Gharo Solar - Mott Macdonald - HSE Audit-2

Gharo 50MW Solar PV Plant
Second Environmental and Social Construction

Monitoring Report
November 2019
Mott MacDonald
Victory House
Trafalgar Place
Brighton BN1 4FY
United Kingdom
T +44 (0)1273 365000

F +44 (0)1273 365100
mottmac.com
Gharo 50MW Solar PV Plant

402705 02 CM
Second Environmental
Mott MacDonald
and Social Construction
Monitoring Report
November 2019
Mott MacDonald Limited. Registered in

England and Wales no. 1243967.
Registered office: Mott MacDonald House,
8-10 Sydenham Road, Croydon CR0 2EE,
United Kingdom
Mott MacDonald | Gharo 50MW Solar PV Plant
Second Environmental and Social Construction Monitoring Report
Issue and Revision Record
Revision Date Originator Checker Approver Description

A 22/11/19 I Kim P Gouws M Maxwell First issue
B 05/12/19 I Kim P Gouws M Maxwell Revised based on comments
Document reference: 402705 | 02 | CM
Information class: Standard

This doc ument is iss ued for the party whic h c ommissioned it and for specific purpos es c onnected with the above-capti oned project onl y. It s houl d not be r elied upon by any other par ty or used for any other purpose.
We accept no r esponsibility for the c ons equences of this document being reli ed upon by any other party, or being us ed for any other purpos e, or c ontaini ng any error or omission which is due to an error or omis sion in data s uppli ed to us by other parties.
This doc ument c ontai ns c onfi denti al infor mation and pr opri etar y intellectual property. It should not be s hown to other parti es without c onsent from us and fr om the party whic h c ommissioned it.
This Report has been prepared solely for use by the party which commissioned it (the 'Client') in connection with the
captioned project. It should not be used for any other purpose. No person other than the Client or any party who has
expressly agreed terms of reliance with us (the 'Recipient(s)') may rely on the content, information or any views
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Data. Inevitably, some of the assumptions used to develop the forecasts will not be realised and unanticipated
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the Report as there are likely to be differences between the forecasts and the actual results and those differences
may be material. While we consider that the information and opinions given in this Report are sound all parties must
rely on their own skill and judgement when making use of it.
Information and opinions are current only as of the date of the Report and we accept no responsibility for updating
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Mott MacDonald | Gharo 50MW Solar PV Plant
Contents
Executive summary 7
1 Introduction 9
1.1 Overview 9
1.2 Project description and construction status 9
1.3 Project participants 10
2 EHSS performance and compliance review 11

2.1 EHSS performance statistics 11
2.1.1 Health, safety and environmental performance statistics 11
2.1.2 H&S incidents 11
2.1.3 Environmental incidents 12
2.1.4 Workforce 12
2.1.5 Grievances 12
2.1.6 Performance categorisation 13
2.2 EHSS compliance review 14
3 Corrective Action Plan 20

3.1 Overview 20
3.2 Corrective Action Plan 21
4 Environmental and Social Action Plan 25

4.1 Overview 25
5 Appendices 31
A. Photographs 32
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Mott MacDonald | Gharo 50MW Solar PV Plant 7
Executive summary
Introduction
Mott MacDonald has been appointed by Nederlandse Financierings-Maatschappij voor
Ontwikkelingsladen N.V. (FMO) (the lender) to perform environmental and social (E&S)
construction monitoring on the 50MW Gharo Solar photovoltaic (PV) project (the project) being
developed by Gharo Solar Ltd (GSL or the sponsor) in Gharo, Pakistan. This report presents the
findings of our second E&S construction monitoring review, covering the period of July to
September 2019.
The purpose of the monitoring is to provide independent verification that construction works are
being executed in compliance with the applicable requirements.
The project will occupy approximately 90 acres of land and consist of bifacial monocrystalline
365-375Wp rating PV modules, inverters, underground electrical cables, 132kV site substation,
site access tracks and upgrade work to the existing access track from the main highway.
Construction commenced in March 2019 and commercial operation date (COD) is scheduled for
24 November 2019. At the time of our site visit, civil piling works, finalisation of PV module
installation and construction of the on-site accommodation buildings were underway.
Environmental and social performance review

For all parameters subject to our performance review, the risk categorisation was found to be
medium or low. Current medium risks identified relate to the following parameters:
● Community investment: The corporate social responsibility (CSR) plan and the needs
assessment to inform the plan must be developed prior to COD. As the plan is currently in
development and expected to be submitted before COD, it will be reviewed to inform our
third monitoring report, envisaged in early 2020.
● Labour and working conditions: An internal labour and human resources (HR) audit was
conducted in September 2019, which identified several key gaps in labour practices on site
for a portion of the workforce including: lack of written contracts; delayed salaries; lack of
sufficient notice before termination of contracts; and differences between paid wages and
provincial minimum wage requirements. GSL has identified corrective actions which the
contractors Banu Mukhtar Contracting (BMC, civil works) and Siemens (electrical works) are
in the process of addressing.
The project personnel have acknowledged the importance of addressing these risks. With
continued implementation of the project E&S management system and corrective actions
identified within this report, we consider that these risks can be managed.
Overall, the project has made good progress in this reporting period to address several
corrective actions identified in the first monitoring report, as well as outstanding E&S action plan
(ESAP) actions. However, the upcoming transition from the construction phase to COD and
operations will need to be monitored carefully to ensure that the remaining corrective and ESAP
actions are addressed. This includes developing E&S management plans (ESMPs) for the
operations phase that address the outstanding gaps identified in several of the construction
ESMPs, These operation phase ESMPs must be disclosed to workers in a timely manner.
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Corrective action plan

Corrective actions have been identified as listed in section 3 of this report. In summary, for this
reporting period, the following corrective actions have been identified:
● Medium risk: two (both in progress from previous reporting period)

● Low risk: ten (two outstanding from previous period and eight new actions)
Sixteen actions that were previously open were closed out in this period. All open actions have
been assigned completion deadlines and responsible parties to facilitate successful close out.
Progress against each action will be reviewed during future reporting periods.
Environmental and social action plan compliance

The project ESAP is included within the finance agreement. In this period four actions remain in
progress while seven have been closed, as further detailed in section 4 of this report.
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1 Introduction
1.1 Overview
Mott MacDonald has been appointed by Nederlandse Financierings-Maatschappij voor
Ontwikkelingsladen N.V. (FMO) (the lender) to perform environmental and social (E&S)
construction monitoring on the 50MW Gharo Solar photovoltaic (PV) project (the project) being
developed by Gharo Solar Ltd (GSL or the sponsor) in Sindh province, Pakistan. This report
presents the findings of our second E&S construction monitoring audit for the period of July to
September 2019.
The purpose of the monitoring is to provide independent verification that construction works are
being executed in compliance with the applicable requirements:
● International Finance Corporation (IFC) Performance Standards (PSs) (2012)

