Human Rights Impact Assessment

Nur Bukhara Solar PV

Nur Bukhara Solar PV

Environmental & Social Impact Assessment (ESIA):
Volume IV – Environmental & Social Management
Plan (ESMP)

Consulting Firm: Prepared for:

Juru Energy Ltd Masdar Clean Energy

Suite 1, One George Yard, London, Khalifa City A,
United Kingdom, EC3V 9DF Abu Dhabi, UAE, P.O. Box 54115
www.juruenergy.com www.masdar.com
ESIA: Volume IV – ESMP
Nur Bukhara Solar PV and BESS

Document Information

Project Name Nur Bukhara Solar PV and Battery Energy Storage System (BESS

Document Title Environmental & Social Impact Assessment (ESIA): Volume IV –

Environmental & Social Management Plan (ESMP)

Juru's Project Reference UZB-MAS_ESIA for Solar PV_Bukhara

Client Masdar Clean Energy

Juru's Project Manager Nicola Davies

Juru's Project Director Jushkinbek Ismailov

Document Control

Version Date Description Author Reviewer Approver

1.0 02 June 2023 Final draft ESIA: Volume IV – Various Marianne Nicola
ESMP (draft for Client Lupton Davies
comment)

2.0 26 June 2023 Final ESIA: Volume IV – ESMP Various Marianne Nicola
Lupton Davies

3.0 31 August Final ESIA: Volume IV – ESMP Various Marianne Nicola

2023 (for disclosure, updated to Lupton Davies
include Lender comments)

Disclaimer

The Environmental & Social Management Plan (the This report has been prepared exclusively for Masdar.
"Report") has been prepared by Juru Energy. Whilst the Masdar makes no representation or warranty, express
information contained in the Report reflects the current or implied, as to the accuracy or completeness of the
status, Juru Energy makes no representation or information set forth in this Report. Masdar has not
warranty, express or implied, as to the accuracy of the independently verified any of the information
information set forth in this Report and accepts no contained in this Report and accept no liability
liability for any information that may have been whatsoever for any information, misstatement or
misstated or omitted. omission contained therein. The Report remains
Masdar property

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Table of Contents
List of Abbreviations 5

1 Introduction 8

1.1 Background 8
1.2 Scope of the ESMP 8
1.3 The objective of the ESMP 9
2 Project Overview 11

2.1 Project location 11

2.2 Project components 16
2.3 Development and construction activities 18
2.4 Land take 18
2.5 Project schedule 19
3 Legal and Regulatory Framework 20

3.1 Applicable environmental and social standards 20

4 Organizational Framework 21

4.1 Overview 21
4.2 Involved entities 21
4.3 Project Company and PMC E&S team 22
5 Environmental and Social Management 24

5.1 Environmental and social risk identification and assessment 24

5.2 Subcontractor management - prequalification 24
5.3 Environmental and social management system (ESMS) 25
5.4 Project Company ESMS 25
5.5 EPC - ESMS 26
5.6 HR policy 27
5.7 Environmental and social management plans 28
6 Mitigation and Management Requirements 37

6.1 Introduction 37
6.2 Mitigation and management requirements – design and procurement phase 38
6.3 Mitigation and management requirements - pre-mobilization phase 40
6.4 Mitigation and management requirements – construction 44
6.5 Mitigation and management requirements – operation phase 54
7 Monitoring and Reporting 56

7.1 Meetings 56
7.2 Inspections and audits 56
7.3 Reporting 56
7.4 Monitoring 57
7.5 Document control 66
8 Stakeholder Engagement 66

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9 Grievance Mechanism 67

10 Budget 67

Indicative costs are provided in Table 10 67

11 Annex A: Project E&S Policy 70

Table of Figures

Figure 1: Project location ....................................................................................................................... 12

Figure 2: Project boundary .................................................................................................................... 13
Figure 3: Project layout .......................................................................................................................... 14
Figure 4: Project receptors and bird's eye view of the Project site.................................................... 15
Figure 5: Overview of the PV process (compiled from IFC, 20157) ..................................................... 16
Figure 6: PV panels ................................................................................................................................. 17
Figure 7: PV tracking system and inverters (Single-axis trackers follow the sun east-to-west on a
single point. NEXTracker) ....................................................................................................................... 17
Figure 8: Battery container (internal) .................................................................................................... 17
Figure 9: Typical container BESS (external): ......................................................................................... 17
Figure 10: Project organogram.............................................................................................................. 23

Table of Tables

Table 1: Summary of topics addressed in the ESMP ............................................................................... 8

Table 2: Current anticipated development schedule .......................................................................... 19
Table 3: Environmental and Social Management Plans...................................................................... 29
Table 4: Mitigation and management requirements – design and procurement phase ................ 38
Table 5: Mitigation and management requirements – pre-mobilisation phase .............................. 40
Table 6: Mitigation and management requirements – construction................................................. 44
Table 7: Mitigation and management requirements – operation ..................................................... 54
Table 8: Monitoring and reporting obligations - construction ........................................................... 58
Table 9: Monitoring and reporting obligations - operation ................................................................ 64
Table 10: Indicative costs for PC / PMC implementation and supporting activities - construction 67

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List of Abbreviations
Acronym Definition

A&E Accident and Emergency

ABIS Amu-Bukhara Irrigation System

ADB Asian Development Bank

AIS Air-Insulated Switchgear

AOI Area of Influence

BESS Battery Energy Storage System

BMP Biodiversity Management Plan

CC Civil Code

CEMP Construction Environmental Management Plan

C-ESMP Construction Environmental and Social Management Plan

CHS Community Health and Safety

CLO Community Liaison Officer

COD Commercial Operation Date

E&S Environmental and Social

EBRD European Bank for Reconstruction and Development

EHS Environment, Health and Safety

EIA Environmental Impact Assessment

EPC Engineering, Procurement and Construction

EPRP Emergency Preparedness and Response Plan

ESIA Environmental and Social Impact Assessment

ESMP Environmental and Social Management Plan

ESMS Environmental and Social Management System

ESP Environmental and Social Policy

EU European Union

FC Financial Close

GBVH Gender-Based Violence & Harassment

GIIP Good International Industry Practice

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Acronym Definition

GM Grievance mechanism

H&S Health and Safety

HMWWP Hazardous Materials, Waste and Wastewater Management Plan

HR Human Resources

IFC International Finance Corporation

ILO International Labour Organization

IUCN International Union for Conservation of Nature

JE Juru Energy

LWCMP Labor and Working Conditions Management Plan

LC Land Code

LILO Line-in Line out

LRP Livelihood Restoration Plan

LV Low voltage

MCC Makhalla Community Council

MNR Ministry of Natural Resources

MSDS Material Safety Data Sheets

MV Medium voltage

NSR Noise Sensitive Receptors

NTP Notice to Proceed

NTS Non-Technical Summary

O&M Operations and Maintenance

O-ESMP Operations Environmental and Social Management Plan

OHS Occupational Health and Safety

OHSMP Occupational Health and Safety Management Plan

OHTL Overhead Transmission Line

OMMP Operational Management and Monitoring Plan

PIT Project Implementation Team

PPE Personal Protective Equipment

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Acronym Definition

PR Performance Requirement

PV Photovoltaic

ROW Right of Way

SanPiN Sanitary Regulations and Norms of Uzbekistan

SMP Security Management Plan

SCRP Site Clearance and Rehabilitation Plan

SEP Stakeholder Engagement Plan

SMzP Site Mobilization Plan

SWID State Committee for Sericulture and Wool Industry Development

SWMP Solid Waste Management Plan

SSMP Subcontractors and Suppliers Management Plan

TrMP Training Management Plan

TTMP Traffic and Transportation Management Plan

UNCCD United Nations Convention to Combat Desertification

UNESCO United Nations Educational, Scientific and Cultural Organization

UNFCCC United Nations Framework Convention on Climate Change

WAMP Worker Accommodation Management Plan

WBG World Bank Group

WMP Water Management Plan

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1 Introduction

1.1 Background

The Nur Bukhara Solar Photovoltaic (PV) Project with a capacity of 250 MWA and a 63
MW/126 MWh Battery Energy Storage System ("Project"). The Project includes a 30 m line-
in-line-out (LILO) overhead line (OHTL) to connect the Project's new substation to an
existing OHTL (requiring an upgrade to approximately 300m of existing OHTL). There are
no associated facilities for the Project as defined by Lender standards. The Project will
support Uzbekistan to:

● Add 250 MW of power supply to the national grid.

● Reduce energy dependence on carbon-based fuels.

● Meet renewable energy targets.

● Reduce greenhouse gas emission rates.

1.2 Scope of the ESMP

The following topics are addressed in the ESMP for the construction, operation and
decommissioning phases.

Table 1: Summary of topics addressed in the ESMP

Environment Social (including labour)

● Climate resilience ● Employment (including local content policy)

● Supply chain (construction) (construction, operation and
● Air quality - dust/fugitive decommissioning)
(construction and decommissioning) ● Labour welfare (including the welfare of
● Noise (construction and sub-contractors, casual workers and
decommissioning) migrant workers) (construction, operation
● Site clearance, including habitat and decommissioning)
clearance (construction and ● Supply chain management (construction,
decommissioning)) operation and decommissioning)
● Hazardous material handling ● Occupational health and safety
(construction, operation and (construction, operation and
decommissioning) decommissioning)
● Waste (including hazardous waste) ● Community health and safety specifically
(construction, operation, and traffic safety, GBVH, and communicable
decommissioning) diseases) (construction, operation, and
● Wastewater discharges decommissioning)
(construction and decommissioning) ● Security and security force management
(construction, operation and
decommissioning)

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Environment Social (including labour)

● Water use and water efficiency ● Emergency preparedness (construction,

(construction and operation, and operation and decommissioning)
decommissioning) ● Accommodation management (as
● Traffic and transportation applicable) following IFC / EBRD guidance
(construction and decommissioning) note: Accommodation: Processes and
● Pollution prevention (e.g., Standards (Guidance Note by IFC and EBRD,
discharges to groundwater or land) 2009 (construction)
(construction and decommissioning)

1.3 The objective of the ESMP

The objective of this environmental and social management plan (ESMP) is to provide a
framework to safeguard the environment and community against activity which may
cause harm or nuisance, as identified during the ESIA process. The ESMP includes the
following:

● Requirements for an environment and social management system (ESMS) aligned

with ISO14001 to address impacts on sensitive receptors and related potential E&S
impacts due to Project activities as identified in the ESIA, including requirements
for:

o key staffing and responsibility

o organization and responsibilities

o training and awareness

o emergency procedures and response.

o record keeping

o performance monitoring, reporting and auditing

o subcontractor management.

● Objectives for the Project Company and Engineering, Procurement and

Construction (EPC) Contractor ESMS.

● Mitigation measures to reduce or reverse adverse impacts and enhancement

measures that increase or distribute more equitably positive impacts.

● Monitoring activities for the construction and operation phases along with
implementation arrangements that detail responsibility, schedule targets, key
indicators and budget needs.

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The ESMP is structured as follows:

● Chapter 2: Project overview

● Chapter 3: Regulatory framework

● Chapter 4: Organizational framework

● Chapter 5: Environmental and social management requirements

● Chapter 6: Mitigation and management requirements

● Chapter 7: Monitoring and reporting

● Chapter 8: Stakeholder engagement

● Chapter 9: Grievance mechanism

● Chapter 10: Budget

● Annex A: Project E&S Policy

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2 Project Overview

2.1 Project location

The Project will be located on a site allocated by the Ministry of Energy through a
competitive auction process and covers approximately 649ha of land in the Alat District
of the Bukhara region in the southwest of the Republic of Uzbekistan. The Site is 24 km
southeast of Alat City, approximately 25 km northwest of the border with Turkmenistan.
The Site is flat and is surrounded by the ABIS canal to the North, South and East. The
regional road R78 runs alongside the Site's northern boundary, and there are drainage
channels and ponds approximately one kilometre to the West of the Site. The Khamza 1
substation is located 1 km to the North of the Site, and the Khamza 2 substation is located
1 km to the South of the Site.

The Project area is located within the Kyzylkum desert ecoregion, and the land is
intermittently used for pasturing purposes. The following figures show where the Project
is located in Uzbekistan (Figure 1), the Project site (Figure 2), how the solar panels will be
laid out on the Site (Figure 3) and key receptors (Figure 4).

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Figure 1: Project location

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Figure 2: Project boundary

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Figure 3: Project layout

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Figure 4: Project receptors and bird's eye view of the Project site

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2.2 Project components

Photovoltaic (PV) power uses solar panels to convert sunlight into electricity by converting
solar radiation into DC electricity. PV inverters convert the direct current that will be
transformed into alternating current, and the transformers (located in the Power
Stations) will raise the voltage from Low Voltage (LV) to Medium Voltage (MV). Then, the
energy generated will be conducted through an underground medium voltage (MV)
network of 35 kV to the 35/220 kV Substation. An overview of the process is illustrated in
Figure 5 below.

Figure 5: Overview of the PV process (compiled from IFC, 20157)

The main components of the Project are:

● 513,582 PV modules (half-cut monocrystalline silicon technology).

● Single-axis tracker, inverters, and transformers.

● Lithium-Ion (Li-ion) battery energy storage system (BESS) consisting of four 40ft
containers.

● Underground cabling system.

● 35/220 kV substation (new).

● 30 m 220 kV line-in-line-out (LILO) connection to an existing overhead

transmission line (OHTL), "Karaku'l 500 SS" - "Hamza-2 SS" from the Project's
Substation.

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● Dismantling and rebuilding approximately 300 m of existing OHTL to enable the

new LILO connection (including one new tower).

● On-site buildings, including an operational control centre, office, welfare facilities,

security guard house, storage facilities and stores.

● New access from Highway R78.

● New internal access roads.

● Site drainage system.

Figure 6 to Figure 9 illustrate some of the main project components.

Figure 6: PV panels Figure 7: PV tracking system and inverters (Single-axis

trackers follow the sun east-to-west on a single point.
NEXTracker)

Figure 8: Battery container (internal) Figure 9: Typical container BESS (external) 1:

1
https://energycentral.com/c/cp/large-battery-energy-storage-systems

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2.3 Development and construction activities

The following activities will be undertaken to develop the Project:

● Site mobilization

● Civil works

● Procurement and transportation of equipment

● Equipment installation

● Waste generation and disposal

● Commissioning

● Operation and maintenance (O&M)

● Decommissioning

Construction of the Project will be confined to the Project site, access road and existing
OHTL right of way (ROW), and the duration of the works will be approximately 12 to 16
months. The main construction activities are site clearance (rocks, unused historical
utilities, vegetation), establishing vehicle access to the Site, civil works (OHTL, substation
and main Site), equipment delivery of PV panels and supporting infrastructure), BESS
installation and commissioning.

Site establishment and civil works are expected to take three months, followed by eight
months for installation and a further three months for commissioning. Work on-site is
planned to start at the end of 2023. A material storage area will be established within the
main site boundary. At this time, the water needed for the construction process is
expected to be tankered to the Site from a municipal water source in Alat City. Cement
will be obtained from a nearby batching plant approximately one kilometre from the Site.
The laydown areas and some worker accommodations are expected to be constructed
within the Project limits.

The Project may have some on-site accommodation, but contractors will also use off-site
accommodation provided it meets Lender standards and adheres to the management
and measures stipulated in the ESIA.

The expected lifetime of the PV infrastructure is 25 years (at least), and ten years for the
BESS. At the end of its lifetime, options will be considered to replace, repair or remove all
infrastructure from the Site.

2.4 Land take

The total estimated land take is 649 ha. The land plot allocated to the Project is owned by
the State Committee for Sericulture and Wool Industry Development (SWID) for an
indefinite time period. One farmer has a lease agreement to farm 20 ha of land at the

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southern section of the Project, outside the site boundary. Up to eight households from
Kirilishon community (I.e., the settlement that is located opposite to Project site near
Khamza 1 substation) and one herder with formal land right granted by the entity that
administers the land for SWID "Alat Qoraqolchilik" LLC to graze that land have also been
identified. A 70 m setback has been agreed upon with the Alat District Sanitary
Epidemiological Wellbeing Department between the edge of the canal to the West of the
Site and the site boundary.

