of which approximately 6 people will be on-site simultaneously.

All relevant (unskilled) labour positions will be posted by the EPC and its subcontractors both at the site and
nearby community centres. The goal is to employ at least 30% women.

Influx management
Though the advertisement is focused on getting local applicants, migrant workers will not be discriminated
against.

The project site will provide drinking water for its workers and in-migrated people. Water will be obtained
from a borehole located on Crawford Farm. There will be waste baskets stationed outside the project fence
to collect the solid waste of the in-migrated people. This waste will be disposed of off-site in accordance
with a waste management plan.

Incoming and outgoing vehicles will be given instructions to be extra observant with potential people
gathering around the project site. Similarly, signage along the road for additional safety will be installed, as
well as informing the local population of the additional traffic expected.

The site security will verify that no unauthorized people will remain on the project property after work
hours.

People selling their wares will be allowed to remain in the vicinity of the project as long as they adhere to
the general guidelines of the project security personnel, safety standards, and local law.

The site security personnel will estimate the number of migrant workers camping near the site and log the
amount in order to discuss the influx situation with the Project management team on site. The security
team will also interview migrant workers to find out if there are any particular issues. The project
management will encourage good conduct however, will not hesitate to call in the local police should legal
problems arise.

Worker accommodation for skilled labour recruited from beyond the local community will be housed in the
greater Monrovia area and will be conveyed to the construction site and back every day.

5.9 Workers’ rights


The IFC performance standard 2 labour and working conditions (January 2012) is to be used as a reference
for best practice. The projects’ mandatory requirements are listed below. More details will be included in
the Workers’ Management Plan.

5.9.1 Working conditions and terms of employment


The project will define Recruitment Procedures in the Workers’ Management Plan. These procedures will be
followed by all subcontractors used for the project. The working conditions, such as working hours are to
comply with local laws. All workers shall have identified terms of employment, including expected working
hours through valid written employment contracts. The following requirements are in place in addition to
local legislation

• A minimum wage of 15 Liberian Dollars per hour for unskilled labour.


• All employees shall be informed of the expected duration of their employment.
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• Any deviations to the planned employment shall have a 3 day’s notice period.
• All payments are to be done bi-weekly.
• All payments are to be completed the last day of employment (no worker leave site with unresolved
payments at the final day of work, regardless of reason for the work to end).
• All subcontractors must report to the EPC Site Manager confirming that payments to all staff have been
made before any funds are released to the subcontractor for their work.
• Skilled workers and subcontractors will be housed by the project in the greater Monrovia area. The
housing option is for up to 50 people.

5.9.2 Non-discrimination and equal opportunity


The project will not make employment decisions on the basis of personal characteristics unrelated to inherent
job requirements. The project will base the employment relationship on the principle of equal opportunity and
fair treatment and will not discriminate with respect to any aspects of the employment relationship.
The project is aiming for the 30% inclusion of women in the manual labour workforce.
The project will take measures to prevent and address harassment, intimidation, and/or exploitation, especially
in regard to women. The principles of non-discrimination apply to migrant workers.
The project has zero tolerance for violence in general, in and around the project site, and especially to women.
In case of such violence a grievance will be filed, and the matter will be dealt with in a manner that constitutes
the most respect to the victim, yet shows that there is no tolerance for this type of action in conjunction with
the project. The police will be contacted for any offence and if the perpetrator of the violence is employed on
the project site it will result in immediate dismissal. All workers employed by the project will be requested to
report on any suspicions of sexual exploitation as a result of the project and any such reports will be
investigated in depth.

5.9.3 Grievance mechanism


The grievance mechanism applies to project stakeholders in general and site workers in particular. It
formalizes the mechanisms to raise workplace and local community concerns. All employees and community
leaders shall be informed of this mechanism (employees to be informed at the time of recruitment or no later
than before start of any work on site, and community leaders to be informed prior to construction
commencing).

An anonymous communication channel with a “suggestion box” will be established on site where workers can
make improvement suggestions.

A notice board with details of how community grievance can be submitted will be placed at the access
entrance gate.

The following e-mail address has been established: Liberia.solar@gigawattglobal.com – for all concerns from
both workers and local community. In addition, grievance boxes will be placed onsite and outside the main
gate. These boxes will also show the SMS/WhastApp contact number for the CLO.

The mechanism involves the Project site management and will address issues and concerns promptly. All
issues raised will be addressed using a transparent process that provides timely feedback where applicable,
without retribution.

The general procedure for the grievance mechanism for both workers and local community is described below.

• A concern is raised, either anonymous or with known name and source. All grievances raised are
tracked in the projects “Grievance Log” by the CLO. The EPC Project Manager is ultimately
responsible for all issues and grievances, but the resolution of a grievance may be delegated to the
EPC Site Manager, the CLO or the EPC HSE Officer as required.
• Any concern indicating danger for human life, violence, including gender-based violence,
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significant environmental damage or corruption will demand an immediate ceasing of relevant


activities until the grievance has been investigated.
• All grievance will be evaluated and corresponding actions to be agreed within 72 hours of the
grievance being made known to the CLO, the EPC Project Manager, the EPC Site Manager or the
EPC HSE Officer.
• If the source of the grievance is known the agreed action is communicated to the source. For all
community related grievances, the agreed action is added to any planned agenda for information
meetings or report. For all workers related issues the agreed action is communicated through the
supplier’s foreman to all relevant personnel at the earliest convenience.
• Once the remedy for a grievance is agreed on, action is taken, and the grievance issue is closed
and final notification is given if the source is known.
• Any concern related to possible corruption, significant security or safety breaches or other
potential major concerns gives anyone on site the right and duty to stop work and report to the
EPC Site Manager.

Actions to voiced concerns or issues are made according to this document and in accordance to the
communication and stakeholder plan in the project charter. All concerns and corresponding actions are
included in reporting to management as defined in the project charter and relevant reporting templates.

5.9.4 Child labour


The project will not employ children in any manner that is economically exploitative or is likely to be hazardous
or to interfere with the child’s education, or to be harmful to the child in any way. National laws related to
employment of minors are to be followed.

No person under the age of 18 is to be allowed to be working on the site.

5.9.5 Forced labour


The Project will not employ forced labour, which consists of any work or service not voluntarily performed
that is exacted from an individual under threat of force or penalty. This covers any kind of involuntary or
compulsory labour, such as indentured labour, bonded labour, or similar labour-contracting arrangements.

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6 ISSUES LOG
Any incidents, accidents, non-compliance and grievance breaching this document are to be registered by
reporting to the EPC Site Manager, the EPC HSE Officer and/or the Community Liaison Officer, and registered
in the project accident log/grievance log.

7 ROLES AND RESPONSIBILITIES

An EPC Contractor will be hired by Gigawatt Global to construct and commission the solar plant and the
transmission line and initially (at least the first 5 years) to maintain and operate the solar plant. In this role
the EPC Contractor is responsible for the implementation, maintenance, monitoring and reporting of the
ESMP and all associated activities outlined in the management plans attached and connected to it.

Gigawatt Global (GWG), the client, is ultimately responsible for the solar PV plant and the building of the
transmission line, though the implementation will be passed on to the EPC Contractor. As such Gigawatt
Global’s Health, Safety and Environmental (HSE) manager and a Community Liaison Officer (CLO) will work in
close collaboration with the EPC Contractor to achieve the project’s goal regarding E&S issues during the
construction phase.

The flow chart below is a graphical representation of the roles and responsibilities related to the
implementation of the ESMS/ESMP.

7.1 Roles and responsibilities during construction

EPC Project Manager:


Is responsible for assuring that the EPC HSE manager and EPC HSE Officer have all the resource, information
and authority to implement the health, safety and environmental procedures described in the ESMP and its
attachments and ensuring that inspections and audits are carried out as required. He is also required to

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ensuring that the offices and work sites are laid out and maintained to secure site safety and clear entrance
/ exit / emergency routes and that sanitation facilities are well maintained. The EPC Project Manager’s
primary workplace will be on-site.

EPC HSE Manager:


Is responsible for the implementation of the health, safety and environmental procedures described in the
ESMP and its attachments and for directly managing the EPC HSE Officer. He is also generally responsible for
overseeing, managing and allocating adequate resources for the implementation of the H&S management
system and to analyse all reports from the EPC HSE Officer/ EPC Site manager or EPC Project Manager with
regards to the ESMP. He will be overseeing internal and external H&S audits and inspections and supervise
the analysis of the results of such audits and inspections, including, but not limited to, non-conformities and
related corrective actions, H&S accidents/incidents, labour unrest and work stoppages, grievances from
local communities and secondary stakeholders and identifying H&S related risks and threats, as well as
opportunities for improvement. He will finalise the monthly reports regarding E&S with data from EPC HSE
Officer. The EPC HSE Manager’s primary workplace will be off-site.

Owners HSE Manager (Gigawatt Global)


Is responsible for developing the ESMP and its sub management plans, in close collaboration with the EPC
Contractor and external E&S experts. These plans must be in compliance with IFC Performance Standards
and aimed to minimize the risk for accidents, negative environmental impacts, labour unrest, conflicts with
the surrounding communities and other stakeholders. She is also responsible for continually update and
improve the plans together with the EPC HSE Manager and external E&S experts for optimal project
implementation. She will also organize and participate in unannounced audits of the construction site, with
or without the presence of external E&S experts. The HSE Manager’s primary workplace will be off-site.

EPC Site Manager:


Is responsible to take any action required on the site in case of any HSE issues. He will ensure that personal
protective equipment is available on site at all times for all people present and to work in close collaboration
with the EPC HSE Officer to make sure the project site is safe and well managed with respect to H&S issues.
The EPC Site Manager’s primary work place is on site.

EPC HSE Officer:


Is responsible to implement, with support from the EPC Site Manager, the Health and Safety procedures
described in the ESMP and its attachments on the construction site. This will include:
- The analysis of the documentation of all subcontractors and carrying out an inspection of the site and
subcontractor areas at least once a week. He will work in close collaboration with the person from the
subcontractor responsible for HSE.
- Lead the training sessions for subcontractors and their workers, suppliers and visitors that come on site.
- Log the information of the companies, workers and equipment / machinery present on site.
- Managing non-conformities, perform accident/incident reporting and upload the reports to the E&S
database and initiating investigations into all accidents and incidents, and implementing corrective
action.
- Perform weekly site inspections including both the solar site and the transmission line and write weekly
reports.
- Provide all the data for the monthly reports.
The EPC HSE Officer’s primary workplace is on site.

EPC Security Manager:


Is responsible for screening and logging all people entering the site and to prevent any unauthorized
personnel to come on site. The EPC Security manager is responsible for preventing any incidents of
attempted break-in or vandalizing of property, most notify the site manager of any such incidents and must
call for law enforcement, also in case of unruly or dangerous behaviour has been detected by people close
to the site perimeter. The security personnel on site is not armed. The EPC Security manager’s primary work
place is off site, however he/she will always assign a site security manager for each shift on site.

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Community Liaison Officer (Gigawatt Global):
Is responsible for overseeing the regular interaction between the affected communities’ and other
stakeholders off-site and will manage any grievances reported from these stakeholders. He is also
responsible for monitoring the treatment and behaviour of all local workers, independent of which
subcontractor has hired them, to make sure that there is a fare process for hiring people and that the
request of the Project Owner to have an appropriate mix of men and women is maintained and that
worker’s get paid in accordance to their contracts. He will be receiving, documenting and reporting of all
grievances and is responsible to take the appropriate action to address the grievances and work with the
EPC HSE Managers to change procedures etc to minimize grievances in the future. In case of worker’s unrest
or similar threats the CLO will take all the measures locally to solve it and use external (preferably local) E&S
experts to reach the appropriate resolve. The Community Liaison Officer’s primary workplace is on site.

External E&S experts and monitors


During the active construction phase an Project Owner’s Engineer will be present on site, representing
Gigawatt Global. The Project Owner’s Engineer will be reporting monthly on the compliance with the ESMP
and its subplans and will report any issues directly to the Gigawatt Global HSE Manager. An E&S expert
representing the investors will make an unannounced audit of the construction site and will recommend to
the investors if additional external E&S audits are required.
The E&S expert will verify that the ESMP is effective and that the EPC Contractor is working in accordance to
it and its subplans and will work with the Owner’s HSE Manager, the HSE Manager and the HSE Officer to
review the results of the audit and recommend improvements. The Liberia Environmental Protection Agency
will also be monitoring the of the project and are expected to perform unplanned audits of the compliance
with the Environmental Certificate and ESMP.

Role/function Name E-mail


EPC Project Manager TBC TBC

Site Manager TBC TBC

EPC HSE Manager TBC TBC


EPC HSE Officer TBC TBC
Community Liaison TBC TBC
Officer
HSE Manager (Gigawatt Hanna Klein Hanna.helena.klein@gigawattglobal.com
Global)

7.2 Roles and responsibilities during operation


During operations the staffing on site is expected to be drastically reduced to one O&M engineer, two technicians
and one operator. For each shift one person will be appointed as the EPC Site Manager and will also have the role
of HSE officer during that shift with the authority and the requirement to follow all the requirements of this ESMP.

O&M HSE Manager:


Is responsible for the implementation of the health, safety and environmental procedures described in the
ESMP and its attachments and for directly managing the HSE Officer. He is also generally responsible for
overseeing, managing and allocating adequate resources for the implementation of the H&S management
system and to analyse all reports from the HSE Officer/Site manager with regards to the ESMP. He will be
overseeing internal and external H&S audits and inspections and supervise the analysis of the results of such
audits and inspections, including, but not limited to, non-conformities and related corrective actions, H&S
accidents/incidents, labour unrest and work stoppages, grievances from local communities and secondary
stakeholders and identifying H&S related risks and threats, as well as opportunities for improvement. The
HSE Manager must finalise the semi-annual reports regarding E&S with data from the HSE Officer. The HSE
Manager’s primary work place will be off-site.

Owners HSE Manager (Gigawatt Global)

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Is responsible for developing the ESMP and its sub management plans. These plans needs to be in
compliance with IFC Performance Standards and aims to minimize the risk for accidents, negative
environmental impacts, labour unrest, conflicts with the surrounding communities and other stakeholders.
She is also responsible for continually updating and improving the plans as needed. She will also organize
and participate in unannounced audits of the solar site, with or without the presence of External E&S
experts. The Owner’s HSE Manager’s primary work place will be off-site.

O&M HSE Officer:


The O&M engineer will be appointed as HSE Officer for the operational phase, however, if he is not present
on site during a particular shift, he will delegate this role of responsibility temporarily to the Site Manager of
that shift. The HSE Officer is responsible to implement the Health and Safety procedures and all other
Management Plans described in the ESMP and its attachments on the site during operation. This will
include:
- The analysis of the documentation of all subcontractors and carrying out an inspection of the site at
least once a month.
- Lead the training sessions for subcontractors and their workers, suppliers and visitors that come on site.
- Log the information of the companies, workers and equipment / machinery present on site.
- Managing non-conformities, perform accident/incident reporting and upload the reports to the E&S
database and initiating investigations into all accidents and incidents, and implementing corrective
action.
- Provide all the data for the monthly reports.
The HSE Officer’s primary work place is on site.