● Applicable World Bank Environmental, Health and Safety (EHS) Guidelines
● Good International Industry Practice (GIIP)
● National E&S, health and safety (H&S) laws and regulations, including national obligations
under international law that apply to the project
● International conventions, treaties and agreements adopted by Pakistan
The monitoring reports are informed by a site visit, discussions with on-site representatives of
the GSL and its contractors and consultants, and a desk-based review of supporting EHS and
social (EHSS) documentation.
An E&S specialist from Mott MacDonald undertook the EHSS construction monitoring visit on
30 October 2019. A summary of the itinerary is provided in Table 1 and photographs of our site
observations are presented in Appendix A.
Table 1: Itinerary
Date Activities
30/10/19 ● Site induction
● Introductory meeting and presentations in the project site office
● Meeting with GSL and contractor EHS team
● Meeting with contractor HR team
● Meeting with the community liaison officer (CLO) team
● Community meetings at local village
● Site tour
● Visit to site clinic
● Meeting with GSL EHS manager and security managers
● Close-out meeting
Source: Mott Macdonald
1.2 Project description and construction status

The project will occupy approximately 90 acres of land and consist of bifacial monocrystalline
365-375Wp rating PV modules, inverters, underground electrical cables, 132kV site substation,
site access tracks and upgrade work to the existing access road from the main highway.
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The project has two main subcontractors; Banu Mukhtar Contracting (civil works) and Siemens
(electrical works). Contractors are being managed directly by GSL and therefore the project
does not follow a typical engineering procurement and construction (EPC) model.
The project also requires construction of a 132kV overhead transmission line (OHL) of
approximately 2km in length connecting the project site substation to the nearby Oursun project
substation. This OHL will be constructed by K-Electric and is considered an associated facility to
the project.
Construction commenced in March 2019. At the time of our site visit, civil piling works,
finalisation of PV module installation and construction of the on-site accommodation buildings
were underway. The revised scheduled commercial operation date (COD) is 24 November
20191 and as of September 2019, the project was on track to achieve this COD.
1.3 Project participants

The key project participants are as follows:
● Gharo Solar Ltd (GSL): the sponsor

● Siemens: electrical contractor
● Banu Mukhtar Contracting (BMC): civil works contractor
● JA Solar: PV module supplier
● Sungrow: invertor supplier
● Optimum Tracker: tracker supplier
● O&M Solutions (OMS): owners engineer
In addition, the sponsor has a number of external advisors providing advice in relation to legal,
insurance, contracting, E&S governance and civil design matters.
1
As per Schedule 4 of Energy Purchase Agreement
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2 EHSS performance and compliance

review
2.1 EHSS performance statistics

EHSS performance statistics are summarised below, as included within GSL’s monthly progress
reports for the months of July, August and September 2019.
2.1.1 Health, safety and environmental performance statistics

Health, safety and environmental (HSE) performance statistics are detailed in Table 2 below.
Table 2: HSE statistics

HSE statistics July 2019 August 2019 September 2019 Project total
(since March
2019)
Fatality 0 0 0 0
Lost time injury (LTI) 0 0 0 0
Restricted work day case (RWDC) 0 0 0 1
Medical treatment case (MTC) 0 0 0 0
First aid case (FAC) 4 4 6 26
Environmental incident (EI) 0 2 3 13
Material damage (MD) 0 0 0 2
Near miss incident (NMI) 1 0 4 10
Security incident (SI) 0 0 0 0
Road traffic incident (RTI) 0 0 0 2
Fire incident 0 0 0 0
Unsafe acts/unsafe conditions (UA/UC) 156 67 148 726
Source: GSPL monthly progress reports
2.1.2 H&S incidents

First aid incidents primarily concerned minor injuries and cuts sustained while handling
equipment and carrying out construction works. One incident entailed a nail piercing the sole of
a worker’s shoe. Regular inspections should be undertaken to ensure that workers are wearing
the project-provided personal protective equipment (PPE), and that safety boots provided to
workers are of sufficient quality.
The monthly reports continue to lack the total working hours per month which would allow for
calculation of the total incident frequency rate. This should be included going forward.
Generally, good OHS practice conditions were apparent on site such as safety signage and use
of mandatory PPE.
It is evident that near misses are being recorded and also that a significant number of UA/UC
are being identified. This is considered good practice and will enable the project to identify any
trends and implement appropriate control measures to prevent accidents and incidents from
occurring.
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2.1.3 Environmental incidents

Five environmental incidents were reported with three related to overflowing of the septic tank.
The other two incidents concerned improper disposal of food waste after lunch (though it is not
stated who was responsible), and dismantling of a waste storage area without the waste having
been uplifted.
Septic tank operations were reviewed in September 2019 and, as a result, a new tank was
installed later that month; this is emptied every four days by an appropriately licensed contractor
and disposed of to Sindh environmental protection agency (SEPA) approved facilities. While the
measures appear appropriate, we note an additional overflow incident was reported at the end
of September, indicating that the new septic tank needs more regular monitoring and the
frequency of emptying increased if needed.
No hydrocarbon spills were reported or observed on site in this period.
2.1.4 Workforce
Table 3 provides the workforce statistics for this reporting period.
Table 3: Workforce statistics

Month Local Thatta district Other Sindh Outside Sindh Total
July 156 137 128 100 521
August 148 137 128 100 513
September 31 8 83 256 377
Source: GSL monthly progress reports
Notes: Local refers to workers who live within 20km of the project
As of September 2019, there were 300 BMC workers and 77 Siemens workers. The proportion
of local workers has decreased from 31%2 in the previous reporting period to only 8% in
September 2019 due to the lower demand for low-skilled workers for the remainder of the
construction period.
2.1.5 Grievances
2.1.5.1 Workforce
Nine grievances were lodged between July and September 2019, mainly pertaining to lack of
availability of safety helmets and safety boots3, inadequate toilet cleanliness, and overflowing
sewage systems. Actions taken to address such grievances included delivery of the requested
PPE by the BMC’s procurement team, installation of a new septic tank as referenced in section
2.1.3 above, and inclusion of inspection checklists at each toilet for daily cleaning. It appears
that the grievance mechanism and register is functioning effectively.
Going forward, we continue to recommend that a brief analysis of worker grievances be

included in the monthly progress reports with commentary on the number of grievances logged,
the number of grievances open/closed, duration of resolution, categories/themes of grievances,
and whether there have been any repeat grievances.
2
The project target for local employment is 30%.
3
Recommendations on provision and inspection of PPE supplies have been included in the corrective action plan.
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2.1.5.2 Community
There were no community grievances received in this period. Previous issues related to dust
and drainage appear to have been resolved and have not reoccurred. The community grievance
mechanism appears to be functioning adequately and community members interviewed were
aware of how to raise grievances with the project. Community requests and comments are now
being logged separately from grievances, among which three were received in this period
concerning requests for more local employment. As community members interviewed were
aware of the upcoming end of the construction phase and the nature of the roles required in the
operations phase, requests for local recruitment are expected to decrease in the coming months
accordingly.
A brief analysis of community grievances received should be included in the monthly progress
reports.
2.1.6 Performance categorisation

Risk categories for identified EHSS non-compliance issues have been determined according to
the criteria in Table 4 below.
Table 4: Performance Categorisation