2.5 Project schedule

The planned development schedule is set out in Table 2 below:

Table 2: Current anticipated development schedule

Activity Date
Scoping March 2023 (completed)
Consultation on national EIA Late April 2023 (completed)
Submission of national EIA 05 May 2023 (completed)
Submission of draft ESIA End of May 2023
Lender disclosure period Aug-23
Finalise ESIA (including public consultation
comments, Lender comments and ongoing Aug-23
studies)
EIA Approval Aug-23
Financial close Oct-23
Finalise LRP compensation obligations (pre-
Aug-23
construction)
Finalize Project Company and EPC-ESMS (pre-
Sep-23
construction)
Early Work program Aug-23
Limited Notice to Proceed to EPC (site
Sep-23
clearance and preparation works)
Construction Start (inverter Skid foundation,
Nov-23
civil works, BESS)
1st Module Delivery at Site Feb-24
Tracker and Module Mechanical Works February 2024 to August 2024
Electrical works (switchyard and MCR) February 2024 to August 2024
Commissioning Jul-24
Early generation Aug-24
Commercial Operation Date (FC plus 12
Dec-24
months)
25 years (2024 to 2049) (BESS to be renewed
Expected Lifetime
after 10 years)

Note: For clarity, early site mobilization includes the construction of the temporary site facilities, telecommunication equipment,
worker welfare facilities, road improvements and site fencing. Works on the solar field (including clearance, levelling or any earthworks
in the solar field) or any work on the energy production infrastructure of the PV plant is not considered early site works.

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3 Legal and Regulatory Framework

3.1 Applicable environmental and social standards

The Project must comply in all respects with the following:

● Uzbekistan Laws and statutes for management of the environment

(Environmental Law), land rights, labour and health and safety, including
requirements of international and regional environmental agreements,
conventions and treaties as ratified by Uzbekistan (such as International Labour
Organization (ILO) conventions and core labour standards)

● IFC Performance Standards (2012) and supporting Guidance Notes (GNs)

● ADB's Safeguards Policy Statement (2009)

● ADB Social Protection Strategy (2001)

● ADB Access to Information Policy (2018)

● ADB Gender and Development Policy (1998)

● World Bank Group (WBG) General Environment, Health, and Safety (EHS)
Guidelines

● Good International Industry Practice (GIIP)

● Masdar E&S requirements including E&S policy, Human Resources Policy, Code of
Ethics, Policy Against Bribery and Corruption, Recruiting Policy, Supply Chain
(Procurement) Policy, and Communication Policy

● Permit conditions: requirements stipulated by the Environmental Statutory

Authority responsible for issuing the environmental permit for the Project, and
which are a condition under which the environmental permit is issued (pending as
of June 2023).

The Project must also comply with the following:

● Environmental and Social Impact Assessment (ESIA), including Non-Technical

Summary, Stakeholder Engagement Plan, Livelihood Restoration Plan,
Environmental and Social Management and Monitoring Plan, Biodiversity
Management Plan, and Environmental and Social Action Plan

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4 Organizational Framework

4.1 Overview

This chapter summarises the roles and responsibilities for environmental, health and
safety (EHS) management structures and Project responsibilities proposed for this
Project. The Project construction will be awarded to a winning EPC contractor under an
open tender process for the development and construction phase ("EPC Contractor"). At
the commercial operation date (CoD), the Project and all operations and maintenance
(O&M) obligations will transfer to the responsibility of the Project Company.

4.2 Involved entities

● Masdar: was the developer of the Project before the establishment of the Project
Company, and they are a shareholder in the Project Company. They will be
overseeing E&S compliance and reviewing reports to be submitted to Lenders.

● Nur Bukhara Solar PV LLC FE (the Project Company or the Company): is the entity
responsible for the development of the Project and is the owner of the Project and
will be the key entity signing the loan agreement with the Lenders and for
overseeing the implementation of E&S requirements as defined here.

● Project Management Company (PMC): the PMC is appointed by the Company and
is involved throughout the construction phase to ensure that the EPC Contractor
is adhering to the technical project specifications required. For this Project, [Insert
name] is appointed as the PMC.

● EPC Contractor: is responsible for preparing the detailed design and layout of the
Project; supply of the material and equipment (PV Panels, inverters, etc.);
construction of the Project and its various components (PV Panels, internal roads,
building infrastructure, etc.). The roles and responsibilities required by the EPC
contractor are outlined in Section 5. The EPC Contractor's management team will
be responsible for ensuring sub-contractor performance, including:

o Adequately informing sub-contractors of the requirements of the Project

ESMP (this document) and the Contractor ESMS and ensuring they can
adhere to them.

o Making sub-contractors fully aware of all the E&S and occupational health
and safety (OHS) and labour rights requirements that must be adhered to
through back-to-back provision contract documentation.

o Identifying the procedures for monitoring and reporting sub-contractor

performance and integrating this into overall site reporting requirements.

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● Subcontractors: Subcontractors are identified as any entity (international or local)

appointed directly by the EPC Contractor through contractual arrangements to
undertake construction activities within the Project area or provide a specific
service for the Project. This could include but not be limited to the appointment of
civil, electrical and mechanical subcontractors or services related to cleaning,
water supply, waste collection, etc.

● Lender Environmental and Social Advisor (LESA): Is assigned by the Lender(s) to

provide different services, including E&S due diligence of the Project prior to
financial close, supervision and monitoring of the construction and operational
phases.

● Ministry of Natural Resources (MNR): Is the main regulating body of state

administration on environmental protection issues.

4.3 Project Company and PMC E&S team

The following personnel will be deployed by the Project Company, PMC and EPC (also
depicted in Figure 10. All roles are site based unless stated otherwise. The Project
developer (Masdar) will obtain approval from the Lenders for all job descriptions and
provide all CVs for all listed personnel below to Lenders for review and comment:

Project Company:

• HSSE Manager
• CLO
• HR Manager (not site based and may be Masdar position). The PC team will
be supported by biodiversity specialist from Masdar.

PMC (MAI Mecados Aires):

• HSSE Manager

EPC:

• HSSE Manager
• International & Local E&S Advisor
• Deputy EHSS Manager
• E&S Supervisors (ratio of 1:40 estimated to be up to seven)
• Community Liaison Officer
• HR/procurement manager

The EPC is also required (as per the ESIA) to appoint a suitably qualified person to oversee
the ecological requirement of the BMP and to employ a local archaeologist to supervise

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excavations works (per the requirements of the institute of Archaeology) 2, (see also
mitigation and management requirements below).

Figure 10: Project organogram

2
The identification of a suitably qualified archaeological team can be undertaken with the support of, or in coordination
with, the local authorities/mahalla or khokimiyat.
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5 Environmental and Social Management

5.1 Environmental and social risk identification and assessment

The Project Company has developed the documentation listed below during the
environmental and social impact assessment (ESIA) process in order to comply with the
environmental and social standards and environmental and social laws listed in the Legal
and Regulatory Framework section (section 3):

● National Environmental Impact Assessment (EIA) dated 19 May 2023 (Stage 1

decision received, Stage 2 decision received 22 August 2023).

● Nur Bukhara Environmental and Social Impact Assessment (ESIA), dated August
2023, including:

o Volume I: Non-technical summary (NTS) (this document)

o Volume II: Environmental and social impact assessment (ESIA)

o Volume III: Technical appendices

o Volume IV: Environment and social management plan (ESMP)

o Volume V: Stakeholder engagement plan (SEP), including grievance

mechanism

o Volume VI: Livelihood restoration plan (LRP)

5.2 Subcontractor management - prequalification

The Contractor selection process will require demonstration of the following

competencies:

● ISO 14001 certified environmental management system (EMS) or equivalent.

● ISO 45001 or equivalent certified health and safety management system (HSMS).

● Publicly disclosed Health and Safety Policy Statement.

● Publicly disclosed Environmental Policy Statement.

● Human Resource Policy.

● Statements relating to any H&S convictions, reportable incidents or environmental

breaches.

● Information on supplier qualification related to labour (forced labour, child labour,

occupational health and safety and biodiversity)

● Experience implementing requirements of IFC E&S Policy on projects.

The EPC Contractor must coordinate, supervise and monitor all its Subcontractors and
ensure that safe practices are implemented, and work is conducted safely and in strict
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compliance with the Owner ESMS (see section 5.3 below). The EPC Contractor must
prepare a Subcontractor Management Paln defining its approach to managing the E&S
performance of their contractor, subcontractors, and other third parties during the
various phases of the project. The contractor management approach will be consistent
with the general principles described within IFC Good Practice. Managing Contractors’
Environmental and Social Performance and will include a program for audit of E&S
performance of EPC contractors and subcontractors, specifying frequency of audit (at
least monthly during construction phase), reporting and roles and responsibilities.

The EPC must verify the subcontractor's environmental and social safety management
system. Personnel from subcontractors will be treated the same way as those from the
EPC Contractor.

The EPC Contractor must be able to evidence to the Owner of the subcontractor's ESHS
qualification, which must be based on demonstrated capability in ESHS management.
Risks and hazards associated with the subcontractor's work must be identified and
addressed in the EPC Contractor ESMS.

5.3 Environmental and social management system (ESMS)

The Project Company will adopt the ESMS structure of Masdar and apply it at the Project
level in the form of a construction ESMS (cESMS) and operational ESMS (oESMS). The
Project Company and the EPC Contractor (and subcontractors) must separately establish
and maintain an environmental and social management system (EPC-ESMS) that
addresses the requirements of this ESMP as follows:

1. Establish and maintain an ESMS and health and safety management system
(HSMS) developed in the manner of international frameworks quality,
occupational health and safety and environmental management such as ISO
14001 and ISO 45001 that is proportionate to their role on the Project and the
impacts identified in the ESIA.

2. Establish a Human Resources (HR) Policy that fully complies with IFC PS2, ILO core
labour standards, and national labour laws and regulations and explicitly
addresses issues including but not limited to code of conduct; recruitment;
compensation and benefits; official working hours; leave; termination; collective
bargaining; child labour; forced labour and overtime to be adopted/reflected in
the practices of ALL parties working on the Project.

5.4 Project Company ESMS

An overview of the Masdar construction ESMS (cESMS) is provided below. The Project E&S
Policy is provided in Annex A and will be updated for issue prior to construction. The E&S
Policy includes commitments to comply with IFC and ADB requirements. This cESMS

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includes the required measures to manage the impacts and risks outlined in the ESIA and
ESMP and other E&S compliance obligations outlined above, ensuring negative impacts
are avoided/reduced to the greatest extent possible and positive impacts are maximized.
A list of the requirement management plans under the cESMS is provided below.

During the operation phase, the Project Company oESMS will be updated along the same
structure to comply with the operational E&S requirements defined in this ESMP. The key
E&S management activities to be addressed in the oESMS are:

● Develop the operational ESMP (O-ESMP).

● Perform E&S-related training for Project Company staff.

● Monitor the performance of the Project against statutory requirements and the
agreed objectives and targets.

● Conduct inspections and audits against the ESMP.

● Oversee maintenance works (risk method statements).

● Liaise with stakeholders on E&S matters.

● Report to Lenders

5.5 EPC - ESMS

The EPC-ESMS means the EPC Contractor's environmental, social, health and safety
management system (including policies, plans and procedures) for managing compliance
with Environmental and Social Law and Project Environmental and Social Standards, and
which is certified to ISO 14001 and ISO 45001 and shall include each of the documents
listed in Table 3. The separate set of MPs to be prepared by the EPC will be prepared
based on the cESMS by adding the Project-specific details (rather than totally from
scratch). Responsibilities for different plans under the cESMS are defined in Table 3.

The EPC Contractor will appoint the following site based key roles to support the
implementation of E&S measures for the Project at the site level. The EPC Contractor will
be required to nominate one (1) EPC Contractor E&S Manager that is supported by two
(2) Senior EPC Contractor HSE Manager, as well as one (1) EPC Contractor HR Manager,
one (1) EPC Contractor accommodation HSE Officer and one (1) EPC Contractor HSE
Officer for every 50 workers. The developer and EPC are also required to have an on-site
community liaison officer (CLO).

Subcontractors will also have their own on-site E&S staff. Subcontractors with less than
20 workers shall deploy a non-dedicated E&S Manager. Subcontractors with more than
20 workers shall deploy a dedicated HSE Officer and an additional HSE Officer for each
additional 50 workers deployed onsite.

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The EPC Contractor's management team will be responsible for ensuring sub-contractor
performance, including:

● Adequately informing sub-contractors of the requirements of the Project ESMP

(this document) and the Contractor C-ESMP and ensuring they can adhere to the
requirements.

● Making sub-contractors fully aware of all the E&S and occupational health and
safety (OHS) and labour rights requirements that must be adhered to through
back-to-back provision contract documentation.

● Identifying the procedures for monitoring and reporting sub-contractor

performance and integrating this into overall site reporting requirements.

The EPC-ESMS must include organization charts for the roles set out above. In addition
to Key ESHS Persons, the EPC Contractor must provide site based HSE officers to
establish, maintain, monitor, report on and enforce the EPC ESMS at a ratio of 1:40 (HSE
officers: Subcontractors). These HSE officers shall be appropriately qualified for this work
and have the authority to issue instructions and take protective measures to prevent
harm, accidents, and environmental incidents.

This EPC-ESMS shall include the EPC Contractor's system manuals and related source
documents, including policies, management programs and plans, procedures,
requirements, performance indicators, responsibilities, training, and periodic audits
designed to maintain compliance with the Environmental and Social Standards,
Environmental and Social Laws and ISO 14001/45001. This EPC-ESMS shall be prepared
by the EPC Contractor and delivered to the Owner (and Lender) before mobilization for
acceptance and approval.

The EPC Contractor must develop a permit tracking mechanism/register to outline all
necessary licenses, consents and permits in line with Environmental and Social Laws,
including timing and responsibility for obtaining under the responsibility of the EPC
Contractor.

5.6 HR policy

The EPC Contractor will also provide human resources (HR) policies and plans
demonstrating compliance with legal and other requirements stipulated in this ESMP (e..
g IFC PS2). The policies and plans will include detailed information on workforce
induction, information on rights, child and forced labour, equal opportunity, migrant
workers, promotion of local employment opportunities, labour unions, worker
accommodation requirements, provision for retrenchment plans, security personnel,
influx management etc. The EPC Contractor will ensure that core labour requirements
align with legislation and other requirements and are cascaded down to contracting

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chains to all subcontractors and suppliers of core materials. The EPC Contractor must be
able to evidence this transfer of responsibilities down the contracting chain.

5.7 Environmental and social management plans

The following plans will be developed for the Project to comply with the requirements of
the ESIA for the construction phase. Relevant stand-alone supporting plans will also be
developed for the operations phase. Plans likely to be retained and updated for the
operational phase are highlighted in the table below.

Plans shall be implemented by all involved counterparts, including the Developer, the
Company, EPC Contractor, O&M subcontractor, subcontractors, and others. However, the
implementation of each management plan is led by one designated party (Company or
EPC/O&M Contractor), as specified in the table below. The Project Company ESMS
(construction and operation) and the EPC-ESMS (construction) will be designed to
implement the requirements of these plans. ESMS implementation tools, including forms,
templates, checklists, and other documentation, will be used to implement the Project
requirements. The Lenders will review and approve the Developer and EPC ESMS
standalone topic specific plans as described below and to be developed under the
respective ESMS prior to construction.

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T a ble 3: E n vir o n m e n t al an d S o ci al M a n a g e m e n t Pla n s

Reference Name Overall Description / Objective Lead Implementation 3 Relevance

in ESMS (phase)
REF 00 S i t e M o b ili z a ti o n P l a n T h e Sit e M o b iliz ati o n Pl a n ( S M z P ) i s p r e p a r e d a s p a r t of E P C C o ntr act or C o n str u cti o n

(S M z M P) t h e E S M S t o d r i v e c o m p l i a n c e w i t h E & S o b li g a t i o n s

d u r i n g t h e i niti al sit e m o b ili z a ti o n p h a s e ( sit e cl e a r a n c e ,

c o n s t r u c ti o n o f t e m p o r a r y sit e f a ciliti e s, e t c.). T h e P l a n

d e s c ri b e s t h e E & S p r o c e d u r e s a n d pl a n s t o b e

i m p l e m e n t e d b y t h e E P C C o n t r a c t o r d u ri n g t h e sit e

m o b iliz a ti o n p h a s e t o e n s u r e all ris k s a n d im p a c t s a r e

p r o p e rl y m a n a g e d a n d h a n d l e d d u ri n g t hi s i niti al st a g e.