O&M Site Manager:


Is responsible to take any action required on the site in case of any HSE issues. He will ensure that personal
protective equipment is available on site at all times for all people present and to work in close collaboration
with the HSE Officer to make sure the project site is safe and well managed with respect to H&S issues. The
Site manager’s primary work place is on site.

O&M Security Manager:


Is responsible for screening and logging all people entering the site and to prevent any unauthorised
personnel to come on site. The Security Manager is responsible for preventing any incidents of attempted
break-in or vandalising of property, most notify the site manager of any such incidents and must call for law
enforcement, also in case of unruly or dangerous behaviour has been detected by people close to the site
perimeter. The security personnel on site will not be armed. The Security Manager’s primary work place is
off-site, however he/she will always assign a site security manager for each shift on site.

Community Liaison Officer (Gigawatt Global):


Is responsible for overseeing the regular interaction between the affected communities’ and other
stakeholders off-site and will manage any grievances reported from these stakeholders. He will be receiving,
documenting and reporting of all grievances and is responsible to take the appropriate action to address the
grievances and work with the HSE Managers to change/improve procedures to minimize grievances during
operations. The Community Liaison officer’s primary work place is off-site during the operational phase and
the main route of communicating grievances will be through email, the grievance boxes and a
SMS/WhatsApp contact number. The CLO will meet with the community semi-annually during the first two
years of operation and after that in accordance to the perceived needs from both sides.

External E&S experts and monitors


An Owners Engineer will be hired to monitor the project during the operational phase. Compliance with the ESMP
will be reported in the yearly Operations Monitoring Report from the Owner’s Engineer.
External E&S experts will be called in during specific events and when necessary. Their main responsibly will
be to perform unannounced site audits to verify that the ESMP is effective and that the O&M provider is
working in accordance to it (and its subplans) and to work with the Owner’s HSE Manager, the O&M HSE
Manager and the O&M HSE Officer to review the results of the audit and recommend improvements. The
Liberia Environmental Protection Agency will also be monitoring the of the project and are expected to
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perform unplanned audits of the compliance with the Environmental Certificate and ESMP.

8 MONITORING AND CONTROL PLAN

The environmental and social impacts that the project will have will be monitored continuously.

The issues and grievances are continuously logged and uploaded to shared drives for all project parties to see.

During the construction phase weekly site reports will be created and weekly meetings held to discuss the
implementation and compliance of the ESMP. A monthly report including key performance indicators will be
issued by EPC HSE Manager and monthly meeting between the HSE managers will be held to discuss the status
and potential improvements to the ESMP. As a result of these monthly meetings the management plans, logs
or forms will be updated.

Gigawatt Global’s and EPC/O&M HSE managers will perform planned and un-planned audits of the compliance
with the ESMS/ESMP, separate or together.

An external E&S Expert will be engaged in monitoring as required.

The project has the following monitoring and control plan related to environmental and social impacts. This
plan will be revised for the operational phase (at least 6 months prior to operations commencing).

The projects monitoring and control plan is executed by the HSE Officer and reported as defined in the project
charter.

ID Measure Frequency Responsible Target Measured Budget


1 Noise level during installation of 2 times GWG 50 dB Noise TBC
ramming poles (measured at south during monitoring
east corner of site) construction
2 Noise level during test of 2 times first 3 GWG 35 dB Noise TBC
operations months of O&M monitoring
operations
3 Water quality 1 GWG WHO Samples TBC
(before start of solar PV installation) (more Drinking
frequently if water
used as quality
drinking water) standards

Presence of
contaminati
on
4 Water quality 1 GWG Presence of Samples TBC
(after project completion) contaminati
on
compared to
baseline
5 Local employment, civil work (% of Statistics will Civil Works 90% Labour OpEx
workforce from Liberia) be logged daily supplier statistics
6 Local employment, O&M phase (% 1 O&M 100% Labour OpEx
of workforce from Liberia) statistics
7 HSE reporting (accidents, incidents Continuous HSE 0 HSE Reports OpEx
etc) Manager

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ID Measure Frequency Responsible Target Measured Budget
8 Community grievance; number of Continuous CLO 0 Grievance OpEx
unresolved complaints at project records
closure
9 Meeting with local administration Start of CLO 1 Meeting OpEx
on emergency procedures constru minutes
ction
10 Human fatalities or serious injuries Continuous Project 0 HSE Reports OpEx
Manager

11 Workers Grievance: number of Continuous Site 100% Grievance OpEx


resolved concerns (count concerns Manager records
resolved)
12 Corruption discovered in the Continuous Project 0 TBC OpEx
project Manager

13 Erosion control Weekly HSE No Site OpEx


Manager movement inspections
beyond site
boundary
14 Security: incidents and/or security Continuous Site 0 Security OpEx
breaches causing damage to site Manager reports
installation or economic loss (theft,
vandalism etc) (count incidents at
project closure)
15 Measure water level of Weekly and HSE <50% Site OpEx
retention ponds (execution) after rainfall Manager inspections
>20mm
16 Alien invasive species Monthly HSE 0 Site TBC
Manager inspections

17 Installed capacity Once GWG 20 MWp Data to come OpEx


from
commissioning
report
18 Operational capacity Continuously O&M 20 MWp Data from OpEx
measured, minus the O&M report
reported predicted including
annually yearly reporting
degradation problems and
actions taken
19 Electricity sold Continuously O&M Monthly Data from OpEx
measured, predictions invoice to LEC
reported presented including
monthly reporting
the month
problems and
before.
actions taken
20 Electricity generated Continuously O&M Monthly Data from OpEx
measured, predictions O&M report
reported presented including
monthly reporting
the month
problems and
before
actions taken
(should be
the same
as
electricity
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ID Measure Frequency Responsible Target Measured Budget
sold since
the PPA is a
contact for
take-or-
pay)
21 GHG emissions during Reported O&M <25% of Data from EPC OpEx
construction and operation monthly generation and O&M
based on fuel consumption reports
Tons
CO2/month
22 Number of solar PV panels Reported O&M All faulty Waste OpEx
recycled monthly panels are management
recycled service
provider
23 Number of recycled electronic Reported O&M All faulty Waste OpEx
equipment besides panels. monthly equipment management
is recycled service
provider
24 Number of jobs: specify %per Reported O&M 30% Based on site OpEx
monthly during
gender and % of low skilled vs women access records
construction and contracts
high skilled and annually
for high skilled
during
operation labour
25 Number of grievances reported Reported CLO <5 Grievance OpEx
from the community monthly records

26 Number of grievances from the Reported CLO 100% On-line OpEx


community addressed and monthly grievance
closed record

9 ATTACHEMENTS
The following table summarizes the attached documents, and their status in the project

Document Description Owner Status


Gigawatt Global Health, Safety and Describes the GWG policy including GWG Final
Environmental Policy handling contractors
Gigawatt Global’s HR policy Describes the GWG human resource GWG Final
policy
COVID-19 Onsite Routines in Liberia sets out actions on how to deal with all GWG Draft
issues related to the pandemic
Worker’s Management Plan Addresses the risks and procedures GWG Draft
related to workers engaged for
construction
Stakeholder Engagement Plan Communication and consultation GWG Final
process for all stakeholder
External Grievance Mechanism To manage external grievances GWG Final

THIS DOCUMENT IS SUBJECT TO CHANGE CONTROL Page 37


HEALTH, SAFETY & ENVIRONMENTAL POLICY

INTRODUCTION/OBJECTIVE:

Gigawatt Global is committed to providing a safe, healthy, and sound environment for its employees,
contractors, and subcontractors inside its offices and on its building sites. We are committed to
demonstrate safety and environmental leadership by demanding the highest standards of our
contractors, subcontractors, and service agents. We adhere to all applicable laws and regulations in
every jurisdiction in which we work. Moreover, we continually strive to improve our safety and
environmental performance.

RESPONSIBILITIES:

The company management, led by the CEO (Chief Executive Officer) and the CCO (Chief Compliance
Officer), is responsible for providing and maintaining:

• a mindset and culture regarding the importance of personal safety and environmental health.

• a safe working environment in which any machinery and equipment comply with occupational
health and safety (OH&S) standards.

• a safe system of work.

• the highest standard of personal safety and concern for the environmental health of our
Engineering Procurement and Construction (EPC) companies.

• safe and environmentally friendly building sites.

• information, instruction, training, and supervision needed to make sure that all workers are
safe from injury and risk to their health.

• continuous information and communication for the adoption of a safety culture.

• appoint a health and safety officer for each project

• safety guidelines for all visitors to our offices and construction sites.

• a commitment to consult and co-operate with workers in all matters relating to health and
safety at the workplace.

• a full compliance with the UN Environment Programme’ s (UNEP) International


Environmental Law as well as any regional environmental laws.

Management must preform a yearly review of all health and safety policies to verify that OH&S
principles are known and properly understood by everyone and that all actions satisfy OH&S
requirements.

Gigawatt Global Coöperatief U.A. Kingsforweg 151 1043 GR Amsterdam ● The Netherlands ● Tel: +31.20.808.0756
www.gigawattglobal.com
Workers are responsible for.

• ensuring their personal health and safety, and that of others in the workplace.

• complying with all safety and environmental polices (such as work procedures, procedures of
wearing protective equipment etc.) given by management.

• preventing misuse or interference with any procedures or equipment provided to protect health
and provide safety.

• reporting all accidents and incidents on the job immediately, no matter how trivial.

• reporting all known or observed hazards to their supervisor or manager.

EPC RELATIONSHIP:

Gigawatt Global will require that any EPC working for the company will:

• take all reasonable steps to ensure that they comply with the highest safety, health, and
environmental standards, the national and international OH&S laws and regulations, and all
other applicable laws and regulations.

• ensure the supply of all necessary labor, material, plant, equipment, and transport required on
site to complete the construction within all safety and environmental guidelines of Gigawatt
Global.

• Always have a safety and health officer on site to verify on the ground that OH&S principles
are known and properly understood by everyone and that all actions satisfy OH&S
requirements.

• ensure that they have a letter of good standing on file.

• adopt a set of standards and rules on site for the entire building process agreed to by Gigawatt
Global in advance.

• have a zero-tolerance policy regarding accidents.

• ensure that all unsafe practices and incidents are investigated and reported and take all
necessary steps to prevent any recurrence.

• have on file readily available health and safety rules.

• maintain and keep health and safety records to demonstrate compliance with the Occupational
Health & Safety Act of 1993.

• ensure that sub-contractors comply with all relevant and applicable health, safety, and
environmental laws.

• ensure that sub-contractors stop any construction work that is not conducted in accordance
with the predefined health and safety regulations.

• inform the sub-contractors of the health and safety plan.

Gigawatt Global Coöperatief U.A. Kingsfordweg 151 1043 GR Amsterdam ● The Netherlands ●
www.gigawattglobal.com
• take all reasonable steps to ensure that the health and safety plan is fully implemented by the
sub-contractor.

• maintain full compliance with the UN Environment Programme’ s (UNEP) International


Environmental Law as well as any regional environmental laws.

TRAINING AND HAZARD IDENTIFICATION

Gigawatt Global is committed to developing fundamental principles of workplace safety and health.
We hope to ensure that these data-based principles will be conveyed to employees in a program that
develops a learning environment that will develop a culture of health, responsibility, and environmental
safety. Gigawatt Global will:

• initiate an annual updated health, safety, and hazard identification program.

• provide a list of site-specific hazards and known safety risks.

• ensure that all visitors, employees, and sub-contractors undergo a site-specific health and
safety induction training session.

• inform all employees and sub-contractors of the location of all first-aid and CPR equipment.

• provide all new employees with an introduction to the company’s health, safety, and
environmental policy.

• communicate, inform, and train all workers regarding the risks and hazards of a particular site
prior to a site visit.

• record attendance of all site visits.

SITE ACCESS

Gigawatt Global will ensure that all sites that it develops will:

• monitor and control access for all workers and visitors.

• keep a list of all visitors.

• maintain a safe environment.

• develop and maintain an area free of trespassers.

• provide for the overall security of the area.

• ensure that the area it controls will not damage the surrounding public and private properties.

EMERGENCY PROCEDURES

Emergency procedures will be posted and/or communicated to all employees and in all our sites and
offices.

Gigawatt Global Coöperatief U.A. Kingsfordweg 151 1043 GR Amsterdam ● The Netherlands ●
www.gigawattglobal.com
MISCELLANEOUS CONCERNS AND PROCEDURES

Gigawatt Global will require its site managers, EPC, or sub-contractors to:

• have fire precaution procedures.

• enforce the prohibition against alcohol, drugs, and weapons on sites.

• respond properly to various weather conditions.

• provide site security and an anti-terrorist plan where appropriate.

• form a site safety committee where appropriate.

• have always on-site a first aid kit and a medical response plan.

• ensure that workers are provided the necessary protective equipment and clothing.

Gigawatt Global Coöperatief U.A. Kingsfordweg 151 1043 GR Amsterdam ● The Netherlands ●
www.gigawattglobal.com
Gigawatt Global/

Energiya Global

Human Resources
Policy
Our HR Policies cannot anticipate every
situation or answer every question about
This policy encompasses guidelines for employment.
efficient and effective Human Resource
Management. The policy is based on the This policy is not an employment contract
company’s values and goals. and is not intended to create contractual
Gigawatt/Energiya Global is committed to obligations of any kind.
achieving its business objectives through This handbook is intended as a guide only.
its people. The Company accepts its
ethical and corporate social Should any HR policy conflict with
responsibilities. It recognizes its obligation applicable legislation, applicable
to conduct its activities in full knowledge legislation will prevail.
of, and in compliance with, the
requirements of applicable employment
legislation according to Israeli law
(‘Applicable Legislation’) and with regard
to any international laws. The Company
will achieve this by adopting a policy of
best practice in all people-management
procedures and policies.