Risk category Description
Low GIIP is generally being implemented and environmental or social aspect is being
managed appropriately. There is a good understanding of the issues and risk based on
the information gathered and the sensitivity of the receptor. Can be addressed within
the proposed project plans or schedule. Where additional mitigation measures are
required, these are likely to be easily implemented.
Medium GIIP is not generally being implemented. E&S aspect is or is likely to result in risk to
people or the environment, and/or meeting permitting or meeting international
requirements. There may be a lack of understanding of the issues and impact. Further
investigation required may have an effect on the project plans or schedule as the
information gaps or mitigation measures required are more complex. Will be escalated
to a high-risk item if evidence is not provided in the subsequent LTA monitoring visit
that adequate effort and resources have been applied to address risk.
High Ineffective or no mitigation and management measures are being implemented.
Environmental or social aspect involves long term or permanent environmental or
social damage that is considered unacceptable or creates significant reputational risk
for the project. There is a lack of understanding of the issues and impacts. Significant
amount of attention to E&S management and monitoring is required to address this
issue. Mott MacDonald will not be able to advise lenders to disburse loan finances
whilst high risks remain unaddressed and related corrective actions are open.
Critical A previously identified high risk that has not been sufficiently corrected for more than
two quarterly reporting periods, or a risk in which irreversible, adverse impact has
occurred. Mott MacDonald will not be able to advise lenders to disburse loan finances
whilst critical risks remain unaddressed and related corrective actions are open.
Source: Mott MacDonald
These risk categories have been applied to the elements detailed in the EHSS compliance
review presented in Table 5 to Table 9 below.
These tables cross-reference to the corresponding remedial measures proposed in the

corrective action plan (CAP) presented in section 3. The photographs referenced therein are
provided as figures in Appendix A. Additionally, opportunities for improvement/recommended
actions are listed in Table 11.
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2.2 EHSS compliance review
Table 5: EHSS management (PS1)

EHSS topic # Parameter Discussion/findings Category CAP
reference
Assessment and 1.1 Environmental permits The permit matrix has been revised with the requested details including validity periods and associated Low NA
management of and regulatory control conditions.
environmental
1.2 Environmental The project is engaging Alvus ESG Consulting4 to develop an operational environmental and social Low NA
and social risks
management system management system (ESMS), environmental and social management plan (ESMP) and associated sub-
and impacts
and management plans one month prior to start of operations. Several construction ESMPs were identified as requiring further
plans revisions in the first construction monitoring report, including the corporate social responsibility management
plan (CSRP), ecological management plan and security plan; as further detailed in the ESAP (Table 12 in
section 4.1). However, given the current final stages of construction these revisions should be made to their
operational counterparts instead.
1.3 Organisational The project’s HSE organisational capacity currently comprises the following key individuals: Low NA
capacity and site EHS ● GSL– full-time E&S manager, full-time HSE officer, full-time deputy HSE manager and two CLOs
personnel
● BMC – full time HSE manager supported by three HSE officers and an HR manager
● Siemens and subcontractors – one EHS manager and one EHS officer at Siemens; one EHS manager
and two EHS officers at subcontractors
Current organisational HSE, HR and community liaison management levels appear adequate. The
operational E&S capacity will be reviewed in the next monitoring report.
1.4 Site environmental GSL indicated that gaps identified in the internal E&S audit of May 2019 have been addressed, though no Low L2
and social monitoring tracker is being maintained to measure progress. The next E&S audit was conducted in August 2019 as per L18
and reporting the quarterly schedule for the audits.5 The audit appears to have sufficient information and highlights gaps
L20
relating to housekeeping and waste management, traffic procedures, supplies at the medical clinic, lack of
PPE usage by some workers, and emergency drills. An audit specification should be developed to ensure
that all parameters to be evaluated during future audits are specified, and a tracker developed to record
progress on corrective actions identified.
Monthly progress reports prepared by GSL include reporting on E&S parameters, however, the following
detail identified in the previous monitoring report is still not included:
● H&S incidents: follow-up actions taken to avoid recurrence (we understand these details are included in a
separate deviation report, however a summary should also be included in the monthly progress reports)
● Community grievances: include brief analysis of grievances6, or indicate if none have been received in this
period
● Worker grievances: include brief analysis of grievances, or indicate if none have been received in this
period
4
The external consultant previously employed to develop the construction phase ESMPs
5
As construction is near completion, the subsequent E&S audits will be undertaken biannually during operations.
6
ie number received, status, general themes, recurring grievances
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EHSS topic # Parameter Discussion/findings Category CAP

reference
1.5 Stakeholder Ad-hoc communication between the project’s social team and local community members have taken place in Low NA
engagement and this period, in addition to planned meetings to disclose local recruitment and project progress as indicated in
community grievance the engagement log. Training was provided by the GSL E&S manager to the CLO team7 in this period, to
mechanism (CGM) raise their awareness on the requirements of the stakeholder engagement plan (SEP) and community
grievance mechanism (CGM). Weekly meetings between the CLOs and the project’s E&S manager are also
being held to discuss relevant issues and maintain regular communication between parties. No grievances
were received in this period, though some requests for employment were received and addressed.
1.6 Community No community investment activities have taken place to date. The project has developed a CSRP which acts Medium M4
investment as a framework, setting out the principles and intention to develop a full CSRP. The CLOs are developing
the CSRP in collaboration with local non-governmental organisation (NGO) partner National Rural Support
Programme (NRSP)8 and through consultations with local governmental authorities. We will review the plan
and the needs assessment completed as part of it during the next monitoring period.
1.7 Local content As outlined in section 2.1.4, local employment currently comprises 8% of the total workforce in comparison to Low O2
its target of 30%, due to the lower demand for low-skilled workers and overall decreasing workforce as
construction activities reduce. While recognising that a more skilled labour force is required for the
operations phase, opportunities to maximise local content should still be taken where possible and local
skilled workers encouraged to submit their CVs for relevant roles.
Table 6: Labour and working conditions (PS2)

EHSS topic # Parameter Discussion/findings Risk CAP
ranking reference
Labour and 2.1 Training Regular training and daily toolbox talks are being provided to all workers on relevant topics. No specific Low NA
working conditions concerns or gaps have been identified concerning delivery of training on site.
2.2 Working conditions The internal labour audit conducted by GSL in September 2019 identified several key gaps in labour Medium M5
and terms of practices on site as listed below:
employment ● Several workers employed by BMC, its subcontractor and Siemens do not have written contracts, and the
provisions are often not explained in detail to illiterate workers.
● Some BMC workers receive their monthly salaries within the first 15 days of the month, exceeding the limit
of the first seven days of the month as established by applicable local laws.
● BMC is not providing sufficient notice or termination letters before termination of contracts
● Minor differences occur between paid salaries and provincial minimum wage requirements for some
workers.
Other gaps identified include the following:
● Lack of comprehensive HR induction that explains contents of the HR policy to workers.
● Compliance with labour laws, regulations or standards are not referenced in the contracts between BMC
and its subcontractors.
7
Comprising one male and one female CLO
8
NRSP was founded in 1991 and is active in 72 Districts in Pakistan, focusing on issues of rural development and poverty. https://nrsp.org.pk/about.html
402705 | 02 | CM | November 2019

