IFC Performance Standards
The IFC Performance Standards, of which there are currently eight in circulation, coupled with the World Bank sector specific Environmental, Health & Safety (“EHS”) Guidelines, represent an energy industry operational benchmark for the identification and management of all aspects of a company’s sustainable development, performance and reporting disciplines.
Savannah Energy’s subsidiary, Accugas, operates within, and is aligned to, the requirements of the IFC Performance Standards and Environmental, Health & Safety (“EHS”) Guidelines. To achieve alignment to the IFC PS, Accugas has developed operational policies and implemented the associated management systems that are in line with the requirements of the IFC PS. Accugas has also developed and deployed an operational personnel management structure or organogram (both field and office based) that is both robust, extensive, experienced and fit for purpose.
A high level overview, with key points, of how Accugas achieved this level of alignment with the IFC PS during 2019 is as follows:
IFC PS 1 sets out a number of requirements for the assessment and management of the Company’s environmental and social ‘risks and impacts’. Accugas has achieved alignment to PS 1 via the development and deployment of:
- specific and focused operational policies;
- a process for the continual and ongoing identification and assessment of the Company’s operational and project safety, environmental and social related risks and impacts;
- a continually updated environmental and social management system (‘ESMS’);
- a Company-wide emergency preparedness and response plan which is constantly tested and rehearsed at both bench top and field levels; and
- a number of processes designed to monitor and measure the effectiveness of the above risk/impact management areas.
IFC PS 2 relates to the creation and deployment of systems that governs the Company’s management of labour and working conditions. Accugas has achieved and maintained its alignment with this Standard via;
- the creation and communication to the workforce of a Company policy that provides a framework of processes related to the engagement of staff and the associated terms and conditions of employment;
- a communication to all staff informing how the Company complies with local, regional, national and international labour laws and where this information can be found; and
- implementation of detailed exit management, grievance recording, forced labour compliance, child labour compliance and enforcement of equal opportunities’ policies and processes.
IFC PS 3 describes an operational and project level approach to controlling the use by the Company of natural resources and also preventing/minimising any pollutive impacts arising from the Company’s operations, activities and projects. Accugas has ensured compliance with this Standard via:
- the development and implementation of both operational and project environmental management plans (‘EMP’);
- the formation of a multi-disciplinary team to identify operational and project environmental and social risks;
- the development of policies prohibiting the use of CFCs and ozone depleting gases throughout the Company; and
- the development of a full suite of resource usage and emissions monitoring protocols and review processes.
IFC PS 4 key objective is to anticipate and avoid any adverse impacts on and to the health, safety and security of the Company’s ‘footprint’ communities and other related stakeholders as a result of the Company’s operations, activities and projects. Accugas achieved alignment the requirements of PS 4 by:
- ensuring the design and engineering of all projects and pipelines met the related international standards for integrity, safety and performance thereby minimising/ avoiding any risk to the footprint communities;
- the inventorying and safe storage of hazardous material used by the Company;
- minimising land usage and avoiding the loss of community natural ‘buffer’ areas such as wetlands, swamps, forests; and
- education and sensitisation of the local communities with respect to possible emergency and security scenarios and their roles therein.
IFC PS 5 relates to the responsibilities and commitments of the Company with respect to the requirement for land acquisition and possible involuntary resettlement/physical displacement, and the avoidance of any adverse impacts on the land owners and community members such as income loss, livelihood or economic loss. During the implementation of any of its projects and operational activities, Accugas deployed a very carefully planned, constructed and extensive ‘Relocation Action Plan’ and ‘Livelihood Restoration Plan’ thereby ensuring that:
- an accurate and up to date register of affected persons was implemented to ensure a fair and generous compensation package was offered to eligible land owners and displaced people etc; and
- measures were also taken to ensure that, where possible, locations were chosen to avoid and/or minimise any potential impacts on communities.
IFC PS 6 recognises that protecting and conserving biodiversity, maintaining ecosystem services and sustainably managing natural resources are fundamental to ‘Sustainable Development.’ Accugas ensured alignment with PS 6 via:
- carefully identifying the Company’s impacts on biodiversity within the Environmental and Social Impact Assessment (“ESIA”) process;
- where impacts on biodiversity could not be avoided, mitigation measures were developed and deployed; and
- project planning always included the minimisation of land uptake where feasible and principles of erosion prevention were implemented.
Nigeria has a long history of oil/gas exploration and production and is, therefore, a mature operator in the international energy sector. As such, many different tribes and peoples from all parts of the country have, over a long history, been attracted and migrated to the many employment offers and entrepreneurial opportunities that the development of the energy industry has realised over many years. Consequently, no ‘one tribe or people’ can rightfully lay claim to a given city or region of operations where a potential energy development may be commencing or has been present for many years. Therefore, in line with the IFC interpretation of PS 7, it has been accepted that this particular Standard is non-applicable in Nigeria.
IFC PS 8 key tenets are to protect cultural heritage from the adverse impacts of the Company’s operations, activities and projects and, where possible, to promote the equitable sharing of any benefits from the proven use of any encountered/observed cultural heritage. To achieve alignment with these tenets via:
- Accugas has been careful in identifying and documenting all examples of ‘cultural heritage’ in its operational and project locations via the use of the ESIA and project planning processes and, via extensive field investigations and consultation processes (including literature surveys);
- the considered decision by management to ‘avoid’ any/all community sites including shrines, graves, cemeteries, and community sacred places; and
- the development and implementation of a ‘Chance Find’ standard operating procedure at the project planning and construction phases.