This policy will be reviewed on a regular Yosef Abramowitz


basis and the Company reserves the right Chief Executive Officer & President
to change any of the provisions set out in
this document from time to time, as may
be required, or desirable.
Ethics

Gigawatt/Energiya Global fosters a non-


discriminatory work environment in which Sexual harassment is illegal and all
all individuals are treated with respect employees, officers, directors, and
and dignity. consultants of Gigawatt/Energiya Global
are prohibited from engaging in any form
Gigawatt/Energiya Global is an equal of sexually harassing behavior. Sexual
opportunity employer and does not harassment means unwelcome sexual
discriminate on the basis of race, color, conduct, and may include, but is not
religion, sex, national origin, age, sexual limited to, unwanted sexual advances,
orientation, disability, or any other unwanted touching, and suggestive
applicable category protected by anti- touching, language of a sexual nature,
discrimination laws. telling sexual jokes, innuendoes,
suggestions, suggestive looks, and
Gigawatt/Energiya Global is committed to
displaying sexually suggestive visual
actions and policies to ensure fair
materials.
employment, including equal treatment in
hiring, promotion, training, Employees, officers, and directors will
compensation, termination, and actively take part in preventing any sexual
corrective action. Gigawatt/Energiya harassment at the workplace and report
Global will not tolerate discrimination by any such behavior.
its employees or agents.
Gigawatt/Energiya Global has appointed
Gigawatt/Energiya Global will always Weldon Turner as company
aspire to a harassment-free workplace representative who should be addressed
and take steps to ensure the physical and with any sexual harassment complaints,
emotional wellbeing of employees. either written or verbal. In case of
unavailability or conflict of interest,
We are committed to a non-violent Gigawatt/Energiya Global appoints Shoshi
workplace where threatening,
Harari as his replacement.
intimidating, aggressive behavior, or
bullying toward fellow employees or In case of a complaint, Gigawatt/Energiya
others is not tolerated. Global will perform a swift and
appropriate investigation, inform the
employee of his/her legal rights, and take
action no later than seven days from the
time the complaint was received.
Safety

Gigawatt/Energiya Global is committed to


creating and maintaining a safe and
healthy work environment for its
employees.

Considering the COVID-19 pandemic,


Gigawatt/Energiya Global is adapting to
the situation in order to uphold the safety
and wellbeing of our employees and
those we work with.

Gigawatt/Energiya Global is mandating


measures suggested by relevant and
reputable public health organizations,
such as working remotely as much as
possible, social distancing, and wearing of
masks. These policies apply to both our
workers along with contractors and
others we interact with.

Gigawatt/Energiya Global reserves the


right to change or alter the protocols over
time according to the demands of the
pandemic, or of any future public health
emergency.

.
Hiring
All directors, employees, and consultants
Gigawatt/Energiya Global is aware that its at Gigawatt/Energiya Global shall have a
long-term success depends on its capacity written contract signed by its CEO and/or
to attract, retain, and develop employees COO.
who can ensure its continuing growth. To
ensure this, we seek people who are
honest, professional, and hard-working. Gigawatt/Energiya Global shall provide all
new employees with written terms of
Only relevant skills and experience will be his/her employment within 30 days of
considered in employing a person. No his/her first day of work.
consideration will be given to a
candidate's nationality, religion, origin, Salaries are negotiated and based on
race, gender, age, or disability. what is acceptable in the current market.

We have and will continue to work Employees shall sign the standard
through headhunters, professional company NDA and Code of Conduct.
organizations, and word of mouth. We Gigawatt/Energiya Global will always seek
wish to develop and maintain a to promote from within and intends to
reputation with such recruitment sources hire from our internship program.
as an employer of high repute.
Environment

We believe in sharing information and


competencies, to boost creativity. We Gigawatt/Energiya Global is committed to
have therefore incorporated a providing a healthy and safe workplace in
management style that is based on open compliance with the laws, rules, and
communication and dialogue. regulations of the State of Israel. We are
committed to making employees aware of
We have an open-door office policy. Every any and all safety and health issues and
employee has full access to management, policies that affect their jobs. Employees
with the right to an open conversation must immediately advise their managers
with superiors or colleagues. of any workplace-related injury or any
circumstance presenting a dangerous
We are committed to creating an
situation to them or other co-workers, so
environment that promotes the highest
that timely and appropriate corrective
degree of job performance. We trust the
action can be taken.
employees and consultants to be
responsible for the work they do.
Employment at Energiya Global

Monthly deductions from an employee’s Gigawatt/Energiya Global is proud to have


salary are set aside in accordance with employees that actively serve in reserve
local law and coordinated with the duty. An employee that has been
employee’s insurance agent. summoned for active reserve duty shall
inform his superior within reasonable
All non-executive (Non-Executive does time.
not include the following: CEO, COO, CFO,
Managing Director, and VP) workers shall All of Gigawatt/Energiya Global’s
be entitled to overtime pay in accordance information technology systems, including
with local law. This includes non- computers, email, internet and internet
executive employees that receive a access, telephones, cell phones, and voice
monthly based salary. mail are the exclusive property of
Gigawatt/Energiya Global and are to be
Gigawatt/Energiya Global shall document used primarily for business purposes
its employees’ monthly hours. unless permitted by its officers or unless
otherwise stated in the employee's or
The following benefits programs are
consultant's contract. These systems may
available to employees:
be used for incidental and reasonable
Holidays
personal usage provided that such use is
Vacation Days
kept at a minimum.
Sick leave
Maternity Leave Gigawatt/Energiya Global reserves the
right to monitor the use of its information
To take vacation, employees must request
technology systems.
advanced approval from management in
an orderly and documented fashion
within a reasonable timeframe.
Professional
Development

Gigawatt/Energiya Global encourages


personal and professional development Formal assessment should take place on a
and offers opportunities to progress for regular basis, preferably once a year. Its
those who desire to develop their purpose is to provide feedback on past
capabilities. We promote an environment performance and future potential as well
that welcomes new ideas and the as on other relevant aspects of a staff
willingness to follow up on them. member's work including the
development of his skills and
Employees are encouraged to attend
competencies.
professional conferences and seminars
that will enrich and improve relevant skills
and competencies. An employee shall
notify management of such a program
and receive permission to attend.
This is a trust- building opportunity to
learn about the ways the company and
employee both can do better.

Termination

It is not possible to list all the forms of


Unfortunately, termination of behavior that are considered
employment is an inevitable part of unacceptable in the workplace. The
personnel activity within any company, following are examples of infractions of
and many of the reasons for termination rules of conduct that may result in
are routine. disciplinary action, up to and including
termination of employment:
Since employment with the company is
based on mutual consent, both the
- Theft or inappropriate removal or
employee and the company have the right
possession of company property
to terminate employment at will, with or
- Possession, distribution, sale, transfer, or
without cause, at any time, in accordance
use of illegal drugs in the workplace
with the provisions of the employee’s
- Fighting or threatening violence in the
employment contract.
workplace
Employees shall receive their final pay in - Sexual or other unlawful harassment
accordance with laws applicable to such - Possession of dangerous or unauthorized
employee’s employment contract. materials, such as explosives or firearms,
in the workplace
An exit interview, if applicable, shall take - Excessive absenteeism or any absence
place following termination of an without notice
employment relationship. - Unauthorized disclosure of business
"secrets" or confidential information
- Misuse of company
funds/money/equipment/ property
- Lying
- Violation of the terms of the
employment or consulting agreement
Employee Acknowledgment Form
I, ________________________, hereby acknowledge that I have received a copy of
Gigawatt/Energiya Global’s employee handbook, which provides guidelines on the policies,
procedures, and programs affecting my employment with this organization. I understand
that Gigawatt/Energiya Global can, at its sole discretion, modify, eliminate, revise, or deviate
from the guidelines and information in this handbook as circumstances or situations
warrant.

I also understand that any changes made my Gigawatt/Energiya Global with respect to its
policies, procedures, or programs can supersede, modify, or eliminate any of the policies,
procedures, or programs outlined in this handbook. I accept responsibility for familiarizing
myself with the information in this handbook and will seek verification or clarification of its
terms or guidance where necessary.

Furthermore, I acknowledge that this handbook is neither a contract of employment nor a


legal document and nothing in the handbook creates an express or implied contract of
employment. I understand that I should consult my supervisor or a representative of the HR
department if I have any questions that are not answered in this handbook.

Signature: __________________________________________________

Date: ______________________________
COVID-19 onsite routines for Liberia

Setting up the site

A site (which can be a stationary site such as the solar field or the substation, or can be a
movable site such as for road works or the construction of the transmission line) requires:

• a hand washing station,


• a laser thermometer,
• a register of workers including signing daily how the worker got to site and that he/she
is healthy
• a cloth face mask for each worker
• poster showing social distancing rules (no handshake, hugging, kissing, sharing of
bottles, cups, food or utensils) and hand washing

Arrival on site

This pertains to workers, drivers and pre-approved visitors arriving on site.

Workers or visitors that arrive from other countries or regions in Liberia that have struggled with
COVID-19 are required to show a recent negative COVID-19 test or are required to self-isolate
for 7 days.

First time arrival: A worker/driver has to sign a health declaration related to infectious
deceases 1and will receive an Awareness Talk on Covid-19.

Daily routine:

• Hand washing
• Measure body temperature with laser device
• Sign at the entrance of the site that the health declaration is still valid, that they will
adhere to the personal distance and hygiene and declare how they arrived on site
• All vehicles that will be transporting people to site will be sanitized by the respective
drivers before picking up and again after dropping off employees and the driver will
report and sign a form stating who traveled in the vehicle and that the vehicle was
sanitized before pick-up.
• All frequent touched surfaces will be disinfected daily.
• During face to face meetings attendees should sit 2 meters apart from each other and
only necessary meeting participants should attend.
• Meeting, lunch breaks etc. should be conducted outdoors if possible. A structure
providing protection from the rain and sun, but with open sides will be constructed to
facilitate this.

1
Declare that you have not met anyone in the last 7 days who had or was suspected to have COVID 19,
no symptoms of COVID-19 and you have not recently arrived from abroad or from a region with many
active COVID-19 cases or that you have had the decease and now tested negative at least twice.
• COVID-19 awareness and regulations will be repeated/updated at least weekly
• All work conducted in close physical contact of less than 1.5 m requires all involved to
wear a face mask.

Transportation of workers to site from an area with known COVID-19 cases

The vehicle should only be operating at 50% of capacity and all people in the vehicle will ware
face masks.

Suspicion of COVID-19 or other infectious decease in a person on site

In case someone becomes unwell with flu like symptoms such as cough, shortness of breath,
severe fatigue on site or was discovered that they had a temperature above 37.5C the following
measures will be taken:

People arriving to site by vehicular transport

They should be brought home with no other people in the vehicle and isolate (clear guidelines
should be given what that means) and be in contact with their contractor when they have
recovered and been without symptoms for 48 h. The vehicle will be disinfected and a COVID-19
test will be ordered.

Local labor

The person will be sent home to isolate. A COVID-19 test will be ordered.
Workers’ Management Plan
PlPlanPlanPlan

Liberia 20 MW project
WORKERS’ MANAGEMENT PLAN
(WoMP)
Responsibility
Hanna Klein, in the role of Gigawatt Global’s HSE manager for the Project is responsible for the creation
and revision of the Workers’ Management Plan in close cooperation with the HSE manager of the to be
selected EPC.

Revision History

VERSION DATE AUTHOR COMMENTS

00.00 Hanna H. Klein First official emission

1
Workers’ Management Plan
PlPlanPlanPlan

Contents
1 DOCUMENT PURPOSE ........................................................................................................................................... 3
2 WORKERS’ MANAGEMENT .................................................................................................................................... 3
2.1 Policy ..................................................................................................................................................................... 3
2.2 Roles and responsibilities ...................................................................................................................................... 4
2.3 Work site rules and general Code of Conduct ....................................................................................................... 5
2.4 Workers’ insurance ............................................................................................................................................... 5
2.5 Training.................................................................................................................................................................. 6
3 RECRUITMENT PROCEDURES ................................................................................................................................ 6
3.1 Recruitment procedures for manual labor ............................................................................................................ 6
3.2 Recruitment procedures for skilled labor.............................................................................................................. 6
4 WORKERS’ ACCOMMODATION AND TRANSPORTATION ...................................................................................... 7

2
Workers’ Management Plan
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List of Abbreviations
CLO Community Liaison officer
EPC Enginteering, Procurement and Construction company, also called the contractor
GWG Gigawatt Global
HSE Health, Safety, Environment
PPE Personal Protect Equipment

1 DOCUMENT PURPOSE
The purpose of this document is to define the system, strategies and plans regarding how to recruit,
manage, transport and house workers engaged to construct the solar PV plant and the transmission line to
connect the plant with the substation.

2 WORKERS’ MANAGEMENT

We are dedicated to the fair treatment of all workers engaged to build the solar PV plant and the transmission line
(together called the Project). This includes the workers employed directly by the owner and developer: Gigawatt
Global (GWG) and the EPC company hired by GWG to construct the plant and transmission line and all the
subcontractors hired by any of these companies to work on the site.

2.1 Policy
The Project is firmly committed to support and protect the health, safety, welfare, security, and dignity of each
Worker involved in the Project. Ethical and transparent recruitment and employment practices, safe work,
labor rules and regulations compliance as well as healthy living and working environment are critical elements
to achieve this goal.

We will take appropriate measures to ensure that we and the contractors in our supply chain and with whom
we work on the Project hold an equal regard and understanding for the health, safety, and welfare of the
Workers in and around the project area.

The fundamental principles for the Policy are:

• The employment, welfare policies and standards for us and our subcontractors shall be in line with the
requirements set out in local and international labor legislation.

• Workers shall be provided with all relevant information about their human rights, labor rights and
entitlements under the law and this Policy, using appropriate methods and language, to ensure they
understand;

• The dignity of Workers shall be protected and preserved. Inhumane treatment, abuse and humiliating
disciplinary action is not permitted;

• Forced, compulsory, bonded, or indentured labor, human trafficking practices, or any other violations of
human and labor rights in accord with international standards, and this Policy, shall not be tolerated;

• Recruitment, selection, and hiring shall be conducted in a fair, transparent and ethical manner without
discrimination on the basis of ethnicity, gender, sexual orientation, pregnancy status, family status, social
status, political affiliation, race or religion;

• Employers shall ensure that Workers understand the terms and conditions of their employment and are
provided with written contracts in a language that they understand. Illiterate Workers shall have the
terms and conditions verbally communicated to them;

• Workers shall be provided a clean, secure, safe, and healthy working environment;

3
Workers’ Management Plan
PlPlanPlanPlan
• Workers’ living arrangements shall be in clean, secure, safe, and healthy living environment;

• Workers shall have unrestricted access to drinking water, water for personal sanitation and toilet
facilities at all times;

• All Workers must be treated equally and fairly, irrespective of their gender, sexual orientation, pregnancy
status, family status, ethnicity, social status, political affiliation, race, nationality, or religion;

• Wage payments shall be made as agreed and on time;

• Persons under the age of 18 shall not be employed;

• Within the limits of the law and this policy, Workers have the right to raise a grievance of what poses an
unacceptable safety or health risks, through the existing grievance mechanisms within the company they
are working for or directly to the Site manager, the HSE Office or the Community Liaison Offer on site;

• All Workers shall at all times have the freedom of movement outside normal working hours, unless there
are legitimate safety, security issues that might threaten the health, safety, and well-being of the
Worker;

• The project management shall be engaged and provide leadership and oversight on the implementation
of this Policy;

• Contractors, subcontractors and third parties falling under this Policy will bear full responsibility for
fulfilling the requirements of this Policy.