ranking reference
● BMC is only providing workers with subsidised lunches, despite free lunches for workers being required as
per the project labour and working condition management plan.
GSL has identified appropriate corrective actions for these gaps which BMC and Siemens are in the process
of addressing. The contractors’ implementation of these actions and GSL’s follow-up with the contractors will
need to be monitored going forward.
The timesheet records that were previously noted to show some personnel working in excess of 60 hours per
week appear to have been caused by erroneous data being entered into the sheets. Workers interviewed
generally indicated working eight hours per day with infrequent overtime. Worker facilities such as toilet
provision and shaded rest areas appeared adequate.
2.3 Occupational health As outlined in Section 2.1.1, OHS reporting procedures in place are adequate. The on-site clinic is now open Low L13
and safety (OHS) on those Sundays when works are being carried out, and the project is conducting monthly reviews of the L19
treatment log to identify any work-related trends. Most cases concern minor ailments such as headaches and
back pain.
Although the grievances previously received about a lack of PPE and the first aid incident caused by
inadequate safety shoes in this period appear to have been addressed, the provision of adequate PPE for all
workers must continue to be monitored as part of the regular labour audits, to verify ongoing compliance with
OHS requirements.
Some of the fire extinguisher signage on the site was faded and worn as shown in Figure 10 of Appendix A,
and should be replaced.
2.4 Workers’ grievance Grievance boxes are placed around the site and at the workers accommodation, although workers tend to Low NA
mechanism lodge grievances verbally which are subsequently logged in the grievance register. Grievances received are
detailed in section 2.1.5.1.
2.5 Workers’ unions The right for freedom of association is explicitly detailed in worker contracts. We understand that workers on Low NA
the project are not members of a trade union.
2.6 Contractor A formal programme of labour and HR audits is now in place with the first comprehensive audit conducted in Low NA
monitoring September 2019 to verify contractual conditions, grievance mechanism, working hours and overtime,
payment, and benefits and entitlements. The findings of the audit are discussed in row 2.2 above. Weekly
contract and HR inspections are also being undertaken by GSL.
2.7 Workers’ Accommodation is provided within the nearby town of Gharo for workers that do not live locally. The Low L15
accommodation accommodation viewed on the visit comprised eight-bed bunk rooms that were generally clean with an L16
adjoining shower room. The accommodation is inspected routinely by the project company using a checklist
adapted from the IFC/EBRD Guidance on Workers’ Accommodation. Completed checklists identify minor
non-compliances but no details exist on how they are addressed; a corrective action tracker should therefore
be developed.
Improvements are needed to address aspects including broken bathroom doorknobs, windows with no
privacy curtains, insufficient or broken lighting, lack of soap in bathrooms and lack of hot water in the shower.
However, as the houses are being rented from a third-party landlord up to the end of the construction phase,
we recognise there is limited capacity and time to implement such improvements at this point9. Our
recommended actions therefore reflect these constraints.
9
On-site accommodation will be built to house operations workers
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ranking reference
The on-site worker accommodation as well as the worker accommodation plan will be reviewed in the
operations phase to verify that regular accommodation checklists and appropriate follow-up are being
conducted, and that general facilities and housekeeping are in line with best practice.
Table 7: Pollution prevention and abatement (PS3) and biodiversity management (PS6)
ranking reference
Pollution 3.1 Air quality and dust Community grievances relating to dust generation were raised earlier in the construction phase and the Low NA
prevention and project now routinely sprays water on the access track to supress dust.
resource efficiency Quarterly emissions monitoring at the generators is being conducted by a SEPA-approved external
consultant. No issues have been identified to date.
3.2 Noise No community grievances have been lodged concerning construction noise and no issues were noted during Low NA
our site visit. No internal or external noise monitoring is taking place or is it considered to be required.
3.3 Water consumption The project meets its water needs via deliveries to site by a licensed third-party company and tracks its Low NA
consumption in the resource use register.
3.4 Wastewater, Domestic wastewater generated through ablution facilities is currently collected within a septic tank and Low L17
drainage and water collected from site by a licensed contractor. Certificates show that the contractor uses appropriate, SEPA-
discharge approved facilities for wastewater disposal.
Numerous instances of the septic tank overflowing were previously recorded by the project. In late
September 2019, a new tank was installed and is being emptied by a licensed contractor every four days.
While the corrective measures appear appropriate, one additional overflow incident was reported at the end
of September, indicating that the septic tank needs more regular monitoring and more frequent emptying if
needed.
The project is not discharging any water to the environment.
3.5 Hazardous and Suitable facilities have been developed to handle hazardous and non-hazardous waste streams, although Low L13
non-hazardous some of the waste storage area signage was observed to be worn and faded and in need of replacement. L14
waste management Storage of the general and plastic waste needs to be improved, as waste is kept in a haphazard manner with
no containers (refer to Figure 7 and Figure 8 in Appendix A). Clinical waste is currently stored externally in an
unlocked bin as shown in Figure 2 of Appendix A; this should be stored within the medical facility in a secure,
locked container.
3.6 Hazardous Diesel is being stored and dispensed from a large tank within a shaded and bunded area. No spills were Low NA
materials handling observed during the monitoring visit. The drip trays that were previously identified as being inadequate have
and storage been replaced with appropriate alternatives as shown in Figure 9 of Appendix A, and refresher training was
delivered on hazardous material handling practices and spill response in September 2019.
3.7 Energy/resources Electricity for project facilities is currently generated by static and mobile diesel generators. Fuel and energy Low NA
used (diesel usage is tracked via the resource use register.
generator on site,
etc)
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ranking reference
3.8 Spoil disposal and The project is not generating large volumes of spoil and any spoil is utilised to level the ground within the site. Low NA
sediment
management
Biodiversity 3.9 Protection of The project does not currently have a specific ecological management plan as the replanting strategy will be Low L4
biodiversity developed as part of the operational ESMS. This is not considered to represent a high risk due to the habitats
present on site, however the strategy will be reviewed for adequacy in the next monitoring period. The project
does not require the use of pesticides.
Table 8: Community health, safety and security (PS4)