For clarity, early site mobilization includes the construction

of the temporary site facilities, telecommunication
equipment, worker welfare facilities, road improvements
and site fencing. Works on the solar field (including
clearance, levelling or any earthworks in the solar field) or
any work on the energy production infrastructure of the PV
plant is not considered early site works.
REF 01 E S M S M a n u al T h e E S M S d riv e s c o m plia n c e wit h E & S o blig ati o n s f or Co m pany - ES MS C o n str u cti o n

t h e c o n str u c ti o n p h a s e b y i d e n tif yi n g: 1. t h e o v e r all EPC - ES MS O p e r ati o n

st r u c t u r e a n d o u tli n e f o r t h e E S M S i m p l e m e n t e d f o r D e c o m m i s si o ni n g

t h e c o n s t r u c ti o n p h a s e b y all i n v ol v e d c o u n t e r p a r t s,

incl u di n g t h e D e v el o p er, c o m p a n y, c o ntr a cto r s a n d

o t h e r s; 2. E & S p olici e s a n d c o m m i t m e n t r e q u ir e m e n t s;

3
This column identifies the lead responsible entity. Compliance is ultimately under the responsibility of the Company. The EPC and its contractors and suppliers shall provide the relevant
input for the documents and plans implemented by the Company. All parties shall comply with all relevant ESMS requirements.

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Reference Name Overall Description / Objective Lead Implementation 3 Relevance

in ESMS (phase)
3. Str u ct ur e of th e k e y E & S pr o c e d u r e s a n d pla n s to b e

i m p l e m e n t e d t o e n s u r e all ri s k s a n d i m p a c t s a r e

p r o p e rly m a n a g e d; a n d 4. t h e i n stit uti o n al fr a m e w o r k

a n d r e s p o n s i b iliti e s t o e n s u r e t h a t s u c h p r o c e d u r e s

a n d pl a n s a r e i m p l e m e n t e d eff e cti v el y a n d e f fi ci e n tl y,

e. g., i n s p e c ti o n s, a u d i ti n g, tr ai ni n g, i nt e r n al

c o m m u n i c a ti o n, d o c u m e n t a ti o n c o n t r ol et c . i n cl u di n g

te m pl at e s.

REF 01a P er mits R e gist er O u t li n e s t h e s t a t u s , tim e l i n e s a n d r e s p o n s i b iliti e s f o r C o m p a n y or EP C to take C o n str u cti o n

P r oj e ct p e r m its, in cl u di n g t h o s e sti p ul at e d b y t h e t h e le a d a s d efi n e d i n t h e O p e r ati o n

E n vir o n m e n t al St at ut o r y A u t h o rit y r e s p o n s i bl e f or E P C c o ntr a ct wit h ot h er D e c o m m i s si o ni n g

iss ui n g t h e e n vir o n m e nt al p er mit t o b e i m pl e m e nt e d e n tity s u p p o r ti n g a s

f o r t h e P r oj e c t. T h e s e a r e c o n d i ti o n s u n d e r w h i c h t h e n e e d e d.

e n vir o n m e n t al p er mit is iss u e d, ot h er Pr oje ct

c o n str u cti o n p e r m it s, E P C l e d p e r m it s, a n d

s u b c o n tr a ct or p er m its.

REF 02 S u bc o ntractor an d T h e S u b c o n tr a ct o r s a n d S u p plier s M a n a g e m e n t Pl a n E P C C o ntr act or C o n str u cti o n

S u p pli er M a n a g e m e n t (SS M P) is to b e i m pl em e n t e d b y th e E P C C o ntr act or

Pla n (S & S M P) b e f o r e a n d d u ri n g t h e c o n str u cti o n p h a s e o f t h e

Pr oj ect as p art of th e E S M S t o e n s ur e th at

S u b c o n tr a ct o r s a n d s u p pli er s hir e d f or t h e p r oj e ct

c o m p l y wit h t h e p r oj e ct E & S r e q uir e m e n t s.

REF 03 E & S Tr ai ni n g M a n a g e m e n t T h e m ai n o bj e ctiv e of t h e E & S Tr ai ni n g M a n a g e m e n t E P C C o ntr act or C o n str u cti o n

Pla n (Tr M P) P l a n ( T r M P ) i s t o i d e n t if y t h e t r a i n i n g n e e d s i n t e r m s o f

e n vi r o n m e n t al, s o ci al, h e alt h a n d s a f e t y t o p ic s r el e v a n t

t o t h e p r oj e ct a n d p r o vi d e tr ai ni n g r e q uir e m e n t s a n d

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Reference Name Overall Description / Objective Lead Implementation 3 Relevance

in ESMS (phase)
s c h e d ul e/ m a trix of trai ni n g f or t h e r a n g e o f e m p l o y e e s

in v ol v e d i n t h e pr oj e c t d u ri n g t h e c o n str u ctio n p h a s e.

REF 04 St ak e h ol d er E n g a g e m e nt T h e S E P p r o vi d e s a s y st e m a tic a p p r o a c h t o id e ntify t h e Co mpany C o n str u cti o n

Pla n (SE P) a cti o n s t h e Pr oj e ct n e e d s t o u n d e rt a k e t o e n s u r e t h at a O p e r ati o n

ti m el y, c o n si st e n t, c o m p r e h e n si v e, c o o r d i n a t e d a n d D e c o m m i s si o ni n g

c ult u r all y a p p r o p ri a t e a p p r o a c h i s t a k e n f o r

c o n s u lt ati o n s a n d P r o je ct di s cl o s u r e. T h e S E P i n cl u d e s

s p e cifi c st a k e h ol d e r id e n tifi c a ti o n a n d m a p p i n g

r e q uir e m e n t s, e n g a g e m e n t, inf or m a ti o n discl o s u r e,

c o n s u lt ati o n m e e ti n g s a n d p u b li c p a r ti ci p a ti o n. T h e S E P

is alr e a d y p r e p a r e d ( V ol u m e V, E SI A) a n d will b e

r e g ul arly u p d a t e d t hr o u g h o u t t h e Pr oj e ct co n s tr u cti o n

a n d o p e r a ti o n p h a s e a s r e q ui r e d , b u t n o t le s s t h a n

a n n u a lly.

REF 05 St ak e h ol d er (ext er n al) A c o m m u nity Sta k e h o ld er Griev a n c e M e c h a nis m is a n C o m p a n y (su p p orted b y C o n str u cti o n

G riev a n c e M e c h a nism e st a blis h e d p r o c e s s to r e c eiv e st a k e h ol d e r c o n c e r n s E P C C o ntr a ct or) O p e r ati o n

(G M) a n d g ri e v a n c e s a n d t o f a cilit a t e t h e i r r e s o l u t i o n D e c o m m i s si o ni n g

thr o u g h a set pr oc e d ur e.

T h e st a k e h o l d e r g ri e v a n c e m e c h a ni s m i s im p l e m e n t e d

b y t h e C o m p a n y t hr o u g h o u t t h e c o n str u ctio n p h a s e of

t h e P r oj e ct f o r d e ali n g w it h st a k e h o l d e r g rie v a n c e s t o

id e ntify a n d m a n a g e st a k e h ol d e r c o n c e r n s a n d t h u s

s u p p o r t eff e ctiv e ris k m a n a g e m e n t, pr e v e n t a d v e r s e

c o n s e q u e n c e s of f ail u r e t o a d e q u a t el y a d d r e s s

g ri e v a n c e s, a n d b uil d a n d m a i n t ai n tr u s t wi t h all

st a k e h ol d er s.

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Reference Name Overall Description / Objective Lead Implementation 3 Relevance

in ESMS (phase)
REF 06 Li v eli h o o d R e s t o r ati o n T h e Li v eli h o o d R e s t o r a ti o n Pl a n ( L R P ) i s f o r r e st o ri n g Co mpany C o n str u cti o n

Pla n (L R P) t h e li v eli h o o d s o f f o r m a l o r i n f o r m a l p e r s o n s /l a n d

u s e r s a d v e r s ely aff e cte d b y t h e Pr oj e ct t o m i ti g at e a n d

f ull y c o m p e n s a t e f o r e c o n o m i c di s p l a c e m e n t i m p a c t s.

REF 07 C o m m u nity D e v el o p m e n t I d e n tifi e s t h e o v e r all d e v el o p m e n t n e e d s, m a n a g e m e n t Co mpany O p e r ati o n

Pla n (C D P) a n d i m p l e m e n t a ti o n o f d e v el o p m e n t i niti a ti v e s f o r l o c a l

c o m m u n itie s. T h e r e q uir e m e n t s a n d b u d g et f or t his

w o r k w ill b e d e fi n e d a t a l a t e r d a t e b a s e d o n i d e n tifi e d

n e e d s.

REF 08 L a b o r a n d W o r ki n g T h e L a b o r a n d W o r k i n g C o n d iti o n s M a n a g e m e n t Pl a n E P C C o ntr act or C o n str u cti o n

C o n d i ti o n s M a n a g e m e n t ( L W C M P ) i d e n tifi e s t h e m a i n l a b o r r e q u i r e m e n t s a n d O p e r ati o n

Pl a n ( L & W C M P ) (i n cl u d i n g ri s k s a s s o ci at e d w it h t h e P r oj e ct d u ri n g c o n st r u c ti o n. It D e c o m m i s si o ni n g

p r oj e ct s p e cifi c W o r k e r d et er mi n e s t h e r el ev a n t m a n a g e m e n t m e a s u r e s t o

c o d e of c o n d u ct) a d d r e s s la b o r is s u e s a n d a c hi e v e c o m p li a n c e wit h

p r oj e ct o blig ati o n s a n d E S M S ., T his pl a n also i n cl u d e s

t h e w o r k e r grie v a n c e m e c h a ni s m a n d m e a s u r e s t o

a d d r e s s w o r k e r i nfl u x 4 (c o n si d e r e d l o w ri s k).

REF 09 W o r k er A c c o m m o d a tio n T hi s Pl a n d e t ail s t h e s p e cifi c a ti o n s f o r W o r k e r E P C C o ntr act or C o n str u cti o n

M a n a g e m e n t Pl a n ( W A M P) A c c o m m o d a ti o n M a n a g e m e nt Pl a n ( W A M P ) w h e n D e c o m m i s si o ni n g

e m pl o y e d o n t h e Pr oje ct d urin g t h e c o n stru ctio n

p h a s e. It i n cl u d e s s p e cifi c a ti o n s f o r t h e d e si g n a n d

m a n a g e m e nt of w o r k er ac c o m m o d a tio n t o w hic h

c o n t r a ct o r s ( a n d a n y s u b - c o n t r a c t o r s) s h a ll c o m p l y

4
No dedicated worker influx plan is deemed necessary for this Project, but worker influx management measures are addressed across various plans.

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Reference Name Overall Description / Objective Lead Implementation 3 Relevance

in ESMS (phase)
w h e n h o u si n g t h eir w o r kf o r c e, a s w ell a s a c o d e of

c o n d u ct f or w o r k er s sta yi n g i n t h e a c c o m m o d a ti o n.

REF 10 O c c u p atio n al H e alt h a n d T h e O c c u p atio n al H e alt h a n d Saf ety ( O H S) E P C C o ntr act or C o n str u cti o n

Safety ( O H S) M a n a g e m e nt M a n a g e m e n t Pl a n ( O H S M P ) e st a b li s h e s g ui d e li n e s a n d O p e r ati o n

Pla n ( M P) p r o c e d u r e s t h a t cl e a r ly d e s c ri b e h o w c o n s t r u cti o n D e c o m m i s si o ni n g

a c ti viti e s w ill b e c a r ri e d o u t t o e n s u r e e m p l o y e e s a f e t y

a n d saf e g u ar di n g of per s o n n el a n d pr o p erty f or

r o u ti n e a n d n o n - r o u tin e a cti viti e s. T h e o b j e cti v e i s t o

p r e v e n t all O H S i n ci d e n t s t o t h e g r e a t e s t e x t e n t

p o s si bl e f o r all e m p l o y e e s a n d e n s u r e e n vi r o n m e n t al

p r ot e cti o n at t h e pl a c e of w o r k, z er o f at al a c ci d e n t s a n d

l o st ti m e a c ci d e n t s, a n d f ull c o m p li a n c e w it h l e g al a n d

c o n tr a ct u al r e q uir e m e n t s.

REF 11 E m erge ncy Pre p are d n ess T h e o bj e ctiv e of t h e E m e r g e n c y Pr e p a r e d n e s s a n d E P C C o ntr act or C o n str u cti o n

a n d R e s p o n s e Pl a n (EP R R e s p o n s e Pl a n ( E P R P ) is t o e s t a b li s h a s e ri e s of O p e r ati o n

M P ) (i n cl u d i n g m e d i c a l o r g a niz ati o n, o p e r atio n al a n d p r e v e n tiv e m e a s u r e s i n D e c o m m i s si o ni n g

res p o n s e pr oc e d ur e) th e ev e nt of a n e m e r g e n c y t h at is a d a pt e d to th e

cir c u m s t a n c e o f s u c h sit u a ti o n s, w hi c h i n t u r n will

e n s u r e t h e s af et y of w o r k er s, t h e e n vir o n m e n t a n d

p o t e n ti all y c o m m u n i tie s. T h e E P R w ill i n cl u d e a m e d i c a l

s e r vi c e s p r o c e d u r e o u tli ni n g o n - sit e a n d o f f- sit e

m e d i c al c a r e p r o vi si o n s, i n cl u di n g o u t b r e a k s of

c o m m u n i c a bl e di s e a s e s ( e. g., C O V I D - 1 9). It w ill al s o

i n cl u d e a d rill s c h e d u l e t o c o m p l e t e e m e r g e n c y d r ill s

t h a t w ill p r e p a r e w o r k e r s f o r p o s si b l e e m e r g e n c y

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Reference Name Overall Description / Objective Lead Implementation 3 Relevance

in ESMS (phase)
sit u ati o n s. T his in cl u d e s c o n si d e r ati o n of E P R

r e q ui r e m e n t s /i m p li c a ti o n s f o r n e a r b y c o m m u n i ti e s.

REF 12 T r a ffi c a n d T r a n s p o r t a ti o n T h e Tr affic a n d Tr a n s p o r t ati o n M a n a g e m e n t Pl a n E P C C o ntr act or C o n str u cti o n

M a n a g e m e n t Pl a n (T & T ( T T M P ) f o r i m p l e m e n t a ti o n d u ri n g t h e p r oj e ct' s D e c o m m i s si o ni n g

M P) c o n s t r u c ti o n p h a s e i s t o a v oi d tr a ffi c a n d t r a n s p o r t-

r el a t e d ri s k s t o P r oj e c t w o r k e r s a n d c o m m u n iti e s

d u ri n g c o n str u cti o n, p r o m o t e s a f e d ri vi n g a w a r e n e s s

a m o n g t h e p r o j e c t s t a ff, a n d e s t a b li s h b e s t p r a c ti c e s o n

v e hicl e m a n a g e m e n t. T hi s in cl u d e s m a n a g e m e n t of a n y

i m p a c t s o n t h e c o m m u n it y fr o m t r a ffi c a n d

tr a n s p o r t ati o n-r el at e d i m p a ct s.

REF 13 S e c u rity a n d H u m a n T h e o bj e ctiv e of t h e S e c u rity M a n a g e m e n t Pl a n ( S M P ) is E P C C o ntr act or C o n str u cti o n

Rights M a n a g e m e nt Plan t o i d e n tif y t h e s e c u rity m e a s u r e s t h a t will b e O p e r ati o n

(S H R M P) i m p l e m e n t e d o n sit e fo r m i ti g a ti n g s e c u rit y ri s k s a n d D e c o m m i s si o ni n g

e n s u r e t h at a r e s p o n s i bl e a p p r o a c h t o w a r d s s e c u rit y

m a n a g e m e nt is i m pl em e n t e d t o pr ot ect stak e h ol d er s

a n d w o r k e r s fr o m h u m a n ri g ht s a b u s e s.