2.2 Roles and responsibilities

Project Manager (EPC):


Is responsible for implementing the Workers’ Management Policy and to pre-qualify all subcontractors
in accordance to the Policy and provide support to all staff with regards to the policy.

HSE Manager (EPC):


Is responsible for the oversight of this Policy and is authorized to coordinate and assess the specific
management plans to implement this Policy.

Owners HSE Manager (Gigawatt Global)


Is responsible for monitoring the implementation and adherence to the policy and the Workers’
management plan.

HSE Officer (EPC):


Is responsible to implement the Workers’ Management Plan on site and to report any accidents,
incidents or grievances and act to solve any problems.

Site manager EPC):


Is responsible to make the worksite a safe and healthy place for the Workers. He/she is also responsible
for only letting subcontractors enter the site that have passed the pre-qualification with regards to
Workers’ rights. He/she will ensure that personal protective equipment is available on site at all times
for all people present and to work in close collaboration with the HSE Officer to make sure the project
site is safe and well managed with respect to H&S issues.

Community liaison officer (Gigawatt Global):


Is responsible for overseeing and monitoring the treatment and behavior of all local workers,
independent of which subcontractor has hired them, to make sure that there is a fare process for hiring
local people in accordance to this plan and that the request of the Owner to have an appropriate mix of

4
Workers’ Management Plan
PlPlanPlanPlan
men and women is maintained and that worker’s get paid in accordance to their contracts. He will be
receiving, documenting and reporting grievances and is responsible to take the appropriate action to
address the grievances and work with the HSE Managers to change procedures etc to minimize
grievances in the future. In case of worker’s unrest or similar threats the CLO will take all the measures
locally to solve it and use external Liberian E&S experts to reach the appropriate resolve.

Subcontractors’ supervisor on site


Is responsible for overseeing and managing the Workers under their supervision and make sure that the
Workers are following the site rules and Code of Conduct.

2.3 Work site rules and general Code of Conduct


These site rules and Code of Conduct rules apply to the site, the workers accommodation and during workers’
transportation to and from the site.

• The site entrances have a register where all visitors, workers and guests entering the site are registered.
The name of each visitor has to be submitted to the security staff when the site opens in the morning. If
no record is found the worker will not to be allowed on site.
• All workers on site will wear identification tags on their hard hats to clearly document their
belonging to the project. This includes visitors and guests.
• Sleeping, resting or staying within the construction site is not allowed, workers on break have
to reconvene at the laydown area or outside the main gate.
• Harassment, intimidation, indecent conduct (including showing and viewing pornographic
material) and/or exploitation, especially in regard to women, are not tolerated at the work site
or at the workers accommodation or on the transportation vehicles bringing the workers to
the site.
• Acts of violence will lead to immediate dismissal and denied access to the work site.
• All workers are requested to report any suspicions of sexual exploitation as a result of the
project and any such reports will be investigated in depth.
• Workers are encouraged to report any grievances, all accidents and near misses to the CLO,
the HSE Officer or the Site Manager and the project staff are committed to address the
grievance in a speedy manor.
• Working alone is not permitted.
• All workers are requested to report anything that seems unsafe.
• All workers are required to wear the appropriate Personal Protective Equipment.
• The work area must remain tidy and cleaned up when a task is finished.
• Use the correct tools and use them safely.
• All workers are required to think of the safety of others as well as his/her own.
• Use natural resources sparingly.
• All workers are required to act respectfully. Bullying is unacceptable nor the use of abusive,
threatening, intimidating or embarrassing language any other worker.
• Alcohol and Drugs are strictly forbidden to be used in or around the work site.
• Smoking will not be permitted on site.
• Carrying any kind of weapons (firearms or knifes) are strictly forbidden.
• No tampering with equipment on site.
• It is not permitted to bring hazardous substances without prior consent.
• It is not permitted to remove flooring or gratings without permission.
• It is not permitted to ride on vehicles not designed for passengers.
• It is not permitted to park vehicles in unauthorized areas.

2.4 Workers’ insurance

5
Workers’ Management Plan
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Gigawatt Global, the Contractor and their subcontractors shall have adequate general insurance coverage, and
comprehensive employee medical and work-related accident insurance suitable and applicable for their
workforce.

2.5 Training

Training pertaining to H&S will be provided by the HSE Officer from the EPC.

Each worker will receive general and specific training for the tasks they are required to perform. The general
induction training will be given in English for all workers.

Each worker will sign a form that they have understood the H&S objectives, the color coding of the construction
site, waste management rules, incident reporting, safety directives in general and for fire in particular and
requirements for personal protective equipment and the location of first aid equipment.

All workers will also receive ToolBox talks on additional safety, the hazards of electricity and substance abuse. The
workers will have to sign attendance lists for these ToolBox talks.

Specific training will be provided to each worker dependent of their tasks. This training is provided directly by the
supervisors of each subcontractor. Each subcontractor has signed that they are in line with the projects Health
and Safety policies and guideline and the training will always be given with health and safety in mind.

3 RECRUITMENT PROCEDURES
The Contractor has the obligation to share with GWG all relevant information about their process of
selecting subcontractors for the Project and to advice on the final choice.
All the call for proposals should be published in the local newspapers, broadcasted on the radio and posted
at the offices of GWG, the Contractor and at the offices of the province.
Service agreements signed with subcontractors all include the clause that they comply with the
Environmental and Social Management Plan (ESMP) and it’s underlying management plans, with a specific
focus on the H&S Plan and the Environmental management Plan. The subcontractors that will provide
security services will have to have defined Use of Force policies that are in general agreement with this
plan.

3.1 Recruitment procedures for manual labor


Most of the recruitment of manual labor for the work on site is expected to happen next to the project
site. GWG, the Contractor and all subcontractors are expected to follow these recruitment procedures.
• Recruit manual labor including at least 30% women.
• Include the indigenous population and other vulnerable groups.
• Include all ages.
• Pay a respectable wage per day for manual labor above the stated minimum wage.
• All employees shall have a written contract and be informed of the expected duration of their
employment. In case the worker is illiterate, the contract will be read to them.
• Any deviations to the planned employment shall have a 3 days’ notice period.
• All payments are to be done at least bi-weekly for manual labor and at least monthly for skilled labor.
• All payments are to be completed the last day of employment (no worker leave site with unresolved
payments at the final day of work, regardless of reason for the work to end).
• All subcontractors to report to the Site Manager by e-mail confirming that payments are made.

All relevant manual labor positions will be posted by the Contractor and its subcontractors both at the site
and in the surrounding villages.

3.2 Recruitment procedures for skilled labor


6
Workers’ Management Plan
PlPlanPlanPlan
GWG, the Contractor and all Subcontractors are individually responsible to recruit skilled labor in
accordance with the principle of equal opportunity and in accordance to local laws.

4 WORKERS’ ACCOMMODATION AND TRANSPORTATION

The Contractor is expected is provide Workers accommodation in for up to 50 people in the greater
Monrovia area . All workers stationed in this facility will be skilled labor needed for specific tasks at the
site.

The facility will be clean, tidy and well-guarded and in compliance with the IFC/EBRD guideline for such
accommodation1. The Worker Management policy and code of conduct described above that can be
applied to the workers accommodation are in force at the facility.

All workers accommodated at the Worker Accommodation will be transported by buss or private car to
the site during work hours.

1
(https://www.ifc.org/GPN-WorkersAccommodation)
7
STAKEHOLDER
ENGAGEMENT PLAN
GIGAWATT GLOBAL 20 MW SOLAR PV PLANT
Liberia

Prepared for: Gigawatt Global

SLR Project No.: 710.13089.00001


Report No.: 002
Revision No.: B
October 2020
Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

DOCUMENT INFORMATION
Title Stakeholder Engagement Plan for Gigawatt Global 20 MW Solar PV Plant,
Liberia
Project Manager Conroy van der Riet
Project Manager Email cvanderriet@slrconsulting.com
Author Conroy van der Riet
Reviewer Stuart Heather-Clark
Keywords Gigawatt Global, Wind, Renewable, Liberia
Status Final
Report No. 002
SLR Company SLR Consulting (Africa) (Pty) Ltd

DOCUMENT REVISION RECORD

A 21 October 2020 Draft issued to Client CvdR

B 26 October 2020 Final CvdR

BASIS OF REPORT
This document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescales
and resources devoted to it by agreement with Gigawatt Global Cooperatief U.A (the Client) for part or all of the services it has been appointed by the
Client to carry out. It is subject to the terms and conditions of that appointment.
SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any person
other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or
collateral warranty.
Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Client and/or
its other advisors and associates. These data have been accepted in good faith as being accurate and valid. SLR disclaims any responsibility to the Client
and others in respect of any matters outside the agreed scope of the work. The copyright and intellectual property in all drawings, reports, specifications,
bills of quantities, calculations and other information set out in this report remain vested in SLR unless the terms of appointment state otherwise. This
document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which
may be unclear to it.
Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents
referenced explicitly herein and should then only be used within the context of the appointment.
Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

CONTENTS
INTRODUCTION ............................................................................................................. 1
1.1 Background ..............................................................................................................................1
1.2 Scope and Applicability ............................................................................................................1
1.3 Objectives ................................................................................................................................1
1.4 Policy and Principles.................................................................................................................2
1.4.1 Commitment to Stakeholder Engagement ................................................................................................................... 2
1.4.2 Stakeholder Engagement Principles .............................................................................................................................. 2

PROJECT OVERVIEW ...................................................................................................... 3

RELEVANT POLICY, LEGISLATIVE AND PLANNING FRAMEWORK ...................................... 3


3.1 Project Requirements ..............................................................................................................3
3.2 Liberian Regulations .................................................................................................................8
3.3 Lender Requirements...............................................................................................................8
3.3.1 IFC Performance Standards ........................................................................................................................................... 8
3.3.2 Good Practice ................................................................................................................................................................. 8

3.4 World Bank Environmental and Social Safeguards (2016) .....................................................10

STAKEHOLDER ENGAGEMENT PROGRAMME ................................................................ 12


4.1 Overview ................................................................................................................................12
4.2 Pre-Construction Engagement ...............................................................................................12
4.2.1 Appoint a Community Liaison Officer (CLO) ............................................................................................................... 13
4.2.2 Re-engagement ............................................................................................................................................................ 13
4.2.3 Disclosure of Project Information ................................................................................................................................ 13

4.3 Construction Phase Engagement ...........................................................................................14


4.3.1 Activities ........................................................................................................................................................................ 14
4.3.2 Maintain Site/Project Company Presence .................................................................................................................. 14
4.3.3 Monitor Contractor ...................................................................................................................................................... 14
4.3.4 Maintain Stakeholder Database .................................................................................................................................. 15
4.3.5 Maintain Grievance Procedure .................................................................................................................................... 15

4.4 Operations Phase Engagement ..............................................................................................15


4.4.1 Stakeholder Engagement Management...................................................................................................................... 15
4.4.2 Engagements Related to Transition to Operations .................................................................................................... 15
4.4.3 Continue Regular Engagements................................................................................................................................... 16
4.4.4 Maintain Stakeholder Database .................................................................................................................................. 16
4.4.5 Maintain Grievance Procedure .................................................................................................................................... 16

4.5 Tools and Methods ................................................................................................................16

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Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

RESOURCES AND RESPONSIBILITIES ............................................................................. 17


5.1 Gigawatt Global Head Office Support ....................................................................................17
5.2 EPC/O&M Site Manager .........................................................................................................17
5.3 Community Liaison Officer .....................................................................................................17
5.4 Community Working Group ...................................................................................................17

MONITORING AND REPORTING ................................................................................... 18

ANNEXURE A: STAKEHOLDER DATABASE ............................................................................... 19

LIST OF FIGURES
Figure 1: Regional Locality Map Showing the Location of the Proposed Solar PV Site .............................. 1
Figure 2: Location of the Proposed Solar PV plant and associated Transmission Line Route Options ...... 2
Figure 4: Stakeholder Engagement Activities in each development phase ............................................. 12

LIST OF TABLES
Table 1: SEP Objectives............................................................................................................................... 1
Table 2: Performance Standard 1 Stakeholder Engagement Requirements .............................................. 8
Table 3: Performance Standards 2, 4, 5, 6 and 8 Stakeholder Engagement Requirements ...................... 9
Table 7: Tools and methods for engagement........................................................................................... 16

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Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

INTRODUCTION

1.1 BACKGROUND
Gigawatt Global (GWG) is proposing to develop a 20 megawatt (MW) solar photovoltaic (PV) plant, to be
located on the Crawford Farm in the Montserrado County of Liberia, approximately 4 km south east of
the Mount Coffee Hydropower Plant (MCHPP) and approximately 25 km north of Monrovia. The nearest
established community is Crozierville, located 2 km south east of the Project site. The Project will also
involve the construction of a medium voltage (± 66 kV) transmission line from the solar PV plant to the
Mount Coffee substation.
This Stakeholder Engagement Plan (SEP) has been prepared for the 20 MW Solar PV Plant and
transmission line.

1.2 SCOPE AND APPLICABILITY


This SEP describes how the Project will engage external stakeholders during pre-construction,
construction and operations. This SEP is specific to the Project, and provides the following:
• Description of requirements for stakeholder engagement (regulatory, lender, company,
and/or other);
• Identification of stakeholders;
• Strategy and schedule for engaging with stakeholders;
• Resources and responsibilities for implementing the SEP;
• Monitoring and reporting requirements related to the SEP.

1.3 OBJECTIVES
In the context of the Project development, the purpose of stakeholder engagement is to provide a means
for stakeholders to express their views on Project risks, impacts, mitigations and enhancement. The
specific objectives of the SEP are summarised in Table 1.
The SEP describes how the Project will manage the process of engagement throughout the pre-
construction, construction and operational phases. The SEP is a “living” document that will be updated
as appropriate through the Project’s development, in accordance with key milestones, to facilitate
stakeholder participation in Project decision-making.
The SEP presents an approach that is based on current engagement activities and the future engagement
strategy, guided by international best practice.

Table 1: SEP Objectives


Objective Rational
Identify relevant stakeholders for Involving stakeholders to facilitate inclusive communication and capture
this Project a wide range of issues and concerns.
Distribute accurate project Ensuring that stakeholders, particularly those directly affected by the
information in an open and proposed development, have information with which to make informed
transparent manner comments and enable them to plan for the future. This reduces levels of
uncertainty and anxiety. Information should allow affected parties to
develop an understanding of potential impacts, risks and benefits and an
open and transparent approach is central to achieving this aim.
Form partnerships to promote Developing relationships of trust between the Project and stakeholders
constructive interaction between all will contribute to proactive interactions and avoid where possible,
parties unnecessary conflicts based on rumour and misinformation. Identifying
structures and processes through which to deal with conflicts and
grievances, in contrast to attempting to quash any disputes, would allow
the Project a better understanding of stakeholder concerns and

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Objective Rational
expectations thereby increasing the opportunities to increase the
Project’s value to local stakeholders.
Record and address public concerns, Documenting stakeholder issues allows Project decisions to be traced
issues and suggestions and motivated. This approach addresses potential concerns that
stakeholder engagement may be a token gesture by the developer that
meets requirements but that it is not taken seriously in the project
planning.
Manage stakeholders’ expectations Expectations, both positive and negative, are often out of proportion to
the realities of a project. This is particularly so in areas of poverty with
limited development, infrastructure and service provision. Ensuring that
expectations are kept at realistic levels (eg, around job opportunities;
provision of local infrastructure; social development; disruption and
resettlement) limits the disappointment and frustration of directly
affected parties at later stages of project implementation. Frustration
and unfulfilled expectations are key triggers of conflict and require
mitigation and management that might otherwise be avoided.
Fulfil national and international Ensuring compliance can avoid potential project delays based on
requirements for consultation procedural issues rather than substantive ones.