ranking reference
Community health 4.1 Community health No community H&S incidents have been reported to date. Awareness raising sessions were held with local Low NA
and safety and safety villages during the reporting period to discuss construction-related H&S risks and road traffic safety.
Community members interviewed indicated that they have not experienced issues related to project traffic
movements and were provided sufficient updates from the CLOs on the risks. We have not identified any
significant concerns due to the location of villages in relation to the project.
Emergency 4.2 Emergency No emergency drills were held in August 2019, but the monthly drills have commenced in September. Low NA
preparedness and preparedness and Sufficient information on relevant emergency procedures was provided to local community members as part
response response of the awareness-raising sessions described in row 4.1 above.
Traffic and transport 4.3 Traffic and transport Flag men were observed along the external and internal site access road to help manage the traffic flow, Low NA
movement and direction of site vehicles. The project provides transport for workers between the site and
Gharo town as well as to the worker accommodation. These vehicles are subject to routine inspection. The
project has conducted toolbox talks on road safety including safe driving practices.
Security/influx 4.7 Security No security incidents have been recorded to date. A permanent armed security presence is provided by Mars Low NA
management Security Guards, a subcontractor to BMC. The contract specifies the provision of 29 guards comprising ex-
military as well as trained civilian personnel. The guards are permitted to use force where necessary and
have received training on the Voluntary Principles on Security and Human Rights.
An appropriate site entry/exit register is being maintained and unauthorised access to the site compound is
prohibited.
Table 9: Land acquisition and involuntary resettlement (PS5), indigenous peoples (PS7) and cultural heritage (PS8)
ranking reference
Consultation 5.1 Consultation The project has implemented a SEP and undertakes a range of planned and ad-hoc consultation meetings. Low NA
The project maintains an engagement log summarising activity undertaken to date.
Compensation for 5.2 Compensation for No persons will be displaced or experience economic loss as a result of the project. Low NA
displaced displaced The project purchased a series of land plots from private vendors with details included within a land memo.
persons/economic persons/economic An additional memo was provided in this reporting period demonstrating that a large-scale landowner
loss loss
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ranking reference
whose land values were previously in question had also received compensation in excess of the valuations.
We consider that the land purchases were conducted appropriately at this point.
Grievance 5.3 Grievance mechanism No grievances have been received in relation to land acquisition aspects. Please refer to Table 5 for Low NA
mechanism commentary on the community grievance mechanism.
Indigenous 5.4 General The project company conducted a screening exercise and no indigenous peoples were identified within the Low NA
Peoples project zone of influence.
Cultural heritage 5.5 Chance finds The project has a cultural heritage and chance find management procedure in place, protection of heritage Low NA
procedure features is also mentioned in the site induction. The training register shows that toolbox training on the
chance finds procedure has been delivered. No finds have been encountered on site to date.
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3 Corrective Action Plan
3.1 Overview
The CAP is provided in Table 10 and provides the corrective actions identified from our EHSS
compliance review presented in section 2.2. Recommended completion deadlines are based on
the date of issue of this report.
Those actions that have been closed in the reporting period have been highlighted grey and will
be removed from future reporting.
Table 11 includes our recommendations/actions for opportunities to improve project

performance and add value. These do not reflect non-compliances. In this period, one new
recommendation was identified.
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3.2 Corrective Action Plan
Table 10: Corrective Action Plan

# Date Topic Description of action Responsibility Completion Timeframe Status (November 2019)
evidence/KPI
Critical risks
NA as currently no critical risks identified
High risks
NA as currently no high risks identified
Medium risks
M1 07/08/19 Site environmental and social Develop and implement an E&S audit GSL ● Audit specification Within one month Closed - superseded by action L18
monitoring and reporting specification. ● Completed audit report
M2 07/08/19 Stakeholder engagement and Formalise a schedule of weekly meetings GSL ● Confirmation of meeting Within one month Closed
community grievance mechanism between the CLOs and the GSL EHS team frequency and agenda Meeting minutes and photos were provided of the
(CGM) to keep the CLOs apprised of construction weekly meetings being held between the CLOS and
activities and the project informed of any the GSL E&S manager, to discuss relevant
pertinent community issues. community issues.
M3 07/08/19 Stakeholder engagement and Deliver a training session to the CLO team GSL ● Completed training Within one month Closed
community grievance mechanism to disseminate the requirements of the register Evidence of the applicable training given to the CLOs
(CGM) stakeholder engagement plan (SEP) and was provided.
community grievance mechanism (CGM).
M4 07/08/19 Community investment Develop a full CSRP as required by ESAP GSL ● NGO engagement letter Prior to COD In progress
action 1.1. Engage an external party to ● Completed needs The CLOs are developing a CSRP in collaboration
undertake a needs assessment prior to assessment with local NGO partner NRSP10 and through
COD which will inform the strategy for consultations with local governmental authorities. We
community investment. will review the plan and the needs assessment
completed as part of it in the next monitoring period.
M5 07/08/19 Working conditions and terms of Review the BMC process of logging worker GSL ● Summary of review Within one month In progress
employment hours and payment calculation in response findings The internal labour and HR audit conducted in
to the input errors noted. ● Completed labour and September 2019 identified several key gaps in labour
Carry out a labour and HR audit of all HR audit practices on site. GSL has identified corrective actions
contractors including parameters such as: which BMC and Siemens are in the process of
contracts, payslips, timesheets, working addressing. The contractors’ implementation of these
hours, amount of overtime, overtime rates actions and GSL’s follow-up with the contractors will
and payment. This should include worker need to be monitored going forward, particularly
interviews to verify understanding of concerning the lack of written contracts, delayed
contractual conditions, grievance salary payments and lack of sufficient notice before
mechanism, working hours and overtime, termination of contracts given the ongoing
payment, and benefits and entitlements. demobilisation phase.
M6 07/08/19 Occupational health and safety (OHS) Ensure adequate medical provision when BMC/GSL ● Confirmation of medical Within one month Closed
works are taking place on Sundays. provision where works Evidence was provided of medical services available
Issue eye protection to the workforce. are taking place on on Sundays when works are taking place, and a
Conduct a weekly review of the clinic Sundays treatment log tracking the work-related medical
treatment log to identify any work related ● Confirmation that safety incidents. Workers confirmed that safety glasses have
OHS trends. glasses have been been issued.
issued
● Inclusion of treatment
log review in site
inspection checklist
M7 07/08/19 Waste water, drainage and water Review adequacy of the septic tank BMC/GSL ● Septic tank review Within one month Closed
discharge capacity, frequency of uplifts and take any findings and summary Based on a review of septic tank operations
action as necessary. of action taken. undertaken in September 2019, a new tank was
Arrange for appropriate treatment and uplift ● Details of how installed later that month and is being emptied every
of contaminated soils. contaminated soils four days. While the corrective measures appear
Verify that the contractor is using an have been dealt with. appropriate, one additional overflow incident was
appropriate facility to dispose of the waste ● Confirmation of reported at the end of September, indicating that the
water. sewerage disposal new septic tank needs more regular monitoring and
facilities.
10
NRSP was founded in 1991 and is active in 72 Districts in Pakistan, focusing on issues of rural development and poverty. https://nrsp.org.pk/about.html
402705 | 02 | CM | November 2019