REF 14 H a z ar d o u s M a t erial an d T h e m a i n o b j e cti v e of t h e H a z a r d o u s M a t e r i al s, W a s t e E P C C o ntr act or C o n str u cti o n

W a st e M a n a g e m e nt Plan a n d W a st e w at er M a n a g e m e nt Pl a n ( H M W W P ) is t o O p e r ati o n

(H M W M M P) i d e n tif y t h e t y p e s a n d q u a n titi e s of h a z a r d o u s D e c o m m i s si o ni n g

m a t e ri al s s o u r c e d a n d n at u r al r e s o u r c e s u s e d, a n d

w a s t e a n d w a s t e w a t e r g e n e r a t e d at t h e p r o j e c t sit e

d u ri n g t h e c o n s t r u c tio n p h a s e a n d t o d e s c ri b e t h e

p r o c e d u r e s a n d r e s p o n s i b iliti e s f o r t h e m a n a g e m e n t ,

tr a n s p o r t, st o r a g e a n d di s p o s al of t h e s e m a t e ri al s,

s u b st a n c e s, a n d w a st e p r o d u ct s.

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Reference Name Overall Description / Objective Lead Implementation 3 Relevance

in ESMS (phase)
REF 15 W a t er M a n a g e m e nt Plan T h e W a t e r M a n a g e m e n t P l a n ( W M P ) i d e n ti fi e s s o u r c e s E P C C o ntr act or C o n str u cti o n

(Wa M P) o f w a t e r s u p pl y f or t h e P r oj e ct, e sti m a ti o n o f r e q uir e d O p e r ati o n

q u a n titi e s, a n d p r o c e d u r e s f o r t h e s u s t ai n a b l e u s e a n d D e c o m m i s si o ni n g

m a n a g e m e nt of water reso urces use d thro u g h o ut the

c o n str u cti o n p h a s e of t h e Pr oj e ct. T his in cl u d e s

m a n a g e m e n t of a n y im p a c t s o n c o m m u nity w a t e r

a v ail a bilit y.

REF 16 Bi o di v e r sity M a n a g e m e n t T h e Bi o div e r sity M a n a g e m e n t Pl a n ( B M P ) e n s u r e s t h e E P C C o ntr act or C o n str u cti o n

Pla n (B M P) p r ot e cti o n of bi o di v e r sity r e s o u r c e s, in cl u din g h a bit at, O p e r ati o n

f a u n a , fl o r a, a n d a vif a u n a , d u ri n g t h e sit e p r e p a r a ti o n D e c o m m i s si o ni n g

a n d c o n str u cti o n p h a s e of t h e Pr oj e ct.

REF 17 E m i ssi o n s M a n a g e m e n t T h e C E M P i s a sit e- s p e cifi c pl a n d e v el o p e d t o e n s u r e E P C C o ntr act or C o n str u cti o n

Pla n (E M P) t h at a p p r o p ri at e e n vir o n m e n t al m a n a g e m e n t pr a ctic e s

a r e f oll o w e d d u ri n g th e c o n s t r u c ti o n o f t h e p r oj e ct t o

c o n tr ol a n d m i ni m iz e a s s o ci at e d e n vir o n m e n t al

i m p a c t s. T h e C E M P o u tli n e s h o w a c o n s t r u cti o n p r oj e c t

w ill a v oi d, mi ni mi z e, a n d m itig at e its e n vir o n m e n t al

i m p a ct a n d e n s ur e s th at e n vir o n m e n t al as p e ct s n ot

c o v e r e d b y o t h e r p l a n s ( s o il, h y d r o l o g y, d u s t, n o i s e,

e t c.) ar e m a n a g e d i n c o m p li a n c e w it h t h e P r oj e c t' s E & S

o blig ati o n s. T his i n cl u d e s c o m m u n it y h e alth a n d s af et y

ri s k fr o m e n vi r o n m e n t al a s p e c t s ( e. g., d u s t a n d n oi s e)

REF 18 C h a n c e Fi n d Pr o c e d u r e I d e n tifi e s p r o c e d u r e s t o b e i m p l e m e n t e d d u ri n g t h e E P C C o ntr act or C o n str u cti o n

(CFP) c o n str u cti o n p h a s e of t h e Pr oj e ct w h e r e t h e r e is (s u p p o r t e d b y I n stit ute of

p o t e n ti al f or a s- y et u n di s c o v e r e d c ult ur al h e rit a g e o r Ar c h a e ol o g y)

a r c h a e o l o g i c a l r e m a i n s t o o c c u r (i. e., c h a n c e fi n d s )

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Reference Name Overall Description / Objective Lead Implementation 3 Relevance

in ESMS (phase)
u n d e r g r o u n d d u ri n g th e c o n str u cti o n p h a s e of t h e

P r oj e ct.

REF 19 G e n d er M a n a g e m e nt Pla n A P r oj e ct G e n d e r A ctio n Pl a n ( G A P) is A D B’s k e y g e n d e r Pr oj ect C o m p a n y C o n str u cti o n

(G M P) m a i n str e a mi n g t o ol an d m e c h a nis m f or e n s uri n g O p e r ati o n

g e n d e r-i n cl u siv e d e sig n a n d i m pl e m e n t atio n of D e c o m m i s si o ni n g

p r oj e ct s.

REF 20 O p e r ati o n al E & S O p e r ati o n al M a n a g e m e n t a n d M o nit ori n g Pl a n ( O M M P ) Pr oj ect C o m p a n y O p e r ati o n

M a nage m ent and is a n o p e r ati o n al pl a n for m a n a gi n g E & S risk s wit h

M o n it o ri n g Pl a n ( O E S M P ) s u p p o r ti n g pr o c e d u r e s, f or m s, a n d m e t h o d st at e m e n t s

a s p e r t h e r e q u i r e m e n t s o f t h i s E S M P . T h i s p l a n w ill

i n cl u d e a l o c al hiri n g p l a n i n o r d e r t o i d e n tify a n d t r ai n

a s m a n y a s p o s si bl e lo c al p e o pl e e m p l o y e d o n t h e

c o n s t r u c ti o n s t a g e t o d e v e l o p / c r e a t e t h e n e c e s s a r y sill s

t o c o nti n u e w o r k o n th e Pr oj e ct d u ri n g t h e o p e r ati o n

s t a g e f o r r ol e s w h e r e t h e b a si c q u a lifi c a ti o n crit e ri a f o r

th e O & M of t h e pla nt c a n b e m et. Including a

Manpower and Training Plan.
REF 21 D e c o m m i s si o ni n g E & S D e c o m m i s si o ni n g p h a s e pl a n ( wit h s u p p o r ti n g Pr oj ect C o m p a n y D e c o m m i s si o ni n g

M a nage m ent and s u b pl a n s) f or m a n a gin g E & S ris k s wit h s u p p o r ti n g

M o n it o ri n g Pl a n ( D E S M P ) pr oc e d ur es, for m s a n d m et h o d stat e m e nts as p er th e

r e q uir e m e n ts of this E S M P.

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6 Mitigation and Management Requirements

6.1 Introduction

The ESMP sets out the management and monitoring requirements for the design, pre-
mobilization, construction (including site preparation) and operation phases of the
Project.

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6.2 Mitigation and management requirements – design and procurement phase

Table 4: Mitigation and management requirements – design and procurement phase

Objective Activity Action Responsibility Timescales Evidence

Avoid significant impacts on Design / EPC Contractor ● Grade temporary access roads so their slope is not too large to avoid the build-up of fast- Contractor (detailed design) Pre-FC 5 EPC Contract 7
sensitive receptors from the Technical Specification running runoff water during extreme precipitation events.
construction works. ● All equipment to ensure less than 85d(B) A at 1m from the equipment.
EPC approved
● No noisy or high noise activities to be undertaken outside normal working hours (7am to
Design
Pre-NTP 6
6pm) without prior approval of the Project Company.
● EPC contractor to supplement existing noise baseline with pre-construction baseline noise
measurements at nearest residential receptor to the R78 for the Kirlishon and Kulchovdur REF00 Site

communities, the R78 between the Kirlishon and Kulchovdur communities, batching plant, Mobilization Plan

and community within the Khamza 1 pumping station.

Address climate resilience Design / EPC Contractor ● Design project for climate projections up to 2085 – consider the need to reinforce the Masdar Pre-FC EPC Contract
measures in the technical Technical Specification structures or higher design standards (stronger winds, higher temperatures). Technical
design ● Design access roads to consider short-term, extreme weather events.
Contractor (subcontractors) Specification)
● Design any drainage to account for increased or short-term extreme precipitation patterns.
EPC approved
Pre-NTP
● Design for increasingly frequent and extreme dust storms.
design
● Specify more effective cooling for BESS, substations, and transformers.
● Design shading around the BESS to help cool.
Reduce the use of raw Design / EPC Contractor ● Substitute raw materials or inputs with less hazardous or toxic materials wherever Contractor (subcontractors) Pre-FC EPC Contract
materials/ potentially finite and Technical Specification economically and technically feasible.
or scarce resources. ● Identify opportunities to prevent waste production in the first instance.
Approved Design
● Dry cleaning for PV panels.
Pre-NTP Water Resource
● No groundwater is to be used in the construction process.
confirmation
● All drinking and potable water will be tankered to the Site from a sustainable source.
● No water can be extracted from the ABIS canal or other surface water sources. REF00 Site

● Use septic tanks on Site for wastewater management. Mobilization Plan

Ensure biodiversity mitigation Design / EPC Contractor ● Maintain a 70 m setback from the fence line to the edge of the ABIS canal. Masdar Pre-FC EPC Contract
measures are incorporated into Technical Specification ● Install Bird Flight Diverters on overhead, or static lines of the OHTL on all new (30m) and
the design refurbished (200m) sections of 220kV powerline.
Contractor (subcontractors) Approve Design
● Select fencing that allows the free movement of small fauna onto and across the site
Pre-NTP REF00 Site
(through a gap of circa 20 cm under the fence) to support habitat (and soil) restoration goals
Mobilization Plan
and limit biodiversity impacts.

Hazardous materials Design / EPC Contractor ● Prohibit the following materials in EPC Contract: Masdar Pre-FC EPC Contract
Technical Specification o Asbestos
o PCB-containing materials.
Contractor (subcontractors) Approve Design
o lead-based paints
Pre-NTP
o pesticide, and herbicides defined under the Stockholm Convention.

5
Pre-NTP–Pre-Notice toproceed.
6
Pre-FC–Pre-FinancialClose.
7
In this table, referenceto “EPCContract” refers to the inclusionof this requirementasa specific contractobligation intheEPCcontract. Implementationof theserequirementswill bemonitoredduringconstructionandoperationasrelevant (andnoted insubsequent tables).").

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Objective Activity Action Responsibility Timescales Evidence

Safeguard workers and Design / EPC Contractor ● Ensure sufficient separation between battery containers and batteries and other critical Masdar Pre-FC EPC Contract
community from an emergency Technical Specification infrastructure.
or abnormal events ● Ensure sufficient ventilation (BESS)
Contractor (subcontractors) Approve Design
● Hazard and fire protection, including gas extinguishing method using NOVEC1230 and
Pre-NTP
water or liquid Fire Fighting (Suppression) System) (FFS) along with detectors for
combustible gas like hydrogen or carbon monoxide and their exhaust system.
● Ensure all BESS containers can be locked to prevent unauthorized access.
● The areas between and around the equipment will be finished with gravel and kept free of
vegetation or other material that could act to spread a fire.
● The Project will have a dedicated emergency preparedness and response plan in place.
Safeguard the well-being and Complete ● Make all compensation payments as required in the LRP prior to losing access to the land. Project Company Pre-construction Evidence of
improve the living standards of implementation of the ● Start (and complete, if possible) any livelihood restoration activities as required in the LRP compensation
those whose livelihoods are Livelihood Restoration before site clearance. paid.
involuntarily displaced. Plan LRP Monitoring
Report
Compliance
report
Close out report

Promote local hiring EPC Contract ● Unbundle procurement contracts so that local community members have a greater Project Company Pre-construction EPC Contract
chance of supplying the Project and advertise employment and procurement contracts
locally and in local languages.
● Set target of at least 15% national participation (Uzbek).
● Confirm that Kirlishon and Kulchovdur communities will be considered 'local' for the
purpose of local hiring.
● Adopt approach to maximise “local” hiring including training 3 months in advance of the
start of operations in order to identify and train as many local people as possible who
were employed on the construction stage to make them skilled enough to continue work
on the Project on the operation stage.
● Discuss with Alat district khokimiyat and local communities the employment and
procurement contracts available to manage expectations of the number of local jobs that
will be available.
● Prioritize employment of local community members where possible.
● Prioritize employment of PAPs or members of their families where possible.
● Prioritize procurement of goods from local communities where possible.
● Where possible, prioritize women's employment and people from vulnerable groups.
Safeguard local community EPC Contract ● All accommodation (onsite or off-site) must comply with "Worker’s Accommodation Masdar Pre-FC EPC Contract
from worker influx. Processes and Standards”: Guidance Note by IFC and EBRD. Approve Design
● Community grievance mechanism provided in locations where worker accommodation is
Contractor (subcontractors) REF08: Labour
provided in local communities.
Pre-NTP and Working
● Do not allow contractors to use at-the-gate hiring or day laborers.
Conditions MP
REF09: Workers
Accommodation
MP

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6.3 Mitigation and management requirements - pre-mobilization phase

Table 5: Mitigation and management requirements – pre-mobilisation phase

Objective Activity Action Responsibility Timescales Relevant Management Plan /

Monitoring / KPI

Comply with national permit Environmental permits ● Develop permit matrix (name, phase, requirements, and lead) and set Project Company / EPC Pre-Financial Close (FC) REF 01a Permit matrix –
requirements. Labor permits out conditions register. Contractor monthly updates

Construction permits
Transportation permits

Implement robust ESMS for the Site implementation from NTP ● Establish the cESMS. Project Company / EPC Pre-Financial Close (FC) REF 00 ESMS Manual
duration of the Project to COD ● Establish the EPC-ESMS Contractor EPC-ESMS

Demonstrate Contractor Organization ● Define Project Company Project Implementation Team Project Company / EPC Pre-mobilization Sponsor organogram (approved
capacity to implement the E&S ● Define Contractor Project Implementation Team Contractor by Lenders)
requirements for the Project. REF 00 ESMS Manual

Ensure a transparent and Supplier selection • Unbundle procurement contracts so that local community members Project Company / EPC Pre-mobilization Panel procurement DD
robust supply chain have a greater chance of supplying the Project and advertise Contractor (performed by Masdar affiliate).
procurement contracts locally and in local languages.
• Perform panel supply chain due diligence or obtain third-party supply
Supply Chain and Local
chain due diligence reports to verify potential suppliers’ credentials
Employment and Procurement
regarding the occurrence of forced labour, child labour or
(see Appendix C)
occupational health and safety failures. The supply chain will be
mapped (to the polysilicon level) and verified by an independent
consultant for the point of origin. For all other materials adopt the REF02 Subcontractor and

Masdar Supply Chain and Procurement Policy that includes the Supplier MP

following obligations:
o Prohibit forced labour at the Site and in the supply chain.
o Prohibit the hiring of child labour at the Site and in the supply
chain.
o Preference for using local suppliers where possible.
o Maintain an employee register.
o Preference suppliers who remove packaging waste for
ultimate disposal (following Uzbek regulations and
transboundary waste disposal obligations)
Promote the use of local Procurement of local labour Develop Local Hiring Procedure as part of the Labour and Working Conditions Contractor (subcontractors) Pre-mobilization EPC Contractor HR manager
workers on the Project and contractors Plan including:
● Workforce requirements for the construction and operation phase for
REF08: Labour and Working
Masdar, the EPC Contractor and subcontractors, including the number
Conditions MP
of E&S personnel and their qualifications.