1.4 POLICY AND PRINCIPLES

1.4.1 Commitment to Stakeholder Engagement


GWG is committed to free, prior, and informed engagement with stakeholders. Effective stakeholder
engagement and public consultation is a cornerstone for successful project development. It involves
working closely with interested and affected parties through the Project’s life to ensure stakeholder are
well-informed about plans, impacts, and risk and have meaningful opportunities to provide input into
decisions which may affect them.
A structured, effective and culturally appropriate engagement program is required in order to build and
maintain positive community relationships, and by extension, a Project’s social license to operate.

1.4.2 Stakeholder Engagement Principles


The key principles guiding the Project’s approach to stakeholder engagement are as follows:
• To be open and transparent with stakeholders;
• To be accountable and willing to accept responsibility as a corporate citizen and to account
for environmental and social impacts associated with the Project activities;
• To have a relationship with stakeholders that is based on trust and a mutual commitment to
acting in good faith;
• To respect stakeholders’ interests, opinions and aspirations;
• To work collaboratively and in cooperatively with stakeholders to find solutions that meet
common interests;
• To be responsive to stakeholders;
• To be pro-active and to act in anticipation of the need for information or potential issues;
• To be fair and engage with stakeholders such that they feel they are treated fairly and their
issues and concerns are afforded fair consideration;
• To be accessible and within reach of stakeholders so that they feel heard and to provide
comprehensive information; and
• To proactively anticipate, identify and include all stakeholders.

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These principles have informed the Project’s approach to stakeholder engagement.

PROJECT OVERVIEW
Gigawatt Global (GWG) is proposing to develop a 20 megawatt (MW) solar photovoltaic (PV) plant, to be
located on the Crawford Farm in the Montserrado County of Liberia, approximately 4 km south east of
the Mount Coffee Hydropower Plant (MCHPP) and approximately 25 km north of Monrovia. The nearest
established community is Crozierville, located 2 km south east of the project site (see Figure 1).
The GWG project is responding to shortages in supply of electricity in Liberia. During the dry season in
Liberia the Mount Coffee Hydropower Plant (MCHPP) runs below its maximum production capacity
leading to a shortage in the national electricity supply. The ongoing expansion of the national grid and the
resulting new private and public off-takers are driving the need for additional electricity. GWG’s solar PV
project is responding to this need. As a result, GWG signed an amended Memorandum of Understating
(MoU) with the Chairman of Liberian Electric Corporation (LEC).
The project will also involve the construction of a medium voltage (± 66 kV) transmission line from the
solar PV plant to the Mount Coffee substation. In this regard two options have been considered.
Transmission Line (TL) Route Option 01 follows the Crozierville-White Plains road that runs directly south
of the solar PV site for approximately 3km, and then heads north next to the MCHPP-Monrovia road for
4 km to the Mount Coffee Substation. TL Route Option 02 follows the existing Côte d'Ivoire-Liberia-Sierra
Leone-Guinea (CLSG) transmission line servitude (that crosses the farm and the northern section of the
solar PV site) to the Mount Coffee Substation (see Figure 2).

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Figure 1: Regional Locality Map Showing the Location of the Proposed Solar PV Site

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Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

Figure 2: Location of the Proposed Solar PV plant and associated Transmission Line Route Options

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RELEVANT POLICY, LEGISLATIVE AND PLANNING FRAMEWORK


This Section describes the legal and policy framework for the Project’s stakeholder engagement as
required under applicable Liberian laws and regulations as well as specified in the requirements of the
Project’s proponents.

3.1 PROJECT REQUIREMENTS


The GWG Health, Safety and Environmental (HSE) Policy is included below. It outlines the HSE
commitments of GWG with respect to its construction activities, operational activities, and overall HSE
performance. The policy stipulates the commitments of GWG to continually improve HSE management
and comply with relevant HSE legislation, standards and codes of practice to which GWG subscribes.
The policy shall be maintained, implemented and communicated to all employees of GWG and its Project
contractors. This policy shall be made available to the public upon request.
If policies are to be adapted or developed they must include the following minimum management
requirements:
• A clear set of values and objectives for the effective management of environmental, health,
safety and social (EHSS) issues;
• Commitment to identification and management of all EHSS risks in line with the topics above
and their effective management through operational controls;
• Commitment to legal and our other voluntary obligations;
• Senior leadership commitment;
• Providing the resources needed to meet our performance objectives including training and
competency;
• Establishing measurements and targets for performance;
• Ensuring ongoing monitoring, evaluation and reporting on performance; and
• Periodic review of all policies (at least every 2 years).

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3.2 LIBERIAN REGULATIONS


In terms of national legislation, there is a requirement for stakeholder engagement during the
environmental impact assessment process as stipulated by the Environmental Protection and
Management Law of the Republic of Liberia (2003).
There are no further legal or regulatory requirements for stakeholder engagement during the Project life.

3.3 LENDER REQUIREMENTS


The Project will adhere to the environmental and social performance requirements of the Project’s
prospective lenders. In the case of the Project, these are contained in the IFC Performance Standards on
Environmental and Social Sustainability (2012) and good international practice.

3.3.1 IFC Performance Standards


The IFC Performance Standards on Environmental and Social Sustainability (the “IFC Performance
Standards”) are considered a benchmark for good practice for environmental and social risk management
in private sector developments. The IFC Performance Standards require that clients engage affected
communities through disclosure of information, consultation, and informed participation, in a manner
commensurate with the risks to and impacts of the Project on the affected communities.
The IFC Performance Standards include specific guidance on conducting stakeholder engagement both
during the planning phase and through the Project lifecycle.
Relative to the ESIA process, stakeholder engagement requirements are contained in Performance
Standard 1: Assessment and Management of Environmental and Social Risks and Impacts. The key
requirements for consultation and disclosure applicable to the ESIA process and ongoing engagement
through the life of the Project are summarised in Table 2.
The IFC Performance Standards also have stakeholder engagement and consultation requirements for
specific topic areas as described in IFC Performance Standard 2, 4, 5, 6 and 8 (refer to Table 3). These are
to address impacts and risks to the following:
• Labour and working conditions;
• Community health and safety;
• Impacts on livelihoods;
• Biodiversity and natural resources; and
• Cultural heritage.

3.3.2 Good Practice


In addition to the requirements of the IFC Performance Standards, the Project has adopted certain good
practices as described in the Stakeholder Engagement: A Good Practice Handbook for Companies Doing
Business in Emerging Markets (IFC 2007).
The handbook provides recommendations on use of written and oral communication in local languages,
accessibility to information, the use of oral and visual methods, respect of local traditions, care that
vulnerable groups are included in the process, and mechanisms to respond to peoples’ needs, fears and
expectations.
The handbook was used to guide the development of this SEP.

Table 2: Performance Standard 1 Stakeholder Engagement Requirements


Aspects Engagement Requirements
Stakeholder Analysis and Stakeholder engagement is an on-going process that may involve, in
Engagement Planning varying degrees, the following elements: stakeholder analysis and
planning, disclosure and dissemination of information, consultation and

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Aspects Engagement Requirements


participation, grievance mechanism, and on-going reporting to Affected
Stakeholders.
Disclosure of Relevant Project Provide affected stakeholders with access to relevant information on: (i)
Information the purpose, nature, and scale of the project; (ii) the duration of
proposed project activities; (iii) any risks to and potential impacts on
such stakeholders and relevant mitigation measures; (iv) the envisaged
stakeholder engagement process; and (v) the grievance mechanism.
Consultation Consultation will be in line with the degree of impact of the Project and
should: i) begin early and continue through project, ii) be based on prior
disclosure of relevant and easily accessible information on the project,
iii) focus engagement on those who are directly affected, iv) be free of
outside interference and external manipulation, v) enable meaningful
participation, vi) be documented.
Informed Consultation and For projects with potentially significant adverse impacts on affected
Participation stakeholders, conduct an informed consultation and participation
process. It should involve deep exchange of views and information, and
an organized and iterative consultation, leading to the project
incorporating into their decision-making process the views of the
affected stakeholders on matters that affect them directly, such as the
proposed mitigation measures, the sharing of development benefits and
opportunities, and implementation issues. The process should be
documented, in particular the measures taken to avoid or minimize risks
to and adverse impacts on the affected stakeholders. The stakeholders
should be informed about how their concerns have been considered
External Communications Implement and maintain a procedure for external communications that
includes methods to (i) receive and register external communications
from the public; (ii) screen and assess the issues raised and determine
how to address them; (iii) provide, track, and document responses, if
any; and (iv) adjust the management program, as appropriate. In
addition, clients are encouraged to make publicly available periodic
reports on their environmental and social sustainability.
Grievance Mechanism for Affected Establish a grievance mechanism to receive and facilitate resolution of
Stakeholders affected stakeholders’ concerns and grievances about the client’s
environmental and social performance.
On-going Reporting to Affected Provide periodic reports to the affected stakeholders that describe
Stakeholders progress with implementation of the project Action Plans on issues that
involve on-going risk to or impacts on affected stakeholders and on
issues that the consultation process or grievance mechanism have
identified as a concern to those stakeholders. The Performance
Standards require that after completion of an environmental
assessment the consultation and disclosure must continue throughout
the life cycle (construction and operation phase) of the project.

Table 3: Performance Standards 2, 4, 5, 6 and 8 Stakeholder Engagement Requirements


Standard Key Requirements
Performance Standard 2: Labour Recognizes that the pursuit of economic growth through employment
and Working Conditions creation and income generation should be balanced with the protection
of basic rights for workers.
Acknowledges that constructive worker-management relationship and
safe and healthy working conditions may enhance the efficiency and
productivity of operations.

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Standard Key Requirements


Performance Standard 4: Recognizes that project activities, equipment and infrastructure bring
Community Health, Safety & benefits to communities including employment, services and
Security opportunities for economic development. However, the project can also
increase the potential for community exposure to risks from
development.
Where project activities pose risks of adverse impacts on the health and
safety of affected communities the developer is required to make
available relevant information (including the details of an Action Plan), in
an appropriate form, to affected parties and government authorities so
that they can fully understand the nature and extent of the risks.
Performance Standard 5: Land In such instances the developer will undertake extensive consultation
Acquisition and Involuntary and negotiation with affected parties. Such communication will include
Resettlement (including physical transparent access to project related information in a timely fashion to
and economic displacement) enable people to plan for the future. Here public participation will
include the establishment of appropriate representative forums through
which resettlement and compensation are discussed. Most of this
consultation is part of the SIA and Resettlement Action Plan (RAP) but it
should be recognized as a component of the SEP.
Although resettlement is always seen as a last resort, this Standard
recognizes that involuntary resettlement occurs as a result of projects
and refers to both physical and economic displacement as a result of
project related land acquisition. Resettlement is considered involuntary
when affected individuals or communities do not have the right to
refuse land acquisition that result in their displacement.
Consultation shall also take place with host communities.
Performance Standard 6: Recognizes that protecting and conserving biodiversity in all its forms is
Biodiversity Conservation and fundamental to sustainable development.
Sustainable Natural Resource
Where the project has potential impacts on legally protected or critical
Management
habitats consultation with relevant authorities, specialists and
communities must be undertaken.
Performance Standard 8: Cultural Recognizes the importance of cultural heritage for current and future
Heritage generations and is consistent with the convention concerning the
protection of the world’s cultural and natural heritage.
Where sites of cultural heritage are potentially impacted by the project
the developer will consult with local communities as well as relevant
national authorities responsible for the maintenance of such sites

3.4 WORLD BANK ENVIRONMENTAL AND SOCIAL SAFEGUARDS (2016)


The World Bank Environmental and Social Framework sets out the World Bank’s commitment to
sustainable development, through a Bank Policy and a set of Environmental and Social Standards that are
designed to support borrowers’ projects, with the aim of ending extreme poverty and promoting shared
prosperity.

This Framework comprises:


• A Vision for Sustainable Development, which sets out the World Bank’s aspirations regarding
environmental and social sustainability;
• The World Bank Environmental and Social Policy for Investment Project Financing, which sets
out the mandatory requirements that apply to the Bank; and

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• The Environmental and Social Standards, together with their Annexes, which set out the
mandatory requirements that apply to the Borrower and projects.
The World Bank Environmental and Social Policy for Investment Project Financing sets out the
requirements that the Bank must follow regarding projects it supports through Investment Project
Financing.
The Environmental and Social Standards set out the requirements for borrowers relating to the
identification and assessment of environmental and social risks and impacts associated with projects
supported by the World Bank through Investment Project Financing. The Bank believes that the
application of these standards, by focusing on the identification and management of environmental and
social risks, will support borrowers in their goal to reduce poverty and increase prosperity in a sustainable
manner for the benefit of the environment and their citizens. The standards will: support borrowers in
achieving good international practice relating to environmental and social sustainability; assist borrowers
in fulfilling their national and international environmental and social obligations; enhance non-
discrimination, transparency, participation, accountability and governance; and enhance the sustainable
development outcomes of projects through ongoing stakeholder engagement.
The ten Environmental and Social Standards establish the standards that the Borrower and the Project
will meet through the project life-cycle, as follows:
• Environmental and Social Standard 1: Assessment and Management of Environmental and
Social Risks and Impacts;
• Environmental and Social Standard 2: Labour and Working Conditions;
• Environmental and Social Standard 3: Resource Efficiency and Pollution Prevention and
Management;
• Environmental and Social Standard 4: Community Health and Safety;
• Environmental and Social Standard 5: Land Acquisition, Restrictions on Land Use and
Involuntary Resettlement;
• Environmental and Social Standard 6: Biodiversity Conservation and Sustainable
Management of Living Natural Resources;
• Environmental and Social Standard 7: Indigenous Peoples/Sub-Saharan African Historically
Underserved Traditional Local Communities;
• Environmental and Social Standard 8: Cultural Heritage;
• Environmental and Social Standard 9: Financial Intermediaries; and
• Environmental and Social Standard 10: Stakeholder Engagement and Information Disclosure.