evidence/KPI
the frequency of emptying increased if needed. This is
reflected under action L17.
Certificates of disposal indicate that the third-party
contractor is using facilities approved by the SEPA.
M8 07/08/19 Hazardous materials handling and Replace damaged drip trays. Drip trays BMC/GSL ● Photographic evidence Within one month Closed
storage should be large enough to prevent spills of adequate drip trays Adequate drip trays were observed on site, with
being released to the environment during ● Training register refresher training provided to workers on hazardous
refuelling. material handling in September 2019.
Deliver refresher training on hazardous
material handling practices and spill
response.
M9 07/08/19 Community health and safety Hold awareness raising sessions with the GSL ● Photographic evidence Within one month Closed
nearby villages to inform them of and updated The information disclosure log shows group
construction related health and safety risks engagement log discussions held in several local villages to discuss
and emergency procedures. ● Summary report of H&S matters related to construction and road traffic.
Conduct an emergency drill. emergency exercise
Low risks ●
L1 07/08/19 Environmental permits and regulatory Include details such as validity periods and GSL ● Revised permit matrix Within one month Closed
control any associated conditions within the permit The permit matrix has been revised accordingly.
matrix for ease of compliance monitoring.
L2 07/08/19 Site environmental and social Include the following detail within the GSL ● Revised monthly Within one month Open (overdue)
monitoring and reporting monthly progress reports: progress report The monthly reports have not been updated to include
● H&S incidents: follow-up actions taken to the additional information recommended in the
avoid recurrence (we understand these previous monitoring report.
details are included in a separate
deviation report, however a summary
should also be included in the monthly
progress reports)
● Community grievances: include brief
summary of grievances ie number
received, status, general themes, repeat
grievances, or indicate if none have
been received in this period
● Worker grievances: include brief
summary of grievances ie number
received, status, general themes, repeat
grievances, or indicate if none have
been received in this period
L3 07/08/19 Workers’ accommodation Address aspects identified during BMC/GSL ● Completed Within two months Superseded by action L16
accommodation inspection. Provide accommodation Lockable storage and mattresses are available.
lockable storage and mattresses for all checklists Accommodation inspection checklists continue to
residents. ● Photographic evidence highlight gaps but no information is provided on how
of storage and and when the gaps have been addressed. An
mattresses additional corrective action concerning
accommodation has been identified under L16.
L4 07/08/19 Protection of biodiversity Develop an approach to replanting and BMC/GSL ● Replanting strategy Within two months Open (overdue)
implement on site. ● Evidence of The replanting strategy will be developed as part of
implementation the operational ESMS. This will be reviewed in the
next monitoring period.
L5 07/08/19 Traffic and transport Conduct a toolbox talk on road safety BMC/GSL ● Toolbox talk register Within one month Closed
including safe driving practices. The training register describes the toolbox talks held
on road safety.
L6 07/08/19 Traffic and transport Provide additional flag men along the site BMC ● Confirmation that Within one month Closed
access track. additional flag men Flag men were observed on the access track in
have been stationed on sufficient numbers as requested.
the access track
L7 07/08/19 Chance finds procedure Conduct a toolbox talk on the chance find BMC ● Updated training Within one month Closed
procedure. register Toolbox talks were held on the chance find procedure
in early October.
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evidence/KPI
L8 07/08/19 Stakeholder engagement and Log requests and comments separately GSL ● Completed comment Within one month Closed
community grievance mechanism from community grievances. and request log A separate comment and request log is now being
(CGM) maintained.
L9 07/08/19 Local content Communicate changing skill requirements GSL ● Updated engagement Within one month Closed
to local communities and invite local skilled log The engagement log indicates that community
workers to submit CVs for available meetings were held on this topic.
opportunities.
L10 07/08/19 Traffic and transport Conduct routine inspection of project GSL ● Completed inspection Within one month Closed
vehicles including worker transport log Completed inspection checklists with appropriate
vehicles. information were provided.
L11 07/08/19 Stakeholder engagement and Revise the engagement log to include a GSL ● Revised engagement Within one month Closed
community grievance mechanism column with any actions arising from each log The engagement log has been revised accordingly.
(CGM) engagement so that they can be tracked as
open or closed.
L12 07/08/19 Compensation for displaced Provide verification on the composition of GSL ● Updated land memo Within one month Closed
persons/economic loss land purchased from Mr. Dhedhi, ie area A land memo was provided demonstrating that an
considered to be of low and high value. additional large-scale landowner also received land in
excess of the valuations.
L13 22/11/19 Health and safety signage Update worn and faded site signage, GSL ● Clear signage for fire Within one month New
including for fire extinguishers and labels extinguishers and
for different waste areas. waste areas
L14 22/11/19 Waste storage Improve waste storage by adding GSL ● Waste storage areas Within one month New
containers for storage of general and with containers for
plastic waste; and provide a secure and disposal of general and
locked container for clinical waste in the plastic waste
medical facility. ● Secure and locked
storage container
provided in the medical
facility for clinical waste
L15 22/11/19 Worker accommodation Maintain a tracker of gaps identified in the GSL ● Accommodation Within one month New
monthly accommodation checklists, and corrective action tracker
how and when they have been addressed. developed and
maintained
L16 22/11/19 Worker accommodation Make the following improvements to GSL ● Photos of Within one month New
worker accommodation: improvements made to
● Repair broken bathroom doorknobs accommodation
facilities
● Fix lightbulbs and establish additional
light source in each room eg lamps
● Provide soap in all bathrooms and wash
basins
● Install privacy curtain for room on the
ground floor
L17 22/11/19 Wastewater, drainage and water Conduct a monthly review of septic tank BMC/GSL ● Monthly reports with Ongoing New
discharge overflow incidents, assessing the overview of overflow
adequacy of the current emptying incidents
frequency.
L18 07/08/19 Site environmental and social Develop and implement an E&S audit GSL ● Audit specification Within one month New - in progress
monitoring and reporting specification for operations. An internal audit was undertaken in August 2019 by
GSL’s E&S manager and deputy EHS manager, and
covered appropriate aspects. However, an audit
specification should be developed, specifying all
parameters to be evaluated during future audits.
L19 22/11/19 OHS Include review of provision of adequate GSL ● Labour audits with Ongoing New
PPE for all workers as part of labour audits review of PPE supplies
including through review of PPE supplies included
and interviews with workers.
L20 22/11/19 Site environmental and social Develop and maintain an audit tracker to GSL ● E&S corrective action Ongoing New
monitoring and reporting record progress on corrective actions tracker developed and
identified as part of the internal E&S audits maintained
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Table 11: Opportunities for improvement/recommended actions

# Date Description of action Responsibility Completion evidence/KPI Timeframe Status (November 2019)
O1 07/08/19 Provide signage and training to encourage energy and water efficiency GSL ● Photographic evidence of Within one month Closed
use. signage Signage has been posted and
● Training log training provided on energy and
water efficiency use.
O2 22/11/19 Continue local recruitment and content activities in operations phase, GSL ● Records of local procurement Ongoing in operations phase New
including sending project employment opportunities to local communities and recruitment efforts
and encouraging applications from skilled workers, and exploring
opportunities to procure from local suppliers.
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4 Environmental and Social Action Plan
4.1 Overview
The project ESAP is included in the finance agreement. We have reviewed the ESAP actions
that remained open in the previous monitoring period and provide the compliance status in
Table 12. Some actions comprise multiple components; for clarity, the text has been underlined
in the status column where there are outstanding actions remaining.
The ESAP actions that were previously closed have been removed from this table for ease of
reference; and those closed in this period are highlighted grey and will be removed from
subsequent reporting.
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Table 12: Environmental and Social Action Plan