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Objective Activity Action Responsibility Timescales Relevant Management Plan /

Monitoring / KPI
● Key competencies for all roles with plenty of notice to mobilize local
recruitment.
● Hiring needs.
● Local counterparts for advertising project needs (skilled and unskilled
workers) may be sourced from the local labour pool.
● Mechanism for promoting women working on the Project.
● Prioritizes local unskilled/semiskilled local employees.
● Definition of working terms and conditions (salary, etc.) for each role
on site.
● Nominate an EPC Contractor HR manager to oversee employment
matters on the Project.
Implement good international Notification of works Following GIIP undertake the following: EPC Contractor Pre-mobilization Monthly update via the PIT
practice (GIIP) for site ● Plan and give regulators advanced warning of potential problems and REF04 SEP
management and coordination. the start of work.
REF11 EPR MP
● Always display on Site the emergency number for regulators and local
community leaders at key worksites.
● Ensure site personnel know the correct procedure for reporting
incidents
Managing sub-contractor ● Follow IFC Good Practice Guidance note: Managing Contractors Contractor (subcontractors) Part of the contractor Proof of checks, training
mobilization) Environmental and Social Performance (section 4.5) including: tender process records
● Sub-contractors should provide work completion certificates and EHS Site inspection records
certificates to prove their past environmental performance before
HR policies approved by EPC
hiring.
Contractor
● Ensure subcontractors have a copy of the Project ESMP and EPC-ESMS
as part of the tender process. Ensure sub-contractors attend
environmental training/induction sessions (communicated to workers REF02 Subcontractor and
in their main language(s) spoken). Supplier MP
● Audit the performance of sub-contractors during the Project.
● Adhere to the local hiring policy (see below) for prioritizing local
contractors.
● Require sub-contractors to provide a copy of their HR policy for
approval, or they commit to following the EPC Contractor’s/ Project
Company HR policy that meets Lender and ILO requirements and
prohibits explicitly child and forced labour use, OHS management and
encourages non-discrimination.
Management and site control ● Nominate a person within Contractor’s organization with defined EPC Contractor Throughout project Successful third-party audit
responsibility for the EHS role in Project. works (Project Company)
● All method statements to include EHS requirements.
● All PTW forms to include reference to E&S (including community and
REF00 ESMS Manual
climate risks).
● Through relevant training, ensure everyone on Site is aware of their
responsibilities and liabilities with respect to the environment and
social responsibility.
● Through site induction, inform staff and visitors of Project
environmental issues and standards (including labour, climate, E&S
and security risks).
● Display warning signs at key work sites prominently

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Objective Activity Action Responsibility Timescales Relevant Management Plan /

Monitoring / KPI
● Make Project Company environmental policy available to all on Site
● Protect primary work sites against vandalism, theft, and breakage with EPC Contractor
permitter fence (a temporary permitter fence must be erected if the
permanent site fence is not erected at mobilisation)
● Define responsibilities for site’s security in a Security Management
Plan (as defined below) while the services are being performed.
● Secure the Project boundary with a secure fence.
All Site works ● Establish a safe working environment with an occupational health and Contractor (subcontractors) Throughout project REF10 OHS MP
safety (OHS) plan that addresses potential hazards, identifies works
preventive and protective measures, including training and use of PPE,
and describes documentation and reporting of accidents, diseases
and incidents.
Liaison with the local ● Identify the key local representatives and inform them of the Project's EPC Contractor/CLO Start of Site works – Monthly audits
community progress. ongoing after that. Communication records
● Nominate a community point of contact in the Contractor team and
CLO
Operations team (a CLO)
Daily Site walk around
● Display a contact board at the perimeter of key work sites stating
contact details in case of a complaint or comment. Grievance logs

● Use this board to display information about project phasing and other Number of complaints
relevant matters. REF04 SEP
● Implement the requirements of the grievance mechanism and
stakeholder engagement plan (SEP)
● Deal with any grievances that arise quickly and follow the defined
grievance procedure.
● Create a log of grievances and ensure they are appropriately followed
up and resolved.

Ensure general site Daily and weekly site ● Work sites will be subjected to “walk-round” site inspection by the EPC Contractor (oversight by Throughout project Site inspection records
housekeeping and inspections of permanent contractors’ EHS management staff daily. Project Company) works Number of complaints
environmental protection work sites Target zero

Protected Priority Biodiversity Complete mitigation ● Preconstruction sensitive plant survey (Calligonum matteianum, C. Project Company To be completed Project Company BMP (part of
Features obligations molle, C. paletzkianum) including construction phase seed collection before construction ESMP) (including CAT rescue
and replanting program (completed 8).

8
Duetodrought, theSpring/ summerflora surveyplannedfor the timewindowwhentheseedsofCalligonumareripeandhavenot yet fallenfromtheparentplantsdidnotenable the identificationof (Calligonummatteianum,C.molle,C. paletzkianum).Previoussurveys will be
usedtodefine thereplantingprogram

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Objective Activity Action Responsibility Timescales Relevant Management Plan /

Monitoring / KPI
● Pre-construction survey (June) for reptiles (to confirm the baseline EPC Contractor (oversight by and relocation procedure) EPC
survey findings concerning presence or absence of Central Asian Project Company) BMP approved by PC.
Tortoise (CAT) (completed). REF16 BMP
● Perform a terrestrial animal survey and chance rescue/relocation plan
immediately before construction for CAT.
Noise Establish baseline at all ● Supplement noise baseline to include communities (Krilishon, EPC Contractor To be completed Noise baseline report
nearest noise sensitive Kulchovdur) adjacent to the main access route in case of complaints before construction REF17 Emissions MP
receptors including along relating to noise generated by passing heavy vehicles
transportation route

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6.4 Mitigation and management requirements – construction

Table 6: Mitigation and management requirements – construction

Objective Project Activity Action Responsibility Timescale Monitoring / KPI

Minimise dust generation Earthworks, material handling. As part of the Construction Emissions Management Plan, develop procedures for the implementation of the EPC Contractor Construction Site inspection
within the direct AOI (measures to control dust from following GIIP: (subcontractors) records
(200m from the works) vehicle activities described
● Locate activities and rock/earth stockpiles more than 250 m away from the ABIS canal edge. Community
under traffic and transportation)
● Use off-site concrete batching off-sitefor all concrete needs. grievances
(C&D)
● Demarcate work areas and access roads. REF17 Emissions
● Cover, seed, or fence stockpiles to prevent wind whipping. MP
Infrequent maintenance ● Keep stockpiles for the shortest possible time.
activities (O&M). ● Consider the prevailing wind direction when siting stockpiles to reduce the likelihood of affecting
sensitive receptors.
● No bonfires.
● Minimise amounts of material handling and avoid double handling.
● Seal or re-vegetate completed earthworks as soon as reasonably practicable after completion.
● Ensure all vehicles carrying loose or potentially dusty material are fully sheeted to or from the Site.
● Cement and other fine powders will be sealed or put in bunded containers after use.
● Regular (daily) visual monitoring of dust episodes, soiling of vegetation, dust resuspension on the
roads and dust clouds.
● Re-vegetate areas as soon as possible.
● Provide workers with relevant PPE, including dust masks.
● Require all contractors to have an on-site area for shelter during dust events.
● Construct new road sections following site clearance and stockpile management requirements,
including covering stockpiles to minimize dust events.
● Excavation, handling, and transport of erodible materials shall be avoided under high wind
conditions (>15km/h).
● Use water (from a sustainable source) or other control measures such as chemical bonding agents
or aggregate to control dust.
● Demarcate delivery road and access tracks at the Site and ensure all workers stick to the
demarcated area.
● Record any exceptional incidents that cause dust, either on- or off-site, and the action taken to
resolve the situation in the logbook.
Minimize the impact of Earthworks, material As part of the Construction Emissions Management Plan, including requirements for the following GIIP: EPC Contractor Construction Site inspection
fugitive emissions from handling/vehicle movements (subcontractors) records
● Use of modern vehicle/construction fleet meeting national emissions standards and have regular
vehicle exhausts and
maintenance work following (“O’z DSt 1057:2004 Vehicles. Safety requirements for technical
equipment on receptors Construction
conditions” and “O’z DSt 1058:2004 Vehicles. Technical inspection. Method of control”.
along with the direct AOI
● Monitor all engines and equipment that are turned off when not in use. reports
and the delivery route
● Locate machinery and dust-causing activities (e.g., access roads, stockpiles) away from nearby
from the railway station to
sensitive receptors where practicable and more than 250m from the ABIS canal. REF17 Emissions
the “Material and
● Minimise movement of construction traffic around the Site (use demarcated routes only). MP
Equipment Laydown
● Keep vehicle movements to a minimum.
Area.”
● Enforce speed limits and reduce vehicle movements (maximum of 10 km/h) for project vehicles on
unsurfaced roads).
●
Minimise noise emissions Operation of site equipment ● . EPC Contractor Construction Site inspection
(subcontractors) records

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Objective Project Activity Action Responsibility Timescale Monitoring / KPI

● Demarcate specific routes from the existing road to the right of way that maintain a buffer of at
least 250m from NSR where possible. Construction
● Inform nearby dwellings on the timing and duration of works and when the noisiest stages will reports
likely occur (ongoing through the process). REF17 Emissions
● Plant and equipment are to be examined daily for defects before the start of work, and under no MP
circumstances should defective equipment be used.
● Acoustic covers on machine engines are to remain closed as applicable.
● Avoid unnecessary revving of engines and equipment to be switched off when not in use.
● Site operatives are to be briefed on keeping noise to a minimum.
● No blasting without prior approval of the Project Company.
● Locate static plant (e.g., generators) to take advantage of any screening to break the line of sight
from receptors.
● Brief site operatives to keep noise minimal as part of the induction process.
● Following the SEP, inform receptors when work will commence and any particular noisy works.
Construction traffic ● Limit vehicle speeds on track to 10 km per hour. EPC Contractor Construction Site inspection
● No traffic should park up on the route between the railway station and the “Material and (subcontractors) records
Equipment Laydown Area.” Construction
● All vehicles are to evidence regular maintenance schedules following national statutory reports
requirements.
REF17 Emissions
MP/REF12 Traffic
and Transportation
MP

Minimize waste Construction PB/BESS/OHTL / ● Select PV panel producers and battery suppliers that can ensure the take-back and recycling of PV Project Company Construction Waste logs
generation substation panels during the operation phase and end-of-life decommissioning. REF14 Hazardous
● Ensure selected PV modules and battery supplier contract includes all costs for returning and Materials and
decommissioning PV panels (intermittently during operation and end of life). Waste MP
● Prohibit the following materials in EPC Contract / Procurement Policy
o Asbestos
o PCB containing materials
o Lead-based paints
o Pesticides and herbicides as defined under the Stockholm convention.
● Consider off-site manufacture and design for disassembly to minimize resource use.
● Check need and perform an asbestos survey of OHTL tower and conductors to confirm presence
or absence of asbestos in insulation material. If asbestos confirmed, develop an asbestos removal
and management plan prior to the start of OHTL removal works).
Minimise impact on water Construction PV/BESS/OHTL / ● Construct the perimeter drainage system, to act as a cut-off drain to protect the ABIS Canal during EPC Contractor Construction Site inspection
resources substation earthworks as set out in Water Management Plan which includes the Storm Water Management (subcontractors) records
Procedure.
● No storage or laydown areas within 250 m of the ABIS canal
Construction
● No groundwater abstractions for potable or construction-related purposes.
reports
● Sanitary waste will be collected in portable latrines or septic tanks, and wastewater will be collected
REF15 Water MP
for disposal off Site in a municipal wastewater treatment facility (under licence).
● Portable latrines or septic tanks must be installed at least 250 m from the canal edge, with leak
prevention and detection measures.
● Undertake groundwork to ensure appropriate site drainage (avoiding risk of contaminated runoff)

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● No direct discharge or uncontrolled releases of potentially contaminated water to the ground, e.g.,
concrete washout or oily wastewater (see actions on spill control below).
● Establish a controlled concrete washout area (on Site)
● Maintain a mandatory 70 m buffer between the site fence line and the edge of the ABIS canal.
Sustainable water use Construction PB/BESS/OHTL / ● Drinking/potable and construction water will be sourced from the municipal supply and tankered EPC Contractor Construction Site inspection
substation to the Site (under permit). (subcontractors) records
● All concrete will be delivered to the Site pre-mixed with approved water use licences. Construction
● Do not use water for dampening down roads. reports
● Potable water should be obtained from a sustainable source (and not obtained from ABIS canal or
REF15 Water MP
municipal.

Minimise road hazards, Site/ROW clearance ● Contractors should use a pre-defined route to the “Material and Equipment Laydown Area” (route EPC Contractor Construction Approved
congestion, and damage TBD in the Traffic and Transportation Management Plan (subcontractors) REF12 Traffic and
to road infrastructure ● Design laydown area and delivery approach to minimize vehicle stopping outside the site access. Transportation MP
(surfaced roads) and ● Obtain any necessary approvals. Training logs/
residents along the route ● Confirm no road improvements are required and, where required, ensure they comply with attendance sheets
(see also CHS below) relevant country laws and standards.
Signage in place
● Include a clause in the EPC contract that any damage to the road (wear and tear over the
construction period) must be repaired and ‘made good’. EPC to confirm delivery routes and
conduct condition surveys of routes to be used at the Project site.
Develop a Traffic and Transportation Management Plan (TTMP) that includes the following GIIP and aligns
with IFC EHS Guidelines: General:
● No stopping of Project-related vehicles or abnormal loads is allowed between Alat city and the
Project site.”
● All drivers are to undergo a driver induction.
● Signage on R78 after Khamza pumping station to inform road users of the construction site
entrance.
Minimise road hazards, Equipment delivery ● Ensure drivers are trained to drive heavy goods vehicles (HGVs) on unsurfaced roads (where EPC Contractor Construction REF12 Traffic and
congestion and damage to necessary). (subcontractors) Transportation MP
road infrastructure ● Check that all drivers have the necessary license for their vehicles. Training logs/
(unsurfaced ● Ensure all vehicles have up-to-date maintenance records. attendance sheets
roads/construction areas) ● Minimise transport of workers along the unsurfaced road sections and use pool vehicles where
Maintenance
possible.
records
● Consider the location for the accommodation camp and the Material and laydown area to
Meeting minutes/
minimize additional transportation through local villages and along the unsurfaced road.
attendance sheets/
● Notify the local communities about the delivery of wide/heavy loads and how it could impact their
road use. SE log

Minimise traffic-related Equipment delivery ● Demarcate delivery roads and access tracks across the Site and ensure all workers stick to the EPC Contractor Construction REF12 Traffic and
accidents (surfaced and demarcated area. (subcontractors) Transportation MP
unsurfaced roads) ● Maximum of 40 km/h on the section of road between Khamza 1 pumping station and Site. Training logs/
● Minimise pedestrian interaction with construction vehicles. attendance sheets
● All drivers are to undergo a driver’s induction and sign the driver's code of conduct.
● Employ safe traffic control measures, including road signs and flag persons, to warn of dangerous
conditions along the unsurfaced road to the work fronts.
● Report all traffic accidents and statistics in weekly EHS reporting (all contractors)
● All drivers carrying personnel or material along unsurfaced roads must undertake off-road driver
training.