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STAKEHOLDER ENGAGEMENT PROGRAMME

4.1 OVERVIEW
Broadly, the stakeholder engagement programme consists of the following activities:
• Continuous identification and recognition of stakeholders;
• Refinement of engagement and information dissemination tools;
• Development of appropriate engagement strategies to guide the engagement process during
the Project’s lifetime;
• Notification and invitation to participate;
• Ongoing formal and informal engagement of stakeholders throughout the Project life through
various media;
• Recording issues raised and commitments;
• Recording activities undertaken within the process; and
• Communication of the grievance mechanism.
Following completion of stakeholder engagement planning, activities will occur through the course of
further Project development: pre- construction; construction; and operations. The objectives and specific
activities that will occur in each Project development phase are summarised in Figure 3 below.

Figure 3: Stakeholder Engagement Activities in each development phase

4.2 PRE-CONSTRUCTION ENGAGEMENT


The following activities will be undertaken during the pre-construction phase:
• Appointment of a Community Liaison Officer (CLO);
• Re-engagement with stakeholders; and

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• Disclosure of information about the Project construction and operation.

4.2.1 Appoint a Community Liaison Officer (CLO)


A Community Liaison Officer (CLO) will be appointed by GWG and is responsible for disseminating
information and coordinating community communications through the course of the Project.
The CLO will be responsible for interfacing between stakeholders and the Project.
The CLO will need to be introduced at the pre-construction engagements in order to ensure visibility
amongst the stakeholders and consistency throughout the engagement process. The CLO will need to be
acquainted with the stakeholders and stakeholder process including the Project schedule and
engagement milestones in order to inform stakeholders appropriately. The CLO will need to be an
individual ideally recruited from the community but taking into consideration connections and stance
towards the planning process to ensure that they do not have a vested interest in a particular outcome.
The CLO will speak English (official language in Liberia) in order to facilitate communication both at the
local level and in reporting clearly with Project management, the sponsors and lenders which will be
important in the construction phase.

4.2.2 Re-engagement
It is important that stakeholders have a clear understanding of the Project and planned Project activities
in order to minimise the risk of negative or unrealistic expectations about impacts and or benefits arising
and becoming unmanageable.
A round of focused engagement meetings will therefore need to be undertaken at least a month prior to
the start of construction activities. This will include the following:
• Formal engagements with both regulators/authorities and community leadership to present
the Project SEP, Grievance Mechanism and planned engagement activities over the coming
phases of the Project; and
• A community meeting, open house, or public meeting convened at an accessible location in
the Project area.
The agenda for the community meeting is to include:
• Project update and information disclosure, and presentations on SEP; including key technical
elements and key environmental and social issues, construction activities and schedule
including the planned schedule for engagement.
• Introduction to the CLO and other the roles and responsibilities for engagement by the
Project.
• Introduction and explanation of the function of the community working group and its dual
role as an engagement vehicle for both the Land Acquisition process and for the wider
stakeholder engagement going forward.
• Introduction and explanation of the Project’s Grievance Mechanism.
All planned formal and informal engagements should be used as an opportunity to identify and register
any new stakeholders and to gather and register stakeholder feedback issues and concerns.

4.2.3 Disclosure of Project Information


To supplement pre-construction engagement activities, Project information will also be disseminated
throughout the Project area during this period.
Notices such as a Project summary and stakeholder engagement meetings will be posted in accessible
locations such as Community Halls, Health Centres and Schools within the Project area of influence.

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Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

4.3 CONSTRUCTION PHASE ENGAGEMENT

4.3.1 Activities
The engagement activities that will be carried out during the construction phase are as follows:
• Maintain a presence through CLO;
• Monitor contractors;
• Maintain Stakeholder Database; and
• Maintain the Grievances Procedure

4.3.2 Maintain Site/Project Company Presence


In order to ensure the CLO is visible and accessible to the stakeholders, the Project will maintain a
permanent space for the CLO on the site or in a location convenient for stakeholders. The contact details
of CLO and where their issues/grievances can be registered will be publicised to affected communities.

Regularly Engage Stakeholders


The CLO will be responsible for designing and implementing regular proactive and structured,
engagement with affected stakeholders. During construction this will take place on a monthly basis as a
minimum.
Engagement will be focused on informing and updating community members about the Project
construction activities and schedule including anticipated delays or changes, in that given month, and on
the potential impacts that can be expected to occur along with the measures planned to mitigate these.
These engagements may include:
• Face to face information dissemination meetings if required with local leadership and other
key authorities;
• Community meetings or meetings with community leaders for updates and information
sharing on topics of community concern such as community health and community safety
awareness sessions; and
• Focus Group Discussions (FGDs) for special interest groups with concerns.
Information dissemination tools will continue to be used to support the above activities for example: an
accessible form of Project update document via a notice board will be considered as a medium for
communicating changes to stakeholders concerning Project design, progress on meeting social and
environmental management commitments, details of upcoming construction activities and or changes to
schedule.
Local radio broadcasts, if deemed effective during pre-construction, will continue to be used for updating
communities on construction activities.

4.3.3 Monitor Contractor


Unmanaged or poorly handled interactions between communities and Project contractors can present a
risk to the Project. It may result in inconsistent or contradictory messages or conflicting commitments
from the contractor and Project representatives to stakeholders. This can result in heightened
expectations and conflict.
The CLO will liaise with and monitor contractors to ensure that any interaction taking place between
contractor workforce and stakeholders is consistent with the standards, core principles and procedures
for undertaking, recording and documenting stakeholder engagements, as is outlined in this SEP.

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Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

4.3.4 Maintain Stakeholder Database


In order to ensure all stakeholders affected by construction are identified and engaged, the CLO will be
responsible for ensuring the stakeholder database (Annexure A) and SEP are regularly updated and risks
associated with stakeholders are assessed and re-evaluated as necessary based on information revealed
through interactions, engagement and grievance management. Any new stakeholders that may have
arrived in the Project area or developed an interest in the Project should be analysed and strategies
developed for engaging them. The CLO will be responsible for feeding back to the lenders information on
new stakeholders or changing stakeholder issues/risks which arise through their stakeholder interactions.

4.3.5 Maintain Grievance Procedure


Unresolved stakeholder grievances can quickly escalate, often leading to unforeseen work stoppages and
delay. It will therefore be important during the construction phase to respond quickly and effectively to
grievances raised, and work closely through regularly engaging with stakeholders to try and anticipate
where stakeholder issues or concerns may arise before they do.
The CLO will be responsible for identifying, logging and responding to all external grievances and resolving
locally those that can be managed in the immediate term, or reporting and escalating more complex
issues to GWG management as appropriate.

4.4 OPERATIONS PHASE ENGAGEMENT


The operation phase will consist of a continuation of many of the same activities that have been
undertaken during construction, but likely at a reduced frequency. The programme will be further refined
near to the start of Project operation. The following provides an outline.
Engagement activities that will be carried out during the operations phase are as follows:
• Stakeholder engagement management;
• Engagements related to transition to operations ;
• Continue regular engagements;
• Maintain Stakeholder Database; and
• Maintain Grievance Procedure.

4.4.1 Stakeholder Engagement Management


The Project will need to ensure adequate resources are available for stakeholder engagement during
operations. This could come in the form of continued presence of a CLO or handover to other
management functions. Any transition will need to be managed. The loss of familiar project staff can
impact on established stakeholder relationships and cause a loss of institutional knowledge and often a
breakdown in trust. If the CLO role is passed onto a new CLO or to other management then this needs to
be clearly communicated to affected stakeholders.

4.4.2 Engagements Related to Transition to Operations


Operation phase engagement activities will be designed to clearly communicate anticipated changes
brought by the transition from construction to operations and to manage community expectations around
the associated impacts, for example a reduction in employment and other economic opportunities, and a
high turnover in Project staff.

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Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

4.4.3 Continue Regular Engagements


Regular, direct engagement in the form of Community Working Group update meetings, and where
required focus group discussions around specific issues or concerns, will continue between the CLO and
key Project stakeholders. Engagement will be aimed primarily at maintaining continuity of relationships,
monitoring the effects of project impacts on stakeholders and particularly on vulnerable groups, and
demonstrating long-term organisational commitment to delivering on social and environmental
mitigations or to resolving outstanding issues and grievances.
It is recommended this formal engagement with the Community Working Group continue on a quarterly
basis once the Project is operational.

4.4.4 Maintain Stakeholder Database


In order to ensure all stakeholders affected by operations are identified and engaged the CLO will be
responsible for ensuring the stakeholder database (Annexure A) and SEP are regularly updated and risks
associated with stakeholders are assessed and re-evaluated as necessary based on information revealed
through interactions, engagement and the grievance mechanism. Any new stakeholders that may have
arrived in the Project area or developed an interest in the Project should be analysed and strategies
developed for engaging them. The CLO will be responsible for feeding back information on new
stakeholders or changing stakeholder issues/risks within the Action Plan which arise through their
stakeholder interactions.

4.4.5 Maintain Grievance Procedure


Engagements will continue to be recorded and documented in minutes, and all stakeholder issues and
grievances logged and managed according to the External Grievance Mechanism.

4.5 TOOLS AND METHODS


This section describes information dissemination tools that may be used during the implementation of
the SEP and outlines an implementation schedule.
During the pre-construction and construction phases a number of tools will be developed to facilitate
engagement and disclosure. Based on the initial analysis of stakeholders, the tools and formats detailed
in Table 4 will be developed.

Table 4: Tools and methods for engagement


Tools Description
BID A Background Information Document (BID) should be prepared to be
distributed during pre-construction phase engagement. The BID will
provide a description of the proposed Project and details of the project
proponent.
Notice Boards A notice board(s)will be erected either at the entrance to the Project
site or at a central location to communities and updated on a monthly
basis or following CLO visits as necessary. The notice board(s) will serve
as an information dissemination tool where the Project or the CLO are
able to post information pertinent to the Project. For example the
Project will be able to display construction updates, heavy traffic
movement information, and recruitment updates. Wherever possible,
maps or visual aids will be used to increase accessibility of the notices.

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Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

Tools Description
Radio Broadcasts The literacy levels in area are low meaning information dissemination
through the notice board or newsletter may not reach everyone (and
where a community meeting is not appropriate). Therefore additional
media for communication methods should be explored. A radio
broadcast could be used to provide updates or live question and answer
sessions and information related to the project (this could also reach a
broader audience).
Community Working Group Community Working Group meetings will be used as a regular channel
Meetings to inform the affected communities of project status and progress. The
Community Working Group will then be responsible for updating the
Community through community meetings or informal channels
following each meeting.
Focus Groups Discussions In Focus Groups Discussions a structured questionnaire is used to
conduct engagements with different stakeholder groups with specific
issues of concern. Different stakeholder groups are engaged separately.
The questions explored and discussed can follow several themes (e.g.
grievances experienced in relation to labour).

RESOURCES AND RESPONSIBILITIES

5.1 GIGAWATT GLOBAL HEAD OFFICE SUPPORT


The GWG HSE Manager will be responsible for administering and monitoring the ESMP, and will
participate in the review, approval, and as necessary, update or modification of ESMP in response to
changing project conditions.
The GWG Management Representative will also provide management support to the EPC/O&M Site
Manager, EPC/O&M Contractors HSE and GWG CLO as necessary to ensure proper implementation of
management requirements.

5.2 EPC/O&M SITE MANAGER


The EPC/O&M Site Manager will be responsible to oversee all environmental, social, health and safety
aspects of the project to ensure continuing compliance with the ESMP. In addition, GWG will ensure that
the EPC/O&M Contractor appoint suitable HSE personnel for the construction and operational phases.

5.3 COMMUNITY LIAISON OFFICER


GWG will appoint a CLO who will be responsible for overseeing the interaction with the affected
communities and other stakeholders.
This individual will be physically located so as to provide an initially continuous presence in the project
area, to build trust and relationships with key stakeholders and affected communities, and receive and
manage grievances as part of a broader External Grievance Mechanism.

5.4 COMMUNITY WORKING GROUP


This Community Working Group will serve as a vehicle for communication and ongoing liaison with the
affected communities during the construction period and on an ongoing basis through the Project life.
A typical Community Working Group is made up of at least two representatives (including Chiefs) from
each of the directly affected communities. It will continue to operate beyond the completion of the Land

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Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

Acquisition and Compensation process as an engagement forum and meet regularly with the CLO for the
purposes of information disclosure on the Project and as a channel for community grievances.

MONITORING AND REPORTING


The SEP will be monitored and evaluated regularly using the indicators as recommended by international
best practice (e.g. IFC Handbook). The monitoring results, both qualitative and quantitative, will be
disclosed to stakeholders on an annual basis at a minimum. Suggested monitoring and evaluation
activities are outlined below:
• Monitor the grievance register in terms of response times to address complaints logged as
well as the recurrence of complaints over time.
• Regularly update of the stakeholder register and stakeholder risk analysis.
• Keep records of all engagement activities.
• Keep a library (electronic or hard copy) of all communication material.
• Develop and assess performance in terms of Key Performance Indicators (KPIs), some
suggested KPI are:
o Number of engagement activities facilitated (by stakeholder group and engagement
type);
o Number of attendees at stakeholder engagement activities (expected vs actual);
o Number of grievances received per annum; and
o Overall sentiment towards to the Project and company is should be monitored through
periodic “External Factors Review” Reports.
• Revise plans and activities

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Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

ANNEXURE A: STAKEHOLDER DATABASE

Stakeholder
Engagement Database_Liberia_v2.xlsx

Page 19
ID ORGANISATION POSITION NAME AND SURNAME CONTACT DETAILS EMAIL ADDRESS
Liberia Land Authority
Clay Building,
Sekou Toure Avenue,
Mamba Point,
Monrovia, Liberia
1 Liberia Land Authority (LLA) Commissioner, Land, Policy, and Planning Cllr. Kula L. Jackson Tel: +231 775275328/ +231 888621906 info@lla.gov.lr
Liberia Land Authority
Clay Building,
Sekou Toure Avenue,
Mamba Point,
Monrovia, Liberia
2 Liberia Land Authority (LLA) Director of Internal Audit Division Mr. Romeo Clark Tel: +231 775275328/ +231 888621906 info@lla.gov.lr
Ministry of Public Works
P.O. Box 9011,
Lynch Street,
South,
Monrovia,
Liberia
3 Ministry of Public Works Assistant Minister for Planning and Programming Hon. James J. Reynolds Tel: +233of50Mines
Ministry 701 8200
& Energy tmaxsr@yahoo.com
Buzzi Quarter, Capitol Hill
P. O. Box 10-9024
1000 Monrovia, 10, Liberia
4 Ministry of Mines & Energy Minister Hon. Gesler E. Murray Tel: +231(0)770132540 /+231 77 067 mme@gov.lr
Ministry of Mines & Energy
Buzzi Quarter, Capitol Hill
P. O. Box 10-9024
1000 Monrovia, 10, Liberia
Tel: +231(0)770132540 /+231 77 067
5 Ministry of Mines & Energy Deputy Minister for Operation Hon. Emmanuel O. Shannon, 0524 mme@gov.lr