Item Measure and/or corrective action Responsibility Deliverable/ Required Status (November 2019)
No. measurement completion date
General environmental, social governance (ESG) management
0.1 Develop a permit tracking matrix that lists all required permits for GSL ● Permitting matrix ● Prior to Closed
construction and operations, the status of the permit, the date it identifying necessary construction The permit matrix has been updated to
needs to be renewed, and the responsible party. The permit permits, status, and include the applicable validity periods.
tracking matrix should be a living document that is updated at least required renewal dates
quarterly.
● Updated permitting ● Updated matrix Closed
matrix identifying quarterly As above.
necessary permits, throughout
status, and required construction
renewal dates
Performance Standard 1: Assessment and management of environmental and social risks and impacts
1.1 Develop and implement an ESMS and ESMP for the project. The GSL ● ESMS, ESMP and sub- ● One month prior to In progress
construction ESMP should fulfil the requirements from the plans for operations COD COD is expected to take place on
environmental and social impact assessment (ESIA), GIIP and this 24 November 2019. The operational
ESAP. The ESMP must show responsibilities of all relevant parties ESMPs are currently in development
and persons, including contractors. Prepare construction sub-plans and will be ready for review in late
covering but not limited to the following themes: November. The Sponsor has indicated
● Occupational health and safety (OHS) (including reporting that these ESMPs will incorporate the
protocol for reporting fatalities or serious accidents to the following gaps previously identified in
lender). The incident/accident log should also be revised to the construction ESMPs:
include rows for corrective and preventive actions. ● OHS plan: This plan does not
● Contractor management include a mechanism for reporting
● Corporate social responsibility serious incidents to lenders or flash
reports in response to serious
● Security management plan and security workers’ code of
incidents.
conduct
● CSR plan: This plan is currently the
● Hazardous materials
framework for the full CSR plan
● Erosion and sediment which should be finalised as a
● Training (on E&S matters such as pollution prevention, health priority. A needs assessment should
and safety, labour rights, first aid and disease prevention to all be undertaken prior to COD and the
staff at a level appropriate to their job description) plan updated to reflect the
● Incidents and non-conformance management stakeholder engagement activities
● Supply chain management undertaken, and progress made
towards developing the full
● Community health and safety programme11.
● Workers’ accommodation management plan ● Security management plan (SMP):
● Water management The SMP is generally adequate
however it does not include details
11
At a minimum we would expect the key areas that are being considered (eg health, education, livelihoods), the budget and the outcomes of stakeholder consultation
402705 | 02 | CM | November 2019

● Pesticide use and management of travel arrangements for guards at
● Ecological management night or what protocols are in place
for how male guards interact with
● Reporting
women.
● Chance find procedure
● Hazardous materials storage
● Revised traffic management plan (to include appropriate routes procedure: The procedure states
and identify any other measures to minimise impacts on the local that hazardous materials will not be
communities. Additionally, the TMP should include requirements stored on site unless necessary, and
for appropriate signage, speed limits and any timing restrictions that they should ideally be brought
on movements ie night-time.) onto site daily in their required
Other plans identified as needed following the development of a amounts. This is not feasible and
social impact assessment (SIA), refer to row 1.5 of this ESAP. presents its own risks12. The
Revise the current sub-plans including: air; noise; traffic; and waste operational procedure should
management for the construction phase and set out the project include details on how hazardous
specific roles and responsibilities, training requirements, reporting materials will be stored and
and auditing structure. managed.
● Water management: Resource
efficiency measures and measures
to protect local drainage channels
should be addressed.
● Ecological management: The
replanting approach should be
provided.
● Reporting: The ESMS does not
clearly detail the reporting
requirements to lenders.
● Traffic management plan (TMP):
The TMP does not include specific
routes to minimise community
impacts13.
● Worker accommodation plan (WAP):
A WAP specific to the on-site
accommodation to be provided
during the operations phase is
required.
1.2 Emergency Preparedness and Response Plan (EPRP), including: GSL ● EPRP for operations ● One month prior to In progress
● A table of contents COD The following gaps identified in the
● Scope and objectives should be improved and include list of construction EPRP should be
procedures which should be appended to the plan such as addressed in the operations plan:
12
Having visited site, only necessary hazardous materials are being stored and transferred when required rather than daily.
13
However the associated risk is considered to be low as the only logical route to the site is via a national highway, coastal highway and site access track.
402705 | 02 | CM | November 2019

evacuation (this may be triggered for several emergency ● None of the incident categories
incidents), fires, structural collapse and entrapment, spills, listed in the ESAP item have been
natural disasters eg floods, landslides, lightning/storms etc, included in the EPRP. Section 3 of
action and demonstrations, and accidents the plan includes these types of
● Roles and responsibilities should be clearly defined risks in a bulleted list, but some are
not expanded further in the plan.
● A section on emergency equipment and facilities (clarify
ambulance provision) ● The emergency procedure chapter
is quite difficult to follow. The plan
● A section on inspection of equipment
would benefit from flow charts to
● Assembly points show the process and steps.
● Emergency response team and emergency contact ● Muster points should be clearly
● Requirement for emergency evacuation drills indicated.
● Training ● Emergency and CLO contact details
● Communication of the EPRP should be updated with phone
● Contact details for local communities in case of emergency numbers.
● Reporting, documentation and investigation
● Information on the plan reviews
Consult with local emergency services to understand capacity and
include review of capacity in EPRP.
1.3 Update project environmental and social impact assessment GSL ● NTS ● End of November Closed
(ESIA) to include a SIA based on local level baseline data and 2018 The project website has been updated
consultation with affected communities. Potential social impacts to with an adequate, brief non-technical
be assessed or robustly scoped out include: an accurate summary sheet, available in English
assessment of job creation; local procurement and recruitment and Sindhi.
avoiding exacerbation of conflict; skills development provision;
influx due to the high number of jobs in the construction phase;
interaction between the workforce and local communities; land use
change; physical and/or economic displacement impacts;
ecosystem services; changes to the sense of place (cumulative
with other projects in the area); increased inequality; impacts to
vulnerable groups; inclusion of vulnerable groups in project
benefits; community health, safety and security risks; management
of expectations around (non-)provision of electricity to local villages
as a result of the project, corporate social responsibility (CSR) and
long term employment during operations.
The updated ESIA should also:
● Include a section on stakeholder engagement carried out to
support the process and how the project has addressed
concerns arising during engagement activities.
● Contain mapping of inhabited houses around the project or other
potential receptors.
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● Consider baseline issues such as local tensions, conflict,
vulnerability, indigenous peoples and gender.
● Carry out focus groups to gather the required baseline
information.
● Incorporate methods to include women should be incorporated in
the baseline data collection process.
● Contain a high-level assessment of the transmission line and
provide details such as project parameters, the parties involved
and land acquisition.
Include a cumulative impact assessment (CIA) comprising
evaluation of valued environmental and social components (VECs),
any cumulative impacts on them, and mitigation measures; as well
as the cumulative impact on the sense of place arising from the
development of multiple projects with high brick walls around them.
1.5 Stakeholder Engagement planning and management GSL ● Revised SEP a) to c) Prior to Closed
● Redevelop the SEP to make it project specific, realistic, and ● Stakeholder financial close (by a) Closed
tailored to the needs of affected communities and vulnerable engagement log first week of January
b) Closed: The information
groups. 2019) disclosure log has been updated
● Project website link
● Prepare and maintain stakeholder engagement log detailing ● Website up to date to include a column with actions
dates, locations, attendees, purpose, content of meetings and arising from each engagement so
concerns/points raised to monitor how the project is managing its that they can be tracked as open
response to concerns raised by stakeholders. or closed.
● Set up project website and populate it with useful information for c) Closed
stakeholders, including workers. d) Prior to Closed
● Publish lender-approved draft and final version of key project construction (by The project website now provides
documents on the website (eg NTS, ESIA, SEP). February 2019) information and the NTS in Sindhi.
Performance Standard 2: Labour and working conditions
2.2 Implement monitoring of contractors’ and subcontractors’ GSL Monthly monitoring reports Ongoing throughout In progress
management of the workforce. construction and As required by the CAP, an internal
operations labour and HR audit was undertaken in
September 2019. Further actions
required based on the outcomes of the
audit are detailed in CAP action M5.
2.5 a) Carry out a documented supply chain review process for OHS, GSL ● Outcomes of supply Both prior to financial In progress
child labour, forced labour or human rights issues in the primary chain review close (first week of An appropriate procurement/supply
supply chain. ● Supply chain January 2019) chain management policy was
b) Develop supply chain management policy. management policy provided. To complement this policy, a
procedure should also be established
describing the process in place to
identify and remedy cases of non-
402705 | 02 | CM | November 2019