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Objective Project Activity Action Responsibility Timescale Monitoring / KPI

● Provide awareness training to receptors (herders, local residents, and workers at Khamza 1 and
Khamza 2 substations).
● No night-time driving along unsurfaced roads.
Minimise impact Site/ROW clearance Develop a Site Mobilization Plan (SMzP) that includes the following GIIP requirements and aligns with IFC EPC Contractor Construction REF00 Site
to soils (contamination) EHS Guidelines: General: (subcontractors) Mobilisation Plan
● Avoid total removal of vegetation of the whole Site where possible, e.g., around the edges of the REF11 EPR MP
Site and the substation and BESS site (as set out in the Biodiversity Management Plan)
● Refuelling plant and equipment (on-site) will be carried out in a designated area and on hard
Site inspection
standing ground to prevent seepage of any spillages to soil/groundwater.
records
● Collection systems will be installed in these areas to manage spills, and fuels will be collected and
reused, treated by incineration, or removed by a local contractor.
● Drip trays must be used when refuelling and servicing vehicles or equipment not on the designated Construction
refuelling hardstanding surface. reports
● Hazardous material storage will be on hardstanding and impervious surfaces, and the bulk storage REF16 BMP
facility will be bunded and more than 70m from the ABIS canal.
● Restrict storage and handling of hazardous materials and fuels to bunded areas of sufficient
capacity to contain a release.
● Storage containers will be regularly checked and maintained
● Implement measures to address accidental leaks/spills of oil, fuel, chemicals, and wastes and
manage hazardous materials
Minimise impact Site/ROW clearance ● Preserve the VCA marked areas as defined in the BMP. EPC Contractor Construction Site inspection
to soils (degradation) ● Preserve areas between rows (approx. 200 ha). (subcontractors) phase records
● Demarcate specific tracks to site/ROW and track vehicles to ensure only demarcated routes are Construction
used. reports
● Confine traffic movement to designated routes.
REF00 Site
● Control access to areas within the Site that are not required for construction.
Mobilisation Plan
● Define a designated hazardous materials storage area and ensure adequate security and
REF16 BMP
secondary containment (bunding) to contain any spills.
● Restrict access to hazardous materials.
● Adopt GIIP (as defined in WBG EHS Guidelines: General and reflected in other sections of this
ESMP) for management for pollution prevention from using machines and equipment, refuelling,
storage and handling of hazardous materials and management of wastes.
● Designate a central maintenance and refuelling area on Site located on hardstanding.
Implement sustainable Site/ROW clearance Develop a Site Mobilization Plan (REF 07) to address topsoil removal following sustainable land-use EPC Contractor Plan – pre-NTP Site inspection
site clearance and practices: (subcontractors) Construction records
rehabilitation practices to ● When stripping, stockpiling, or placing soil, do so in the driest condition possible and use tracked phase
avoid impact on natural equipment to reduce compaction.
Construction
habitats (fixed sands) to ● Topsoil to be stripped to a thickness defined by depth below the surface and a distinct colour
reports
avoid the “shifting sands” change.
REF00 Site
phenomenon. ● Clearly define topsoil and sub-soil stockpiles of different soil materials for reuse of topsoil.
Mobilisation Plan
● Keep soil storage periods as short as possible.
● Monitor soil restoration REF16 BMP

● Reuse materials on-site wherever possible REF14 Hazardous

● No imported soils or aggregates Materials and
● Regular checks and surveys for AIS every three months Waste MP
● Organic topsoil (superficial layers) will be used on-site and near the Site for revegetation activities.

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Objective Project Activity Action Responsibility Timescale Monitoring / KPI

Minimise secondary Site ROW rehabilitation ● Rehabilitate the compacted area to support the return of the impacted area to the original state as EPC Contractor Construction Rehabilitation plan
impacts on soils from quickly as possible following the completion of the works. This may require aeration of the topsoil, (subcontractors) phase REF16 BMP
vegetation removal and enrichment of the topsoil or reintroduction of selected species and shrubs. Do not rely on natural
works. rehabilitation.
● Reflect natural gradient and relief when reinstating soils.
Ensure appropriate Site/ROW clearance Prepare HMWMP to include the following GIIP requirements and to meet WBG EHS Guidelines: General: EPC Contractor Plan – pre-NTP Site inspection
handling, storage, and (subcontractors) records
● Identity and characterize the source of all waste streams (hazardous and non-hazardous) and the Construction
disposal of solid and phase
proposed final disposal option (Site waste management)
hazardous waste to
● Define and demarcate dedicated temporary waste collection site at the worksite Construction
minimize impacts to
● Perform due diligence and iidentify temporary waste storage and collection points (hazardous and reports
groundwater, land, and
non-hazardous) at the Site for coordinated onward transportation and disposal at a licenced
workers.
facility. REF14 Hazardous
● Identify waste reuse and recycling disposal routes to process waste streams (following Uzbek Materials and
requirements) and set up agreements Waste MP
● Identify construction waste landfill
● Obtain license and authority of final disposal locations
● Identify and contract authorized transportation company to take waste to the disposal facility (in
particular hazardous waste)
● Define and establish a documentation management system for tracking waste (duty of care)
● Maintain a hazardous waste inventory.
● Segregate waste material on-site for disposal via the identified channels as per SWMP)
● All skips/waste storage to be suitably covered (to avoid dispersion of light materials by wind or
filling of skip with rain) and waterproofing to avoid soil contamination from leachate.
● Hazardous waste must be designed according to GIIP (bunding, separating incompatible hazardous
substations, etc.) as defined in WBG EHS Guidelines: General and in line with national
requirements. Liquid wastes/oil/chemicals will be stored in tanks or drums in bunded areas that
can hold the larger of 110 percent of the largest tank or 25% percent of the combined tank
volumes in areas with above-ground tanks with a total storage volume equal or greater than 1,000
liters and will be made of impervious, chemically resistant material according to national safety
requirements and WBG EHS Guidelines: General (whichever is stricter.
● Implement good housekeeping and operating practices, including inventory control, to reduce
waste from out-of-date materials, off-specification, contamination, damage, or excess to plant
needs.
Prevent leaks, spills, and Site establishment & Develop a spills response protocol (may be part of the wider EPRP), including requirements to: EPC Contractor Plan – pre-NTP REF11 EPR MP
environmental incidents. Construction (subcontractors) including spills
● Maintain an inventory of hazardous materials and specific procedures/ controls Construction
Response Protocol
● Maintain available copies on Site of Material Safety Data Sheets (MSDS) for all hazardous phase

substances used during the Project:

● Establish hazardous materials storage areas that are located away from existing sensitive Site inspection
receptors and are secure from theft or vandalism, well-ventilated, and have suitable emergency records
response equipment (fire extinguisher, eye wash etc.) and PPE. Construction
● Ensure spill kits are located and first response equipment at all work fronts. reports
● Ensure no hazardous materials are stored in large quantities at the work fronts or the central
materials store and laydown area.
Minimise impact on Site clearance ● Identify vegetation compensation areas (VCA) to compensate for the loss of 649 ha of Natural Project Company Plan – pre-NTP REF16 BMP
Natural habitat Habitat per IFC PS6, and therefore subject to the “no net loss” mitigation standard. Construction NH compensation
● VCA areas to be protected during construction works and then enhanced as part of the NNL phase report
planning (see operational phase mitigation).

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● Retain approximately 80% of habitat on site during site clearance.
● Seek to undertake limited enhancement of areas between the panel rows (refer to BMP for further
information)
Minimise impact on Site clearance Develop Biodiversity Management Plan including the following requirements: EPC Contractor Plan – pre-NTP REF16 BMP
habitats – General ● Preconstruction sensitive plant survey (Calligonum matteianum, C. molle, C. paletzkianum) and (subcontractors) Construction Site inspection
development of replanting program (June 2023) 9. (completed) phase records
● Pre-construction tree count survey (in combination with the plant survey above) (following national
requirements) (June 2023) (completed)
Construction
● Identify Vegetation Compensation Areas (VCA) for the purpose of future no net loss (NNL) planting
reports
and preserve for enhancement planting as per the BMP
● Preserve the areas between rows (approx. 200 ha) for enhancement planting
● And monitoring for including in the BMP
● Develop no net loss management plan (Calligonum matteianum, C. molle, C. paletzkianum)as
defined in BMP
● Establish a site nursery to support vegetation compensation planting
● All work is to be within the project site or ROW.
● Rehabilitate temporarily disturbed areas as soon as possible after construction activity is finished
to minimize the risk of shifting sands.
● Minimize the use of trenches or other steep-walled excavations.
● Backfill open excavations as soon as possible after construction activity.
● Employ an E&S Biodiversity supervisor to be present on ite during site preparation and excavation
works to assure compliance with construction phase mitigation measures and to conduct daily
searches of Work fronts and animal rescue from open trenches, as needed, focusing on Central
Asian Tortoise.
● Ensure signage and training to prevent construction workers from poaching or harassing sensitive
wildlife.
● Fence site before the start of construction works to avoid encroachment by mammals.
● For OHTL works, do not leave trenches open overnight unless they are fenced.
● Prohibit poaching (focusing on CITES species) and interactions with fauna and flora in the worker
code of conduct.
● Worker/contractor training/awareness, supervision regarding impacts to animals and species
protection.
Raise worker awareness of Construction works (PV, BESS ● Add the following to the Project specific Worker Code of Conduct - “Workers are prohibited from: EPC Contractor Construction REF 08 L&WC MP
the biodiversity risks and OHTL) o Removing flora from the work area (subcontractors) phase Site inspection
o Hunting any species records
o Interaction with large mammals
o Penalties for infractions
Construction
● During the site induction, make workers aware of the following sensitivities:
reports
o What to do when encountering any of the following species: SEFG, Russian tortoise,
snakes etc.
● Provide works with a visual reference sheet

Manage potential Substation, PV and OHTL ● EPC Contractor to employ a local archaeologist to supervise excavation works (per the EPC Contractor Construction Contract with IOA
unexpected discovery of foundation work requirements of the Institute of Archaeology) 10. (subcontractors) phase

TheSpring / summerflorasurveyplannedfor the timewindowwhentheseedsofCalligonumareripe, andhavenot yet fallenfromtheparentplantswill beusedtoprovidefurtherclarityonthedistributionof thesespecies in theROWandinformtheseedplantingstrategyand
9

NHcompensationapproach.
The identificationofa suitablyqualifiedarchaeological teamcanbeundertakenwith thesupportof, or incoordinationwith, the localauthorities/mahallaor khokimiyat.
10

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archaeological remains/ ● Establish a chance finds procedure REF 18 Chance
artefacts ● Train workers on chance finds procedure during induction and all excavation works (via toolbox finds procedure
talks). Toolbox talk logs
● Maintain a chance finds log. Chance finds the
● Carry out ongoing discussions with local community members about the cultural significance of the register (if
Site as part of broader public consultation exercises. necessary)

Safeguard the wellbeing Livelihood restoration ● Implement ongoing livelihood restoration activities (if not already completed before construction) Project Company Construction REF06 LRP
and improve the living as per the LRP. phase Close out report
standards of those whose ● Monitor impacted households for at least three years to ensure they have at least returned to their
livelihoods are previous level of livelihood, if not improved their livelihood.
involuntarily displaced. ● Monitor the implementation of livelihood restoration activities
● Undertake livelihood restoration activities with all impacted households (the farm owner, herder
households and herder employees’ households).
Protect worker health and Establish Occupational Health and Safety (OHS) Management Plan requiring: EPC Contractor Construction REF10 Occupational
safety. (subcontractors) phase Health and Safety
● Management measures for dust, occupational noise, falls from height, electrocution risks etc.
Plan
● Site risk assessment for all tasks to be undertaken on the Site.
● Communicate hazards and risks to all workers during setting-to-work briefings. Risk assessment
● Mandatory PPE, including steel-toe capped boots, overalls, hard hat, hi-vis vest, safety glasses, hard
REF 08Worker Code
hat AND ear protection, gloves, and dust masks for specific tasks (e.g., welding).
of Conduct
● Worker Induction Program.
● Worker Code of Conduct. REF03 Training MP
● Training to all workers. including:
● OHS inspection and audits and ensure there is a corrective action process. Worker Induction
● Reporting occupational accidents, diseases, and incidents. Program
Training logs/
attendance sheets
REF01 ESMS
manual
Audit reports
Incident reports

Protect community health All works ● House workers from outside the project area or municipality in accommodation away from the EPC Contractor Construction REF08 L7WC MP
and safety. immediate communities at Kirlishon and Kulchovdur as much as possible, thereby reducing (subcontractors) phase inc. Worker Code
potential social tension. of Conduct
● Disclose community grievance mechanism to houses surrounding the worker accommodation. REF13 SMP
● Prepare a plan/strategy to guard workers and community members against contracting including protocols
communicable diseases. for vetting of
● Develop a Worker Code of Conduct to be read and signed by all workers on the contract during the security guards
induction process.
Training logs/
● Include the worker code of conduct, requirements for addressing potential GBVH risks on the
attendance sheets
Project and setting out a zero-tolerance policy for the following:
Signs in place
o Use of drugs, alcohol
Meeting minutes/
o Incidents of GBVH
attendance sheets
● Security personnel to not be armed unless prior approval from Project Company
● Ensure the security plan includes requirements for vetting security guards, training on using force,
security guard code of conduct etc.

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● Employ local security guards and female guards where possible. Number of
● Establish signs across the Project Site and along roads to warn local community members and grievances
other external stakeholders of any risks and hazards, e.g., from site vehicles and electrical received
equipment.
● Establish a Community Grievance Mechanism as set out in Project SEP (Volume V).
● Hold meetings with local herders to explain risks and issues at the start of work.
● Provide cultural awareness training for all workers.
● Disclose the EPRP to community members that may be impacted in an emergency or will be
required to assist (emergency services) during an emergency.
● Implement and disclose details of a community grievance mechanism, including GBVH
requirements.
● Nominate a CLO for the construction and operations phases.
● Determine whether training for community members on migrant workers or communicative
diseases is necessary and implement if needed (to be determined by the CLO).
GBVH All works ● Provide training and awareness-raising on GBVH Policy to all employees (including sub-contractor Project Company Construction REF19 GMP
employees). /EPC Contractor phase Training logs/
● Nominate a dedicated person for receiving GBVH grievances and train on how to respond to attendance sheets
incidents of a GBVH nature.
Number of GBVH
● Elaborate on GBVH referral pathways and mechanisms as part of the external grievance
grievances
mechanism.
received
● Providing safe, secure, and separate living spaces and sanitary facilities for the male and female
workers lockable sanitary facilities will be mandatory for women.
● Allow submission and investigation of anonymous sexual harassment complaints by workers and
host community members and protect the confidentiality of the complainants.
● Work closely with the local authorities to investigate any complaints relating to GBVH in the host
communities related to project workers.
● Provide targeted training (including life skills such as leadership and decision-making) and
awareness-raising to vulnerable workers such as women.
Labour wellbeing All works ● Require contractor (via EPC Contract) to conform to Masdar Human Resources (HR) Policy, Code of EPC Contractor Construction REF08 L&WC MP
Ethics, Policy Against Bribery and Corruption, Recruiting Policy, Supply Chain (Procurement) Policy, (subcontractors) phase Worker contracts
and Communication Policy.
Training logs/
● EPC Contractor and Tier 2/3 sub-contractors to demonstrate functioning HR policies to meet with
attendance sheets
Lender requirements, ILO core conventions and Uzbek law in contractor contracts.
Grievance
● Ensure all workers on the Project have a written project contract that would clearly specify their
terms of employment, consistent with the local labour law and the IFC PS2. The terms of mechanism
employment should be largely similar for all categories of the Project workers. Number of
● EPC Contractor and subcontractors to provide contract templates for review to ensure their overall grievances
compliance with the applicable labour standards. received
● Ensure that both migrant and local workers are engaged on substantially equivalent terms and Labour statistics
conditions.
● Provide an HR onboarding for all workers and explain the contract terms as per EBRD PR2.
● Establish a Workforce Grievance Mechanism and ensure confidentially and anonymity where
required.
● Ensure appropriate welfare provisions (water, shelter, sanitary facilities, food) at the Site.
● Ensure all workers receive the appropriate training as per the training need analysis and matrix
developed under the ESMS (note specific requirements for working within a substation or on live
equipment).
● Undertake daily toolbox talks at all work fronts.

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● See also requirements under Emergency Preparedness and Response.
● Provide all workers with notification of the duration of their contract at the start of work.
● Develop labour reporting statistics for all workers, including identifying labour statistics per worker
category (local, regional, international) and the split between male and female workers.