Liberia Elecricity Corporation


Headquarters,
Waterside
P.O. Box 10-165
6 Liberia Electricity Corporation Community Liaison Officer Mr. Ballah Y. Kezelee Monrovia, Liberia info@lecliberia.com
Liberia Elecricity Corporation
Headquarters,
Waterside
P.O. Box 10-165
7 Liberia Electricity Corporation HSE Manager Mr. B. Baccus Robert Monrovia, Liberia info@lecliberia.com
Liberia Elecricity Corporation
Headquarters,
Waterside
P.O. Box 10-165
8 Liberia Electricity Corporation Environmental Officer Mr. Abraham L. B Monrovia, Liberia info@lecliberia.com
Ministry of Agriculture
P.O. Box 10-9010
Somalia Drive,
Gardnersville, Liberia
Republic of Liberia
9 Ministry of Agriculture Director, Marketing Department Mr. James T. Moore Tel: +231 (77) 961-574/ +231(6) 560-962 Jtmoore@moa.gov.lr

Ministry of Agriculture
P.O. Box 10-9010
Somalia Drive,
Gardnersville, Liberia
Republic of Liberia
10 Ministry of Agriculture Marketing Officer Mr. Stephen N. Teeneh Tel: +231 (77) 961-574/ +231(6) 560-962 snteeneh@moa.gov.lr
Environmental Protection Agency of
Liberia
4th Street, Sinkor
P.O. Box 10-4024
1000 Monrovia
Liberia
Tel.: +231776556839/+231886556839
11 Environmental Protection Agency Assistant Manager, Environmental Social Impacts Assessment Unit Mr. Kawasu M. Toure ktoure@epa.gov.lr
Environmental Protection Agency of
Liberia
4th Street, Sinkor
P.O. Box 10-4024
1000 Monrovia
Liberia
Tel.: (231) 888 12 17 15/ 777797160
Environmental Protection Agency Manager, Department of Compliance & Enforcement John Kpakolo Jallah Jr jjallah@epa.gov.lr / jkj2g4@gmail.com
Liberia Refugee Repatriation
Resettlement Commission
Ave Saint-neuvième Cheeseman
PO Box 10-9043
1000 Monrovia
Liberia
12 Liberia Refugee Repatriation Resettlement Commission Deputy Executive Director for Operation Hon. Alphanso Wallace Tel:+231 651 3449 lrrrc04@yahoo.com
National Public Health Institute of Liberia
P.O. Box 1871, Congo Town Back Road,
Monrovia,
13 National Public Health Institute of Liberia Director of Environmental and Occupational Health Dr. Amos Gborie Liberia info@nationalphil.org
Rural and Renewable Energy Agency,
Newport Street,
Monrovia
Tel:+231 886 527 484/ +231 (0) 776 309
14 Rural and Renewable Energy Agency of Liberia Environmentalist Mr. David Wiles 880 davidw@rrealiberia.org
15 Crozierville Township Leadership Commissioner Ruth L. James, 0777746370
16 Crozierville Township Leadership Township Development Chairman G. Matthew Siaker 0775572359
17 The Elder Council-Crozierville Philip Gblayah 07755732253
18 The Elder Council-Crozierville Jonathan M. Kennedy
19 The Elder Council-Crozierville Rufus Gbanjah
20 Women Leadership-Crozierville Konah Yah 0776922267
21 Youth Leadership-Crozierville Youth chairman Randolph S. Diggs 0777019658
22 Antoinette Tubman Public School-Crozierville VPI and Teaching Staff Peter S. Harris 0770571248
23 Crozierville Reproductive and Maternity Center-Crozierville Kaikee Padmore Registrar Christopher M. Nyaquoi 0777219725
24 Porte School Principal Gladys M. Porte 0776031347
25 Religious Council/Leadership Mot. Fatu Bemah 0776662153
26 Weeks Compound Weeks Compound, Adjacent Crawford farm Angelique Weeks

27 White Plain Township Leadership Urias W .Brooks- Commissioner John B. Bannie 0778462939
28 White Plain Township Leadership Chief of Elders (Youth Chairman) Otis Brown

29 Harrisburg Township Leadership Commissioner Viola B. Garway 0777913791


30 Harrisburg Township Leadership Township Clerk Romeo D. Bass 0776309653
31 Harrisburg Township Leadership Gen. Town Chief Thomas D. Cooke
Gigawatt Global SLR Project No: 710.07072.00001
Stakeholder Engagement Plan 20 MW Solar PV Plant, Liberia

Conroy van der Riet Conroy van der Riet Stuart Heather-Clark
(Report Authors) (Project Manager) (Reviewer)

Page 20
AFRICAN OFFICES

South Africa
CAPE TOWN
T: +27 21 461 1118

FOURWAYS
T: +27 11 467 0945

SOMERSET WEST
T: +27 21 851 3348

Namibia
WINDHOEK
T: + 264 61 231 287

SWAKOPMUND
T: + 264 64 402 317
EXTERNAL GRIEVANCE
MECHANISM
GIGAWATT GLOBAL 20 MW SOLAR PV PLANT
Liberia

Prepared for: Gigawatt Global

SLR Project No.: 710.07072.00001


Report No.: 003
Revision No.: B
October 2020
Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

DOCUMENT INFORMATION
Title External Grievance Mechanism for Gigawatt Global 20 MW Solar PV Plant,
Liberia
Project Manager Conroy van der Riet
Project Manager Email cvanderriet@slrconsulting.com
Author Conroy van der Riet
Reviewer Stuart Heather-Clark
Keywords Gigawatt Global, Wind, Renewable, Zambia
Status Final
Report No. 003
SLR Company SLR Consulting (Africa) (Pty) Ltd

DOCUMENT REVISION RECORD


Rev No. Issue Date Description Issued By
A 21 October 2020 Draft issued to Client CvdR

B 27 October 2020 Final CvdR

BASIS OF REPORT
This document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescales
and resources devoted to it by agreement with Gigawatt Global Cooperatief U.A (the Client) for part or all of the services it has been appointed by the
Client to carry out. It is subject to the terms and conditions of that appointment. SLR shall not be liable for the use of or reliance on any information, advice,
recommendations and opinions in this document for any purpose by any person other than the Client. Reliance may be granted to a third party only in the
event that SLR and the third party have executed a reliance agreement or collateral warranty. Information reported herein may be based on the
interpretation of public domain data collected by SLR, and/or information supplied by the Client and/or its other advisors and associates. These data have
been accepted in good faith as being accurate and valid. SLR disclaims any responsibility to the Client and others in respect of any matters outside the
agreed scope of the work. The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other
information set out in this report remain vested in SLR unless the terms of appointment state otherwise. This document may contain information of a
specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which may be unclear to it. Information, advice,
recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents referenced explicitly
herein and should then only be used within the context of the appointment.
Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

CONTENTS
INTRODUCTION ............................................................................................................. 3
1.1 Purpose and scope of this document.......................................................................................3
1.2 Objectives ................................................................................................................................3

LEGISTATIVE REQUIREMENTS ........................................................................................ 4


2.1 National legisation applicable to the project ...........................................................................4
2.2 International standards ............................................................................................................4

ROLES AND RESPONSIBILITIES ........................................................................................ 5


3.1 Financial resources ..................................................................................................................5
3.2 Organisational Structure and Human resources ......................................................................5

GRIEVANCE MECHANISM ............................................................................................... 5


4.1 Step 1: Receive and Log Grievance ..........................................................................................7
4.2 Step 2: Acknowledge Grievance ...............................................................................................8
4.3 Step 3: Assess, Prioritise and Report Grievance .......................................................................8
4.4 Step 4: Investigate and Resolve Grievance ..............................................................................9
4.5 Step 5: Sign-off on Grievance .................................................................................................11
4.6 Step 6: Monitor ......................................................................................................................11

MONITORING AND REPORTING ................................................................................... 12


5.1 Monitoring .............................................................................................................................12
5.2 Reporting ...............................................................................................................................12

RECORDS ..................................................................................................................... 12

ANNEX A: GRIEVANCE REGISTER AND TRACKER ..................................................................... 13

ANNEX B: GRIEVANCE LOG FORM ......................................................................................... 14

LIST OF FIGURES
Figure 1: Grievance Procedure Flowchart .................................................................................................. 7
Figure 2: Criteria for Prioritising Grievance/ Complaints ........................................................................... 9

LIST OF TABLES
Table 1: Four basic resolution approaches ............................................................................................... 10

ii
Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

INTRODUCTION
The management of grievances is a vital component of stakeholder management and an important aspect
of risk management for the Gigawatt Global 20 MW Solar PV Plant project in Liberia. Grievances can be
an indication of growing stakeholder concerns (real and or perceived).
The grievance mechanism is intended to:
• actively keep track and manage external grievances, including the feedback associated with
the grievances;
• ensure that appropriate actions are taken; and
• ensure that resolutions are achieved.

1.1 PURPOSE AND SCOPE OF THIS DOCUMENT


Local concerns over the impact of a project can be expressed in the form of a formal or informal complaint.
This could encompass relatively minor concerns as well as more entrenched, serious or long-term issues,
which may be described as grievances. In both cases, it is important to have robust and credible local
mechanisms to systematically handle and resolve any complaints that might arise from both real and
perceived impacts so that they do not escalate and present a risk to operations. An effective grievance
mechanism should foster positive relationships and trust with employees and external stakeholders.
This grievance mechanism applies to all activities associated with construction and operation of the
Gigawatt Global 20 MW Solar PV Plant, and includes all work sites (including the associated transmission
line) established.
Gigawatt Global (GWG) will proactively inform affected communities and wider stakeholders of the details
of the grievance mechanism in the course of its community and stakeholder engagement activities
associated with asset development, operations and retirement as described in the Stakeholder
Engagement Plan.

1.2 OBJECTIVES
The objective of this grievance mechanism is to provide stakeholders who have a concern or complaint
the opportunity to have it examined effectively and within an appropriate timeframe. This document
provides a systematic approach to addressing grievances that is consistent, transparent and accessible to
stakeholders.
The UN Guiding Principles on Business and Human Rights (Foundational Principle 31, “Access to Remedy”)
provides a list of key principles that should underpin a non-judicial grievance mechanism. The principles
outlined below provide guidance for designing, revising or assessing a grievance mechanism to help
ensure that it is effective in practice.
In order to ensure its effectiveness, a non-judicial grievance mechanism should be:
• Legitimate: the mechanism must be “trust-worthy”, if it is not stakeholders are unlikely to
choose to use it.
• Accessible: Barriers to access may include a lack of awareness of the mechanism, language,
literacy, costs, physical location and fears of reprisal.
• Predictable: Stakeholders’ trust for and use of the grievance mechanism is enhanced through
the public provision of information about the procedure it offers.
• Equitable: Affected stakeholders usually have less access to information and expert resources
than business enterprises, and often lack the financial resources to pay for them.
• Transparent: Regular communication with affected parties about the progress of individual
grievances is essential to retaining confidence in the process, and the provision of statistics,
case studies and more detailed information about the handling of certain cases, can be
important to demonstrate its legitimacy and retain broad trust. Simultaneously, the

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

mechanism should ensure confidentiality of the dialogue between parties and of individuals’
identities.
• Rights-compatible: Grievances are frequently not framed in terms of human rights, nor do
they initially raise human rights concerns; where outcomes have implications for human
rights, care should be taken to ensure that they are in line with internationally recognized
standards.
• Continuous learning: Regular analysis of the frequency, patterns and causes of grievances,
should be conducted in order to ascertain how policies, procedures or practices may be
altered to prevent future harm.
• Engagement and dialogue: engaging with affected stakeholder groups (potentially through a
third party) about the design and performance of the grievance mechanism can help to
ensure that it meets their needs, that they will use it in practice, and that there is a shared
interest in ensuring its success.
This grievance procedure does not replace existing Liberian legal processes, and nor does it impede access
to other judicial or administrative remedies that might be available under domestic law or through
existing arbitration procedures.

LEGISTATIVE REQUIREMENTS

2.1 NATIONAL LEGISATION APPLICABLE TO THE PROJECT


There are no specific Liberian legal obligations or guidelines governing the development and
implementation of an external grievance mechanism. However, GWG are committed to community
development in the community around the project site and will thus engage with local communities to
accurately assess the needs and expectations of these communities and for the purposes of maintaining
both formal and social licence to operate.

2.2 INTERNATIONAL STANDARDS


GWG uses a variety of funding models for different projects including limited recourse debt markets,
capital markets or bank loans from organizations like the International Financial Corporation (IFC) and
commercial banks.
When seeking financing for projects, GWG expects and will work to the relevant IFC Performance
Standards (PSs). Although these do not directly constitute law, they are applied to loans as a condition of
the loan.
IFC PS 1 and Equator Principles No 6 state that where there are Affected Communities, the client (i.e.
bank’s client - the company seeking finance) will establish a grievance mechanism to receive and facilitate
resolution of Affected Communities’ concerns and grievances about the client’s environmental and social
performance. This grievance mechanism should be scaled to the risks and adverse impacts of the project
and have Affected Communities as its primary user. It should seek to resolve concerns promptly, using an
understandable and transparent consultative process that is culturally appropriate and readily accessible,
and at no cost and without retribution to the party that originated the issue or concern. The mechanism
should not impede access to judicial or administrative remedies. The client will inform the Affected
Communities about the mechanism in the course of the stakeholder engagement process.
The objective of a grievance mechanism in terms of IFC PS 1 is to: “respond to communities’ concerns
related to the project, to receive and facilitate resolution of the Affected Communities’ concerns and
grievances about the project’s environmental and social performance”.

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

ROLES AND RESPONSIBILITIES


GWG will make provision for the necessary financial and human resources to execute the contents of this
grievance mechanism. The resource requirements have been outlined below.

3.1 FINANCIAL RESOURCES


GWG will ensure that there are sufficient funds available for on-going engagement activities, such as
provision of necessary staff and associated training activities, distribution of documents and posters,
translation of documentation where appropriate and provision for hosting of public meetings.

3.2 ORGANISATIONAL STRUCTURE AND HUMAN RESOURCES


GWG will define an organisational structure, which sets out the tiers of responsibility relating to
stakeholder management, and engagement, under which the grievance mechanism will fall, including the
internal reporting lines between the executive and operations.
The GWG Community Liaison Officer (CLO) will be responsible for the implementation of this grievance
mechanism, with assistance from the EPC/O&M Contractor. Clear lines of responsibility, accountability,
information and consultation within the organisation will be established.