compliance with E&S principles within
the primary supply chain.
Completed supplier questionnaires
have been provided that are
considered to be a sufficient review of
the project’s primary supply chain.
Performance Standard 4: Community health, safety and security
4.1 a) Develop a worker code of conduct to govern the behaviour of GSL/Contracto ● Evidence of clarification ● First quarter of Closed
workers in and around the local communities. rs sessions and signed construction and The workers’ code of conduct (CoC) is
b) Provide clarification sessions upon which workers sign up to the forms indicating that ongoing displayed on site and attendance lists
code of conduct upon recruitment. workers will comply with were provided, showing that toolbox
c) Develop plans to provide leisure activities or transport to a requirements of the code talks were held to disclose the CoC to
nearby town or city for workers on rest days to avoid negative of conduct workers.
interaction with local communities.
Performance Standard 5: Land acquisition and involuntary resettlement
5.1 In a stand-alone document, provide: GSL ● Land acquisition review ● Prior to contracting Closed
● A detailed analysis of land acquisition impacts from all project and supplementary A land memo and maps provided
features (solar farm, substation, construction laydown area, information as identified indicate the price paid per acre to
worker camp, office buildings, road, etc) landowners, showing that all
● An explanation of the methodology used for calculating land and landowners were paid in excess of the
asset values, evidence of engagement with land owners, valuated price. As requested, an
negotiations and grievance mechanism additional land memo was provided
demonstrating that an additional large-
● Evidence that land markets or other opportunities for the
scale landowner also received
productive investment of sales income exist – this can be done
compensation in excess of the
by proving that other land is available for purchase nearby (an
valuations.
estate agent’s report showing that there is a healthy and active
land market in the area and that land is available) ● External monitor’s report ● First quarter of Closed
● Evidence that the sellers were provided with fair compensation construction A declaration from an external monitor
based on prevailing market values (documentation from a who met all landowners stating that
certified real estate evaluator). informed consent was reached was
External monitor to meet with all landowners to help establish previously provided, in addition to the
whether there was 'informed consent' to sell land to the Project. Try sale deeds signed by all landowners.
to establish proof that the sellers knew fully what the land was
worth prior to selling and were happy to sell without coercion of any
kind. This will be done in consultation with Gharo and will be
cognisant of trying to avoid claims for additional payments,
provided fair prices were paid.
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5 Appendices
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A. Photographs
Figure 1: View of site Figure 2: Organic and clinical waste storage
Figure 3: Site clinic Figure 4: HSE bulletin board on site
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Figure 5: Emergency response plan notice Figure 6: HSE signage on site
Figure 7: Haphazard general waste storage area Figure 8: Plastic waste storage area without
containers
402705 | 02 | CM | November 2019

Figure 9: Diesel generator located on drip tray Figure 10: Faded signage for fire extinguisher
Figure 11: Demarcation of spoil heaps on internal Figure 12: Fire extinguisher on site with up-to-
roads date tag
402705 | 02 | CM | November 2019

Figure 13: Emergency response details at worker Figure 14: Worker accommodation rooms
accommodation
Figure 15: Lockers at worker accommodation Figure 16: Accommodation bathroom
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Figure 17: Drinking water supply at Figure 18: Complaint box at accommodation
accommodation
Figure 19: Accommodation canteen Figure 20: Wash basin at accommodation
402705 | 02 | CM | November 2019

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Gharo Solar - Mott Macdonald - HSE Audit-2

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Gharo 50MW Solar PV Plant

Second Environmental and Social Construction

T +44 (0)1273 365000

Gharo 50MW Solar PV Plant

Mott MacDonald Limited. Registered in

Issue and Revision Record

Revision Date Originator Checker Approver Description

Document reference: 402705 | 02 | CM

Information class: Standard

402705 | 02 | CM | November 2019

2 EHSS performance and compliance review 11

3 Corrective Action Plan 20

4 Environmental and Social Action Plan 25

402705 | 02 | CM | November 2019

Environmental and social performance review

402705 | 02 | CM | November 2019

Corrective action plan

● Medium risk: two (both in progress from previous reporting period)

Environmental and social action plan compliance

402705 | 02 | CM | November 2019

● International Finance Corporation (IFC) Performance Standards (PSs) (2012)

1.2 Project description and construction status

402705 | 02 | CM | November 2019

1.3 Project participants

● Gharo Solar Ltd (GSL): the sponsor

402705 | 02 | CM | November 2019

2 EHSS performance and compliance

2.1 EHSS performance statistics

2.1.1 Health, safety and environmental performance statistics

Table 2: HSE statistics

2.1.2 H&S incidents

402705 | 02 | CM | November 2019

2.1.3 Environmental incidents

No hydrocarbon spills were reported or observed on site in this period.

Table 3: Workforce statistics

Going forward, we continue to recommend that a brief analysis of worker grievances be

402705 | 02 | CM | November 2019

2.1.6 Performance categorisation

Table 4: Performance Categorisation

These tables cross-reference to the corresponding remedial measures proposed in the

402705 | 02 | CM | November 2019

2.2 EHSS compliance review

Table 5: EHSS management (PS1)

402705 | 02 | CM | November 2019

EHSS topic # Parameter Discussion/findings Category CAP

Table 6: Labour and working conditions (PS2)

EHSS topic # Parameter Discussion/findings Risk CAP

EHSS topic # Parameter Discussion/findings Risk CAP

402705 | 02 | CM | November 2019

EHSS topic # Parameter Discussion/findings Risk CAP

Table 8: Community health, safety and security (PS4)

402705 | 02 | CM | November 2019

EHSS topic # Parameter Discussion/findings Risk CAP

402705 | 02 | CM | November 2019

3 Corrective Action Plan

Table 11 includes our recommendations/actions for opportunities to improve project

402705 | 02 | CM | November 2019