Emergency preparedness - All works Develop EPRP with the following minimum requirements: EPC Contractor Construction REF11 EPRP
general (subcontractors) phase
● Identification of the emergency scenarios. Site medical

● Specific emergency response for each situation relevant to the Project. services in place

● Emergency contacts and communication systems/protocols (including communication with Drill reports
Affected Communities when necessary).
● Outline of medical facilities and services required on-site in a Medical Services Procedure and a
Casualty Evacuation Procedure.
● Assess local emergency services capabilities and identify gaps that may need to be filled with site-
based emergency response capabilities in the form of a “capacity assessment” appended to the
EPRP (for approval).
● Procedures for interaction with government authorities (emergency, health, environmental
authorities), including names and contact details.
● Site plan indicating requirements for permanently stationed emergency equipment and facilities
(e.g., first aid stations, firefighting equipment, spill response equipment and personal protective
equipment (PPE) for the emergency response teams).
● Minimum requirements for trained medical professionals on-site, including first aid stations
● Develop protocols for the use of emergency equipment and facilities.
● Ensure clear identification of evacuation routes and Assembly Points (AP) for each work location
highlighted on a site plan.
● Identification of training requirements for all employees and third-party providers.
● Emergency drills and their frequency are based on assigned emergency levels or tiers and an
implementation schedule.
● Establish a site clinic to provide emergency first aid to employees capable of providing first aid
response to electrocution, falls from height, etc.
● Develop medical evacuation procedures to the nearest A&E facility.
Emergency preparedness All works ● Undertake continuous monitoring of weather events to enable an early warning of any high winds, EPC Contractor Construction REF11 EPRP
– climate risks/natural storms, dust storms, or extreme precipitation to enable workers to get to shelter. (subcontractors) phase Worker emergency
hazards ● Establish worker emergency shelter at the Site and protocols for extreme heat stroke cases. shelters
● During periods of high wind (15 km/h), dust-generating activities will not be permitted.
● Provide all workers with dust masks in the event of a localized dust event.
● Ensure sufficient supply of potable water at the work fronts (>3.5 L per worker per day).
● Ensure sufficient shelter/shade during summer months.
● Provide extra rest periods for workers when temperatures exceed 35 oC.
● Change the shift hours in line with the cooler hours.
● Ensure workers are not penalised for taking extra rest breaks during periods of extreme heat.
● Erect temporary shade at all work fronts for all workers.
Emergency preparedness Prepare Spill Response Plan (may be part of the EPRP) and include appropriate training and requirements EPC Contractor Construction REF11 EPRP – Spill
– Spill response for spill prevention and cleanup equipment including: (subcontractors) phase response
procedure
o Use barriers (e.g., drip trays) to minimise impacts from spills or other potential leaks.

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Objective Project Activity Action Responsibility Timescale Monitoring / KPI

o All chemicals, fuels, and oils are stored at the construction camps and laydown area to be
in designated areas in a secure and bunded facility.

o No herbicide uses.

o Do not refuel except at a dedicated refuelling area.

o All concrete washout to take place at designated concrete washout area only.

o All cement trucks must return to the batching facility or a dedicated wash-out facility to
perform cement washout.

● Works with hazardous liquids must be performed over an area of hardstanding to avoid seepage
to groundwater in the event of a spill.
Security Site/ROW/Accommodation ● Perform a Project Security Risk Assessment (SRA) EPC Contractor/ Construction REF13 including
Develop Security Management Plan including the following: Security contractor phase Project SRA
● Project security approach and systems, e.g., Security Barriers—such as fences, gates, locks, Security Code of
fortifying facilities, and means of access control Conduct
● Accommodation security
Training logs/
● Requirements for vetting security personnel, security uniform,
attendance sheets
● Requirements for training of security guards on human rights and use of force, weapons handling
(if needed), human rights and receipt of grievance
● Security Code of Conduct
Safeguarding community All works EPRP include a procedure for managing communicable diseases, including but not limited to the following EPC Contractor/ Construction REF11 EPRP
members and workers requirements: Security contractor phase
against communicable
● Measures to minimize the risk of contamination of site personnel from outside the project site (and
diseases (including COVID-
construction camp), particularly local workers not residing in the accommodation camp.
19)
● Measure to minimize the risk of transmission to the local community from site personnel.
● Emergency procedure in case of positive cases or outbreak (for affected personnel and potentially
affected personnel).
● Procedures for managing the risk of transmission to the local community (especially the
management of mixing workers from the community with those housed in workers'
accommodation).
● Provide PPE to reduce the risk of spreading COVID-19, such as masks and hand sanitizer (as
needed).

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6.5 Mitigation and management requirements – operation phase

Table 7: Mitigation and management requirements – operation

Objective Activity Action Responsibility Timescales Evidence

Compliance with national O&M works ● Obtain Stage 3 Environmental approval prior to the start of operation Project Company Pre-operation Stage 3 Resolution
requirements

Implement ESMS in line with O&M works ● Ensure ESMS includes relevant requirements for E&S and H&S-related training, Project Company Annually Annual ESMS audit
ISO14001 (environment) and communication, monitoring, reporting, accident incident reporting, auditing,
ISO45001 (health and safety). management review, and continuous improvement.

Operational management O&M works ● Develop Project O-ESMP. Project Company Annually Project O-ESMP (REF 20)
planning ● Ensure grievance mechanism is disclosed in project areas Annual reporting
● Maintain regular stakeholder engagement, at least annually.
GM Log
● All maintenance work to have a specific risk assessment addressing waste,
SE Log
climate risks H&S, hazardous material management, emergency preparedness
and response, and traffic risks) Risk Assessments

● Implement waste management practices in line with O-ESMP and MASDAR ESMS (maintenance works)

● Ensure correct PPE at all times Waste documentation

Project occupational health and Establish Occupational Health and Safety (OHS) Management Plan (REF 15) requiring: O&M Contractor Operation phase Project O-ESMP (REF 20)
safety (Project Company)
● Management measures for dust, occupational noise, falls from height, Occupational Health and

electrocution risks etc. Safety Plan

● Site risk assessment for all tasks to be undertaken on the Site. Risk assessment
● Communicate hazards and risks to all workers during setting-to-work briefings.
● Mandatory PPE, including steel-toe capped boots, overalls, hard hat, hi-vis vest, Worker Code of Conduct
safety glasses, hard hat AND ear protection, gloves, and dust masks for specific
Worker Induction Program
tasks (e.g., welding).
Training logs/ attendance
● Worker Induction Program.
sheets
● Worker Code of Conduct.
● Training to all workers. Audit reports

● OHS inspection and audits and ensure there is a corrective action process. Incident reports
● Reporting occupational accidents, diseases, and incidents.
Protect community health and ● Maintain Worker Code of Conduct to be read and signed by all workers on the O&M Contractor Operation phase Project O-ESMP (REF 20)
safety contract during the induction process. (Project Company) REF04 SEP
● Security personnel to not be armed unless prior approval from Project Company
● Ensure the security plan includes requirements for vetting security guards,
training on using force, security guard code of conduct etc.
● Employ local security guards and female guards where possible.
● Maintain CLO and Community Grievance Mechanism (as developed during
construction phase)
● Provide training and awareness-raising on GBVH Policy to all employees
(including sub-contractor employees).
● Nominate a dedicated person for receiving GBVH grievances and train on how to
respond to incidents of a GBVH nature.
● Elaborate on GBVH referral pathways and mechanisms as part of the external
grievance mechanism.
● Allow submission and investigation of anonymous sexual harassment complaints
by workers and host community members and protect the confidentiality of the
complainants.

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Objective Activity Action Responsibility Timescales Evidence

● Work closely with the local authorities to investigate any complaints relating to
GBVH in the host communities related to project workers.
● Provide targeted training (including life skills such as leadership and decision-
making) and awareness-raising to vulnerable workers such as women.
Labour wellbeing ● Require contractor (O&M contractor) to conform to Masdar Human Resources O&M Contractor Operation phase Project O-ESMP (REF 20)
(HR) Policy, Code of Ethics, Policy Against Bribery and Corruption, Recruiting (Project Company)
Policy, Supply Chain (Procurement) Policy, and Communication Policy.
● Contractors to demonstrate functioning HR policies to meet with Lender
requirements, ILO core conventions and Uzbek law in contractor contracts.
● Ensure all workers on the Project have a written project contract that would
clearly specify their terms of employment, consistent with the local labour law
and the IFC PS2. The terms of employment should be largely similar for all
categories of the Project workers
● Establish a Workforce Grievance Mechanism (WGM)and ensure confidentially
and anonymity where required.
● Ensure appropriate welfare provisions (water, shelter, sanitary facilities, food) at
the Site.
● Ensure all workers receive the appropriate training as per the training need
analysis and matrix developed under the ESMS, including training on the WGM
(note specific requirements for working within a substation or on live
equipment).
● Develop labour reporting statistics for all workers, including identifying labour
statistics per worker category
Emergency preparedness - ● Review and update EPRP (REF 14) for operation phase Project Company Operations phase - ongoing Project O-ESMP (REF 20)
general ● Undertake continuous monitoring of weather events to enable an early warning Monthly O&M reporting
of any high winds, storms, dust storms, or extreme precipitation to enable
workers to get to shelter
Security ● Updated Security Management Plan (REF 19) Project Company Operations phase - ongoing Project O-ESMP (REF 20)
Monthly O&M reporting

Minimize climate risk to workers O&M works ● Monitor climate risks as part of maintenance works risk assessments Project Company Operations phase - ongoing Project O-ESMP (REF 20)
performing O&M works. ● Ensure sufficient supply of potable water at the work fronts (>3.5 L per worker Monthly O&M reporting
per day).
● Ensure sufficient shelter/shade during summer months.
● Provide extra rest periods for workers when temperatures exceed 35 oC.
● Change the shift hours in line with the cooler hours.
● Ensure workers are not penalised for taking extra rest breaks during periods of
extreme heat.
● Erect temporary shade at all work fronts for all workers
Ensure rehabilitation of disturbed O&M works ● Implement the biodiversity management plan requirement for habitat Project Company Operations phase – 5 years or as Project O-ESMP (REF 20)
areas is successful. restoration for no-net loss. necessary REF16 BMP
● Monitor outputs
Monthly O&M reporting
Ensure livelihoods are not O&M works ● Monitor impacted households for at least three years to ensure they have at Project Company Operations phase Monthly O&M reporting
adversely impacted in the long- least returned to their previous level of livelihood, if not improved their
REF06 LRP
term livelihood.
● Monitor the implementation of livelihood restoration activities. Annual M&E report
(livelihoods)

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7 Monitoring and Reporting

7.1 Meetings

The Project will undertake the following meetings to be attended by a representative of

the Project Company and the EPC Contactor as defined in the cESMS:

● Mobilisation E&S meetings

● Weekly E&S meetings (Site)

● Monthly E&S meetings

7.2 Inspections and audits

As part of the EPC-ESMS, the EPC Contractor must develop an environmental and social
compliance program, including a schedule for E&S inspections, auditing and monitoring
to ensure compliance with national and international best practice requirements in the
E&S plans. The following activities will be included in the monitoring of the Project
performance:

● Daily site walkover – EPC Contactor

● Spot checks and walkovers – Project Company

● Weekly site inspections – EPC Contractor

● Fortnightly E&S Site inspections – EPC Contactor and Project Company

● Weekly E&S audit – Project Company (audit of one of the ESMS plans/ procedures
to ensure all plans are audited once every two months.

● Weekly EPC audits of subcontractor – EPC Contractor

● Independent labour audit (third party) for all subcontractors within 4 weeks of
mobilisation on site – EPC Contractor

● Quarterly E&S Audit – Project Company

● Subcontractor E&S Completion Audit – EPC Contractor

● Operational audits (at least quarterly, reduced to annual depending on risk) –

Project Company.

7.3 Reporting

The following reporting activities are required to be performed:

● Daily reporting (incidents, non-compliances) - EPC Contractor

● E&S weekly reports - EPC Contractor

● E&S monthly reports - EPC contractor

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● E&S completion report (at the end of the construction phase) – EPC Contractor

● Quarterly ES Monitoring report (ESMR) (submitted to lenders) – Project Company

(construction)

● E&S monthly report - Project Company (construction)

● Annual ESMR – Project Company (operation)

● Annual E&S report (for public disclosure) (construction & operation)

● E&S incident and deviation management report

The reporting will include (inter alia):

● KPIs for all monitoring activities and provisions for remedial actions, if required;

● EPC performance monitoring results, LRP implementation, Local Hiring and

Gender

● Management Plan implementation, and demonstrating compliance with

conditions of Environmental Approval and lender requirements;

The EPC Contractor and Project Company will establish and keep records of the activities
and related documentation to prove its conformity to the E&S requirements of the plans.

7.4 Monitoring

Table 8 sets out the monitoring proposed for the Project. A key aspect of monitoring is
defining relevant indicators. These are quantitative or qualitative measures of progress
against set goals in the cESMS plans and procedures and E&S policy and are just as
effective for measuring and monitoring the effectiveness of the cESMS. The Project
Company will define KPIs for the Project in the cESMS.

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T a ble 8: Monitoring and reporting obligations - construction

M o nitoring Para m eters Frequency & L o c a tio n R e p o r ti n g o blig a ti o n s R e s p o n s i b ilit y

D u r a tio n

M e t e or ology W i n d sp ee d, C o n ti n u o u s Site D a il y s u m m a r y E P C C o ntractor

t e m p e r a t u r e , r ai n f all.

O HS and N u m b e r s o f f a t aliti e s, M o nt hly Site M o n t h l y c o n s tr u c ti o n m o n it o ri n g r e p o r t. E P C C o ntractor

e n vir o n m e n t al a n d a c ci d e n t s a n d i nj u rie s
( N o t e d : t h e E P C c o n t r a c t d e fi n e s i m m e d i a t e
s o ci al st atistic s a n d n e ar mi s s e s.
r e p o rti n g o blig a ti o n s f o r a f at ality o r s e ri o u s E & S
(i n cl u d i n g C O V I D - 1 9 I n ci d e n t r e p o rti n g
inci d e nt)
st a tistic s) a n d f oll o w - u p

a c ti o n s.

D a il y H & S i n s p e c ti o n s

b y q u a lifi e d

p e r s o n n el.

C o n s t r u c ti o n a n d

o p e r a ti o n s a u diti n g,

in s p e c ti o n a n d

r e p o rti n g s c h e d ul e.

R e vi e w s of in ci d e nt

a n d acci d e n t

r e p o r ti n g , d r ill

r e p o rti n g a n d a n y

c o r r e c tiv e a cti o n s

i d e n ti fi e d , w h e r e

r ele v a n t.

E n vir o n m e n t:

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M o nitoring Para m eters Frequency & L o c a tio n R e p o r ti n g o blig a ti o n s R e s p o n s i b ilit y

D u r a tio n

P oll uti o n c o n t r ol - N u m b er of

r e p o r t e d s pills

(zer o or d o w n w a r d

tr e n d t o b e

m a i nt ai n e d)

- N u m b er of

r e p ort e d in ci d e n ts

of concrete

w as h o ut in

u n d esig n ate d ar e a

(zer o)

W aste - W e e kly an d M o nt hly Site M o n t hl y c o n s tr u c ti o n m o nit o ri n g r e p o rt E P C C o ntractor

m o nt hly w aste

g e n e r a ti o n

v olu m e s for

c o n s t r u c ti o n

w a stes (segreg ated

b y w aste strea m )

- O p e r a ti o n al w a s t e

strea m s

- W a ste contracts

w it h a ut h oris e d

w a st e dis p o s al

f a ciliti e s

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M o nitoring Para m eters Frequency & L o c a tio n R e p o r ti n g o blig a ti o n s R e s p o n s i b ilit y

D u r a tio n

- M o n t hly v olu m e of

w aste generated

(per ty p e)

Resource Use - V olu m e of M o nt hly Site M o n t hl y c o n s tr u c ti o n m o nit o ri n g r e p o rt. E P C C o ntractor

c o n s t r u c ti o n w a t e r

t a n k e r e d t o sit e.

- V olu m e of p ota ble

w a t e r d eliv er e d t o

sit e.

- N o u n a ut h oris e d

r ele a s e of

conta minated or

p o t e n ti all y

conta minated

w ater to A BIS ca n al

or gr o u n d (zer o)

E nviro n m e nt D u s t e pi s o d e s , s oili n g D a il y ( vi s u al) Site D a il y i n s p e c ti o n c h e c k s h e e t E P C C o ntractor

o f v e g e t a ti o n, d u s t

resu s p e n sio n o n th e

roads and dust

cl o u d s at w o r k fr o nt s,

e ffic a c y o f

st or m w a t er dr ai n a g e

syste m, A BIS ca n al

q u ality (vis u al)

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M o nitoring Para m eters Frequency & L o c a tio n R e p o r ti n g o blig a ti o n s R e s p o n s i b ilit y

D u r a tio n

C ultur al h erita g e - L o g a n d r e p o r t all A s r el e v a nt Site M o nt hly E P C C o ntractor

c h a n c e fi n d s
i d e n ti fi e d .
- S h o ul d it e m s of
c ultur al h erita g e b e
foun d on or near
t h e P r oj e ct sit e,
thes e sh o uld be
r e g ul arly
m o nitore d to
e nsure they are
pr o p erly
sig n p o st e d, th eir
b uffer zo n es ar e
m a i nt ai n e d a n d
that no har m has
c o m e t o t h e ite m s.