The GWG CLO will be responsible for overseeing continued community engagement and supporting the
EPC/O&M Contractor to implement the grievance mechanism. The GWG CLO will be responsible for:
• Interfacing with National, Provincial and District Authorities, Traditional Authorities and
Project Affected Villages;
• Responding to low priority grievances and initiating and coordinating responses from the
appropriate managers to mid and high priority grievances;
• Reporting to the GWG HSE Manager on a weekly or monthly basis regarding engagement
activities and community issues and concerns including the management of grievances;
• Being present in, and accessible to, the communities and overseeing the Grievance
Mechanism function; and
• Directing communication with stakeholders around the resolution of grievances.
• Collecting, logging and prioritizing grievances;
• Coordinating and tracking timely responses;
• Monitoring corrective actions;
• Communicating with stakeholders around the resolution of grievances;
• Interfacing directly with the community at regular intervals in appropriate forums; and
• Being based on site and available to the community at well publicized times and at
accessible locations.

The GWG CLO and EPC/O&M Contractor will receive appropriate training in stakeholder engagement,
managing grievances and local community interactions/customs.

GRIEVANCE MECHANISM
The grievance mechanism must be a simple process whereby stakeholders can submit their complaints
free of charge and, if necessary, anonymously or via third parties. It should allow complaints to be
submitted in more than one format.
GWG will establish several channels through which a grievance can be lodged, it will allow complaints to
be submitted in more than one format including:

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

• Submission of complaints in writing or in person to identified staff member/s.


• Submission of complaints via email, SMS and Whatsapp.
• Allowing an elected community members and/or non-governmental organisations (NGOs)
to gather and forward stakeholder concerns /complaints to the operation.
• Allowing for informal identification of complaints (e.g. through employees, on behalf of a
community in which they live).

The process of reporting a grievance should be easily accessible and un-intimidating to any stakeholder.
The preferable channels for reporting grievances can be discussed with the community as part of
community engagement.

Following the establishment of the channels above, the method for addressing grievances is systematic
and is divided into six key steps. These are as follows:

• Step 1: Receive and log grievance.


• Step 2: Acknowledge grievance.
• Step 3: Assess and prioritise grievance and forward to relevant department.
• Step 4: Investigate and resolve grievance.
• Step 5: Sign-off on grievance.
• Step 6: Monitor.

The six steps are described in more detail below and illustrated in Figure 1.

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

GWG

Figure 1: Grievance Procedure Flowchart

4.1 STEP 1: RECEIVE AND LOG GRIEVANCE


The grievance is received by GWG CLO. The GWG CLO logs the grievance using an official grievance log
form and ensures that it is captured in the Grievance Register and Tracker (Annex A) in order to monitor
actions taken against the grievance. The grievance log will contain a record of the complainant and will
record implementation dates for the following actions:

• Date the complaint was made;


• Information on proposed corrective action sent to complainant (if appropriate);
• Date response sent to complainant; and
• The date the complaint was closed out.

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

Each complaint will be assigned an individual number, to ensure that it is appropriately tracked and
closed out. Annex B provides an example of a Grievance Log Form.

Tips for receiving a grievance include:


• Regardless of who receives the grievance, it needs to be forwarded to the GWG CLO and GWG
HSE Manger.
• The grievance mechanism should make it possible to lodge a grievance in any appropriate
format (written, verbal, telephonic, email, post etc.). Consideration should be given to
capturing concerns raised informally or indirectly (e.g., through perception studies, media
reports, social media, etc.).
• It is important that the process is easily accessible and not intimidating to stakeholders.
• Regardless of the form of the complaints, all need to be addressed with the same sincerity
and seriousness.
• The GWG CLO will be required to be in touch with the complainant at least once per month
to provide feedback on the grievance.

4.2 STEP 2: ACKNOWLEDGE GRIEVANCE


The GWG CLO will acknowledge receipt of the grievance in writing and verbally and provide information
on the proposed steps and the anticipated timeframes to resolving the grievance.
This acknowledgement should be provided to the complainant within five (5) days of receiving the
grievance.
If the grievance is not well understood or if additional information is required, clarification will be sought
from the complainant.
Tips for Acknowledging a Grievance :
• Literacy levels should be taken into consideration when providing the complainant with the
acknowledgment of receipt, and verbal acknowledgement should accompany a written
acknowledgement.
• Where appropriate acknowledgement should be provided through the GWG CLO.

4.3 STEP 3: ASSESS, PRIORITISE AND REPORT GRIEVANCE


The GWG CLO, together with the GWG HSE Manager will assess the grievance, and assign it a risk rating.
The outcome of the risk rating has implications for the level within GWG to which the complaint is
reported, and the seniority of management oversight required.
Once the grievance has been rated, the grievance will be discussed with the relevant department Manager
for input to establish context and actions (e.g. Security, Human Resources, Sustainability, Procurement,
HSEQ etc.).
The risk rating categories are provided in Figure 2 below. This categorisation provides an indication of the
severity of the complaint and has implications to what level within the Company the complaint is
reported. Repeated or continuous Level 1 or 2 complaints must be escalated to the next level up if the
cause is not rectified within an acceptable period.
The GWG CLO will manage and resolve Low Risk grievances. High and Medium Risk grievances will be
escalated to senior management. An incident investigation team (overseen by GWG) will be assigned
within 10 days of receipt of the grievance for all Medium and High Risk grievances. The incident
investigation team should be comprised of staff from the relevant departments to which the grievance
applies, as well as representatives from GWG and the EPC/O&M Contractor. Some grievances may also
require involvement of local leadership and/or government.

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

Figure 2: Criteria for Prioritising Grievance/ Complaints

4.4 STEP 4: INVESTIGATE AND RESOLVE GRIEVANCE


Investigation and resolution may entail a dialog or series of dialogs between affected parties to find a
solution to the grievance. It may also entail investigating the underlying cause of the grievance and action
any changes required to internal systems/procedures to prevent a recurrence of grievances.
An Incident Investigation Report will be completed within 28 days (considered good practice) for all
Medium and High Risk grievances.
During the 28 days of dialog and/or investigation, the GWG CLO (with support from the EPC/O&M
Contractor and GWG HSE Manager where required) will co-ordinate conflict resolution activities
necessary to contain and resolve any actual or potential conflicts arising from the reported grievance. If
the case is complex and the stated resolution timeframe cannot be met, interim responses will be
provided (oral or written) that informs the stakeholder of the delay, explains the reasons, and offers a
revised date for next steps.
Tips for resolving grievances:
• Grievance verification is especially important when the grievance is about another contractor
or stakeholder. For example, the community may make claims against a sub-contractor that
needs to be investigated before acted upon.
• A regular forum to discuss grievances could be in the form of a monthly meeting where
grievances are discussed. This forum can be constituted more frequently or as is needed
especially in the case of Medium and High Risk grievances. This is particularly relevant to
phases of the project that are likely to result in the highest degree of impact (e.g.,
construction).
• It is important to be transparent about the mechanism to resolve the issue. The appropriate
level of action may require further consultation. Also, the issue may be symptomatic of a
bigger issue. When this arises, both the symptom and the cause need to be addressed and
resolved. For example, a complaint about job seekers setting up informal housing near the

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

site may be raised as an issue related to informal housing but may also be symptomatic of an
issue around influx of people and associated negative impacts.
• There are instances where grievances cannot be resolved in 28 days. In these cases, monthly
updates must be given to the stakeholders who raised the grievance to provide them a report
on progress.

It is important to note that all grievances shall be dealt with on a case-by-case basis. Face-to-face
discussions with complainants, that seek to jointly identify and select measures for grievance settlement,
will increase ownership of solutions and help to mitigate perceptions that resolutions unfairly benefit
GWG or the project.

Compensation rates (if compensation is required) will be set by GWG with involvement from traditional
leadership, the GWG CLO and Legal functions. Compensation payments can often cause conflict or
disputes thus it is important that compensation rates are applied consistently and fairly across all
operations.

Presented in Table 1 below are four basic resolution approaches that can be offered. Complainants shall
have influence over the approach selected. The resolution approaches might be presented during these
discussions.

Table 1: Four basic resolution approaches


Approach When to Use Benefits

Company proposes Complaint is straight forward; issue is clear, and Rapid response
a solution solution is obvious.
Use of fewer company personnel and material
Company can resolve issue alone, to the satisfaction resources
of the complainant, based on their knowledge and
Control of resolution procedures and
authority.
outcomes
Company proposal is more likely to be acceptable to
High level of satisfaction among community
the complainant.
about expeditious resolution

Company and Case is complex, and several diverse stakeholders Complaint can be addressed early, rapidly and
community decide involved. informally
together
Community level of distrust with company is high. Solution does not feel like a compromise
Response from company proposes is not accepted. Improve relationship and address concern in
principled creative way
Substantive interest exists for both parties.
Approach is less adversarial, faster, flexible and
Talking together is required to promote more
less costly
effective communication, share information or
develop mutually acceptable solutions.

Company and Decide together approach is not acceptable Simple and less legalistic procedure
community refer to
Dispute of facts or conflicts about data Expedited decisions
third party
Unable to reach voluntary settlement through other Choice regarding who hears and decide a case
procedures
More predictability, accessibility, impartiality,
and transparency than legal institutions

Use of traditional Imported procedures are unfamiliar, inaccessible or Simple and cost effective
and customary culturally incompatible with local customary
Use of customary practices is easily acceptable
practices practices of a community
to local community
Alternative traditional means are available that can
Builds up mutual trust and respect
be adapted in mutually acceptable to both the
parties

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

4.5 STEP 5: SIGN-OFF ON GRIEVANCE


The GWG CLO will seek sign-off from the complainant(s) that the grievance has been resolved.

In instances where the stakeholder is not satisfied with actions taken, the GWG CLO will:

1. Escalate to senior management and a decision will be taken either to implement


supplementary actions or to consider initiating an appeal process.
2. If required, approach a neutral or third party to assist in mediating and resolving the
grievance.
3. If required, approach the host country’s judiciary to further address the grievance.

Following this process, the GWG CLO will again approach the stakeholder to obtain sign-off on actions
implemented.

All grievances must also be signed off at an appropriate level of seniority of staff. In this regard, it may
be suitable that:

o all grievances with a Low Risk rating be signed off by the GWG CLO.
o all grievances with a Medium or High Risk rating be forwarded to senior management (e.g.
GWG HSE Manager) for sign-off.

The staff member who signs off the complaint should have sufficient knowledge about the topic to
provide assurance.

Once sign-off has occurred, this should be recorded in the Grievance Log (Annex B).

4.6 STEP 6: MONITOR


The GWG CLO will monitor the satisfaction of the stakeholder and project personnel following sign-off
(this will take place in the 28 days after sign-off).
Any grievances not signed-off as resolved will be further investigated and the GWG CLO will seek
agreement from the stakeholder to maintaining contact in order to determine what further action is
required to resolve the grievance.

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

MONITORING AND REPORTING

5.1 MONITORING
The Grievance Register and Tracker (Annex A) will be monitored on a weekly basis to review response
times to address complaints lodged as well as the recurrence of complaints over time.
The grievance mechanism will be evaluated annually, and revised if required.
GWG shall regularly monitor media coverage of the project.

5.2 REPORTING
GWG will report internally at least once a quarter on all grievances received (both open and closed), and
how they were/will be resolved.
All grievances received will be captured in the Grievance Register and Tracker (Annex A).

RECORDS
All records related to external grievances management (e.g. training, inspections, grievance forms,
grievance tracker, etc.) shall be maintained by the GWG CLO.
Records of all engagement activities including meetings attended, open-house events, focus group
discussions, road shows, etc. shall be maintained by the GWG CLO. It is suggested to maintain a library
(electronic or hard copy) of all communication material.

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

ANNEX A: GRIEVANCE REGISTER AND TRACKER

GWG 20 MW Solar
PV Plant Liberia_Grievance Register and Tracker.xlsx

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INTRODUCTION
Grievance Mechanism for the Gigawatt Global 20 MW Solar PV Plant, Liberia
The purpose of the External Grievance Mechanism is to implement a formalized process (identification, tracking and response) to manage complaints/grievances about the Unika I WInd Farm project that could
potentially arise from communities and other stakeholders in a systematic and transparent manner.

This Project Grievance Mechanism comprises six steps:

Step 1 - Receive and Log Grievance


Step 2 - Ackowedge Grievance
Step 3 - Assess, Prioritise and Report Grievance
Step 4 - Investigate and Resolve Grievance
Step 5 - Sign-off on Grievance
Step 6 - Monitor and Report
Gigawatt Global 20 MW Solar PV Plant, Liberia: Community Grievance Register and Tracker
Number Date Recipient Complainant (Stk Name and Title) Description of Grievance Priority Step (1-6) Action Responsible for resolution Status (Open/In-Progress/Closed) Findings Resolution Date of Close out Additional Comments/Follow up

Claim of crop damage due to increased dust on land plot close to Project area
EXAMPLE: 0001 2018/01/17 CLO Mr A. Smith Medium Step 4 Investigate and Resolve grievance CLO Open TBC TBC TBC TBC
Gigawatt Global 20 MW Solar PV Plant, Liberia: Grievance Tracker
Ngonye: New Issues Reported

Priority January February March April May June July August September October November December Total
High
Medium
Low
New (not rated)
Total

Issues Closed During the month

January February March April May June July August September October November December

Issues Open Remaining Month end

January February March April May June July August September October November December

Priority Closed Open Total


High
Medium
Low
New (not rated)
Total
Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

ANNEX B: GRIEVANCE LOG FORM

GRIEVANCE LOG FORM


SECTION 1: COMPLAINANT DETAILS
Complaint Reference Number Date Received Recipient of Complaint Manner in which
Complaint was
Identified /
Submitted by
Complainant
Request to remain Anonymous? Yes No

Name of Complainant / Organisation Registering Complaint (if not anonymous)

Contact Details Telephone Number Physical and/or Postal


Address

SECTION 2: DETAILS OF COMPLAINT

Company Manager Responsible for Addressing the Complaint


Time and Date Complaint Refers to (i.e. when did the event happen)
Description of Complaint and / or Evidence of the Issue

SECTION 3: GRIEVANCE RATING


Provide the grievance risk rating for Low Risk Medium Risk High Risk
this grievance
Provide a brief reason for the assignment of the risk rating:

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

GRIEVANCE LOG FORM


SECTION 4: ACTION TAKEN / REQUIRED
Acknowledgement of Complaint Sent to Date When Acknowledgment Date Set for Resolution of Complaint
Complainant? (Y / N) Provided

Description of Subsequent Action Taken (divide into Immediate Action and Subsequent Investigation, if applicable)

Action Carried Out By Whom: Date of Completion Method of feedback to Complainant

Stakeholder Response to Action

SECTION 5: EFFECTIVENESS REVIEW


How was the Actions Verified to be Effective at Resolving the Complaint?

Approval and Sign-off by: Date:

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Gigawatt Global SLR Project No: 710.07072.00001
External Grievance Mechanism 20 MW Solar PV Plant, Liberia

Conroy van der Riet Conroy van der Riet Stuart Heather-Clark
(Report Authors) (Project Manager) (Reviewer)

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AFRICAN OFFICES

South Africa
CAPE TOWN
T: +27 21 461 1118

JOHANNESBURG
T: +27 11 467 0945

Namibia
WINDHOEK
T: + 264 61 231 287

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