Labour and w orker N u m b e r of w o r k er s, W e e kly Site M o n t hl y c o n s tr u c ti o n m o nit o ri n g r e p o rt E P C C o ntractor

g ri e v a n c e st atistic s gen d er of w orkers

a n d if t h e y ar e l o c al

or not and

su b c o ntractor

st a tistic s.

Labour C o m p lia n c e of M o nt hly Labour M o n t hl y c o n s tr u c ti o n m o nit o ri n g r e p o rt o r E P C C o ntractor

a c c o m m o d a ti o n a c c o m m o d a ti o n a c c o m m o d a ti o n a c c o m m o d a ti o n a u dit re p o rt

ag ainst th e lab o ur

a c c o m m o d a ti o n pl a n

L a b o u r a n d w o r ki n g R e vi e w of w o r ki n g M o nt hly Site M o n t hl y c o n s tr u c ti o n m o nit o ri n g r e p o rt o r l a b o u r E P C C o ntractor

c o n diti o n s c o n diti o n s, p a y s h e e t s a u dit rep ort

a n d p a y sli p s, l e a v e

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M o nitoring Para m eters Frequency & L o c a tio n R e p o r ti n g o blig a ti o n s R e s p o n s i b ilit y

D u r a tio n

all o c a ti o n, a n d

intervie w wit h

w o r k e r s t o v erify

fi n d i n g s .

S e c u rity in ci d e n t s S e c u rity in ci d e n c e. M o nt hly Site M o n t hl y c o n s tr u c ti o n m o nit o ri n g r e p o rt E P C C o ntractor

I n ci d e n t r e p o rti n g

a n d f oll o w - u p

a c ti o n s.

Stak e h old er Stak e h old er M o nt hly Sit e/l o c al c o m m u n iti e s M o n t hl y c o n s tr u c ti o n m o nit o ri n g r e p o rt E P C C o ntractor

engage m ent engage m ent

co m pleted

(sta k e h ol d er lo g)

- Stak e h old er

engage m ent

co m pleted

(sta k e h ol d er lo g)

- P erio dic foc u s

gr o u p s with

co m m u nity

m e m b ers to

id e ntify a n y

i m p a cts r el at e d t o

i n fl u x o f p e o p l e

an d p ut togeth er

m i ti g a ti o n

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M o nitoring Para m eters Frequency & L o c a tio n R e p o r ti n g o blig a ti o n s R e s p o n s i b ilit y

D u r a tio n

m e a s u r e s, if

i d e n ti fi e d .

G rieva nc es - N u m b er of M o nt hly Sit e/l o c al c o m m u n iti e s M o n t hl y c o n s tr u c ti o n m o nit o ri n g r e p o rt E P C C o ntractor

co m m u nity

griev a n c e s rec eiv e d

( g ri e v a n c e l o g ).

Responses and

f oll o w - u p a c ti o n s

( e. g., C o n d u c t n o i s e

m o nit oring in th e

e v e n t of a n ois e

c o m pl ai nt or

e vid e n c e of

excee da nce of

co m m u nity n oise

g u i d e li n e s v al u e s )

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Table 9: Monitoring and reporting obligations - operation

M o nitoring Para m eters Frequency & L o c a tio n R e p o rti n g R e s p o n s i b ilit y

D u r a tio n o blig atio n s

O H S a n d e n vir o n m e n t al N u m b e r s o f f a t aliti e s, a c ci d e n t s, A n n u ally Site A n n u al o p e r a ti o n s Pr oject C o m p a n y

a n d s o ci al st atistics a n d i nj u ri e s. I n ci d e n t r e p o r ti n g m o nit oring re p ort

(i n cl u d i n g C O V I D - 1 9 a n d f oll o w - u p a c ti o n s.

st a tistic s)
E n vir o n m e n t: w a st e, w a ter u s e

L a b o u r st a ti s ti c s N u m b e r of w o r k er s, g e n d er of A n n u ally Site A n n u al o p e r a ti o n s Pr oject C o m p a n y

w o r k e r s a n d if t h e y ar e lo c al o r m o nit oring re p ort

n o t.

L a b o u r a n d w o r ki n g R e v i e w o f w o r ki n g c o n d i ti o n s, A n n u ally Site A n n u al o p e r a ti o n s Pr oject C o m p a n y

c o n diti o n s p a y s h e et s a n d p a y sli p s, le a v e m o nit oring re p ort or

all o c a ti o n, a n d i nt e r vi e w wit h lab o ur au dit rep ort

w o r k e r s t o v e ri f y fi n d i n g s .

S e c u rity in ci d e n t s S e c u rity in ci d e n t s A n n u ally Site A n n u al o p e r a ti o n s Pr oject C o m p a n y

m o nit oring re p ort

Stak e h old er Stak e h old er en g ag e m e n t A n n u ally Sit e/l o c al A n n u al o p e r a ti o n s Pr oject C o m p a n y

engage m ent co m pleted c o m m u n iti e s m o nit oring re p ort

G rieva nc es N u m b er of w or k er/c o m m u nity A n n u ally Sit e/l o c al A n n u al o p e r a ti o n s Pr oject C o m p a n y

g rie v a n c e s r e c eiv e d ( e. g n ois e). c o m m u n iti e s m o nit oring re p ort

B i o di v e r sity H e c t a r e s o f t e m p o r a ril y A n n u a ll y f o r t h e fi r s t Site A n n u al o p e r a ti o n s Pr oject C o m p a n y

d i s t u r b e d s o il. fi v e y e a r s m o nit oring re p ort

B i o di v e r sity M o n it o r t h e eff e ctiv e n e s s of off- A n n u a l f o r t h e fi r s t fi v e Site A n n u al C H m o n it ori n g Pr oject C o m p a n y

sit e v e g e t ati o n y e a r s. rep ort an d n o n et loss

r e s t o r a ti o n / r e h a b ilit a ti o n t o

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M o nitoring Para m eters Frequency & L o c a tio n R e p o rti n g R e s p o n s i b ilit y

D u r a tio n o blig atio n s

co m p e nsate for per m a n e nt r e p o r t (i n cl u d i n g N N L

h a bitat loss ag ain st N N L K PI c al c ul ati o n)

indicators set o ut in the B M P.

Li v eli h o o d r e s t o r a ti o n Li v eli h o o d r e s t o r a ti o n F o r t h e fi r s t t h r e e PAC A n n u al M & E re p ort Pr oject C o m p a n y

years

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7.5 Document control

A complete and up-to-date E&S file of all relevant sources of information will be
maintained by the designated E&S manager for all phases of the Project and by the
Project Company and EPC Contractor.

This E&S file will be readily accessible and include, as a minimum, copies of the following
documents:

● Current environmental permits and consents.

● All relevant national and international regulations, international guidelines and

codes of practice.

● Current calibration certificates for all the equipment that requires calibration by
an external organization.

● The latest version of the ESMP.

● Records for environmental monitoring (inspection forms) and audits.

● Record of the construction programme.

● Manufacturers’ operating manuals for all the environmental monitoring

equipment.

● Equipment maintenance and repair records.

● Correspondences in relation to environmental matters/permits, including internal

and external.

● Minutes of relevant meetings.

● Training records (e.g., attendance records for inductions and environmental

awareness training).

● Current workforce statistics (including gender and local/non-local) and emergency

contact details for workers.

8 Stakeholder Engagement
All communication, as well as the stakeholders identified, is documented in the Project
Stakeholder Engagement Plan (SEP) that is subject to public disclosure.

For the ESIA phase, a SEP has been prepared (ESIA Volume V - SEP) that presents a
detailed plan for stakeholder engagement obligations for the pre-construction,
construction, operation, and decommissioning phases. The Project is required to:

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● Inform and consult with local communities and other relevant stakeholders before
the development of the facility on potential impacts, management measures and
potential opportunities.

● Publicize the Project grievance mechanism with local communities.

● Maintain meaningful dialogue through consultations and information disclosure

with local communities and other relevant stakeholders.

● Develop a communication records procedure to log key information from and to

stakeholders.

During construction, responsibility for the implementation of the requirements of the SEP
will be the Project Company supported by the EPC Contractor. The EPC Contractor will
appoint a dedicated Community Liaison Officer to manage the stakeholder relations
defined in the Project SEP and any new obligations identified post-finalization of the ESIA.
A Grievance Redress Committee will also be established by the Project Company.

Internal communication between the Project Company, EPC Contractor and workers
must be defined in a Project Internal Communication Plan in the cESMS and EPC ESMS
(as described above).

9 Grievance Mechanism
A community grievance mechanism has been defined and is described in the SEP. The
Project Company will manage the grievance mechanism.

10 Budget

Indicative costs are provided in Table 10

Table 10: Indicative costs for PC / PMC implementation and supporting activities - construction

Requirements (PMC/SPV
Cost Unit Total Assumptions
Construction)
Labour
Masdar staff inputs (covers supply Construction (18months). Covered by
0 0
chain management) existing salaries.
Project Company staff (HSSE Construction (18months) / US$ 7,000 per
7,000 36 252,000
Manager and CLO) (contsruction) person per month
PMC Staff (E&S Manager) Construction (18months) / US$ 5,000 per
5,000 18 90,000
(construction) person per month
Stakeholder engagement
Construction (18 months). Labour
implementation and grievance
18,000 1 18,000 included in Staff costs above, plus 1000
management (including local
per month expenses.
hiring liaison) (excluding labour)
Stakeholder engagement
implementation and grievance
2,000 25 50,000 Operaition (25 years)
management (including local
hiring liaison) (excluding labour)

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Requirements (PMC/SPV
Cost Unit Total Assumptions
Construction)
Operational E&S manager 0 25 0 (masdar to define)
Operational CLO 0 25 0 (masdar to define)
LESC / permitting costs
Stage 3 Approval submission 15,000 1 One time
Construction permits 9submisison Masdar to define Labour costs in team
0
fees) above
Bi-annually (need to do quarterly during
LESC costs 40,380 3 121,140 construction and annually during
operation - needs updating
Biodiversity Management Plan
Land costs for offset 0 1 0 Not required at this time.
Baseline characterization and
seed collection for 3 spp. of red 2500 1 2500 one time
listed Calligonum shrubs
NNL implementation plan (labour)
15,000 5 75,000 per year.
(inc., bird fatality chance finds)
NNL implementation costs
(consultants, seeds, materials, 10,000 5 50,000 per year.
water)
Offset monitoring and evaluation 4,000 12 48,000 3-year monitoring program (quarterly)
E&S Management
Establish PC/SPV cESMS (including
PC supporting management 0 0 0 Covered by labour costs above
plans, training, inspections, audits)
Develop operational management
Covered by labour costs above
plan
Community development 0 0 0 To be defined.
LRP implementation
Vulnerability allowance (food
2,159 1 2,159 one off cost (split across 9 PAPs)
basket) (H1, H2, and V1 to V7)
Livelihood restoration - Financial
2,502 1 2,502 one off cost
awareness training
Livelihood restoration - Livestock
2,502 1 2,502 one off cost
management training
Livelihood restoration -
1,001 1 1,001 one off cost
Agricultural training
Livelihood restoration provision of
117 1 117 one off cost (split across 9 PAPs)
saplings and seeds
Livelihood restoration provision of
22 1 22 one off cost (split across 9 PAPs)
hand tools for agriculture
M&E report 15,000 1 15,000 3-year monitoring program (quarterly)
Third party inputs
Local training (as defined in
5,000 1 5,000 One time
Labour Plan)
Specialist input/studies (third
party labour audit, ecology 35,000 1 35,000 One time
specialist)
Institutional Strengthening and Capacity Building (for EPC Contractor/PMC)

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Requirements (PMC/SPV
Cost Unit Total Assumptions
Construction)
Preparation of Training 25,000 1 25,000 One time (optional)
Trainer 25,000 1 25,000 One time (Optional)
TOTAL 672544

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Appendix
11 Annex A: Project E&S Policy
[Insert Company Logo]

[INSERT PROJECT NAME]

[The Company] E&S Policy

The Project Company is committed to achieve a positive contribution to sustainable development and to
protect Human Rights. This requires, inter alia, the protection of the environment and the wellbeing of its
employees, contractors and the local community, through all stages of the project life cycle, as well as
participative and transparent stakeholder engagement. To achieve these goals, the Project Company is
committed to:

E&S Management

 Comply with applicable national and local E&S laws and regulations as well as permitting requirements,
applicable International Conventions, international requirements, and Project specific E&S obligations
including the applicable requirements of the IFC Performance Standards and Asian Development Bank
(ADB) Safeguard Policy Statement 2009 (ADB SPS 2009).

 Identify, assess and mitigate potential impacts to the community, workers and the environment.

 Establish and maintain an Environmental & Social Management System (ESMS) which identifies
objectives and targets, impacts, risks and hazards, responsibilities, and includes systems of monitoring
and reporting as well as incident and accident reporting and investigation.

 Realize continual improvement in E&S performance by developing indicators, through monitoring and
auditing performance, and by implementing corrective actions where needed.

 Report externally on E&S performance and encourage dialogue with employees, local communities and
other stakeholders to promote awareness.

 Provide the necessary training and resources, which ensures that employees and contractors are made
aware of this Policy and are adequately trained to manage the project E&S risks and impacts to meet the
E&S responsibilities and commitments.

 Communicate our E&S Policy to our contractors, subcontractors and third parties and require
compliance to it.

 Setup a Grievance Mechanism for workers and the community to express concerns without retaliation.

Environment

 Achieve a target of Zero significant environmental accidents.

 Set and achieve targets that promote the efficient use of natural resources.

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 Minimize and manage all waste streams and where waste is generated ensure that it will be handled and
disposed of safely and responsibly according to the waste mitigation hierarchy of “prevent, reuse,
recycle”.

 Protect and conserve biodiversity.

 Promote sustainable management and use of natural resources through the adoption of practices that
integrate conservation needs with the project.

 Address climate change and GHG-emissions impacts, minimize emissions, and enhance positive impacts.

 Avoid pollution of water, air and land

 Ensure safe management of hazardous substances.

Health and Safety (H&S), Labor and Working Conditions

 Commitment to adherence to core labor standards

 Achieve a target of Zero fatalities and Zero injuries.

 Strict compliance with the H&S rules and procedures defined for the project.

 Provide a place of work that is safe for workers and communities.

 Prohibition and zero tolerance to children and forced labor. Screening of contractors, subcontractors
and supply chain on child and forced labor will be taken into account.

 Screen supply chain to minimize labor risks.

 Provide satisfactory working conditions and implement mechanisms to ensure that workers can
meaningfully enjoy their rights.

 Promote a safe, equal, and inclusive workplace, ensuring a work environment free of harassment or
discrimination on the basis of gender, nationality, religion, sexual orientation, or any other personal or
cultural attribute.

Social

 Ensure community health, safety and security throughout all activities undertaken.

 Support and protect human rights.

 Ensure a positive contribution to local development and social impact.

 Provide satisfactory compensation and livelihood restoration for formal and informal land users affected
by the Project.

 Maintain informed consultation and participation with stakeholders and affected communities on
matters that affect them such as mitigation measures, sharing of benefits and opportunities, and ESMS
implementation.

 Recognize the importance of women in development, consider gender-specific impacts and risks and
promoting women’s rights.

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 Ensure Zero tolerance to gender-based or any other type of violence, harassment, and any form of
discrimination. Ensure gender equality among project workers and employees and promote the
participation of women in the Project.

The Project Company will monitor and review this Policy on a regular basis to ensure that it continues to
support and encourage a high standard of E&S performance.

[Signature]________________________________

Date: ____________

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