Board of Directors Meeting

Wednesday, December 6, 2023

This event is closed to the public 

Information summaries for the below listed projects can be found below. 

Meeting Agenda 

I. CHAIRMAN OPENS MEETING

II. CEO’s REMARKS

III. PESNETATION ON DFC’S ENVIROMENTAL AND SOCIAL POLICIES AND

PROCEDURES

IV. PROJECT APPROVALS

a. AMEA Power, Ltd. (Amunet Wind Power)

b. AMEA Power, Ltd. (Abydos Solar PV)

c. Indorama Eleme Fertilizer and Chemicals Limited/SPV Line III

d. PT Medco Cahaya Geothermal

e. Bulgartransgaz EAD

f. Eversource Climate Investment Partners II

g. CRDB Bank PLC

h. Prodigy Finance Ltd

V. REPORTS

a. Audit Committee Report to the Board

VI. CHAIRMAN ADJOURNS MEETING
B-1

Public Information Summary

Host Country Arab Republic of Egypt (“Egypt”)

Name of Insured Party AMEA Power Ltd. (the “Insured” or “AMEA”)

Private Insurer 

Participation

Private Reinsurers 

Project Description Development, construction, and operation of a 500 megawatt wind 

power plant and associated infrastructure in the Red Sea Governorate of 

Egypt.

Investment Amount Up to $100,000,000

Investment Type Equity

Proposed Insurance 

Amount

Up to $100,000,000

Total Project Costs $670,000,000

U.S. Involvement None

Foreign Enterprise Amunet Wind Power Company S.A.E.

Policy ReviewDevelopmental Objectives The Project is expected to have a positive development impact in Egypt 

by fueling the government’s energy diversification strategy, helping to 

decarbonize its grid through wind power, and terminating the 

development of a coal fired power plant as part of the award agreement. 

The wind farm is expected to generate approximately 2,000 GWh/year, 

and will be the largest of its kind on the African continent.

Environment and Social 

Assessment

SCREENING: The Project has been reviewed against DFC’s 

categorical prohibitions and determined to be eligible. The Project is 

screened as Category A because greenfield wind projects are considered 

to have significant adverse environmental and social impacts that could 

be diverse, irreversible, or unprecedented. The Project area (and wider 

landscape) is associated with a number of globally important migratory 

soaring birds concentrated at the Gebel El Zeit Important Bird and 

Biodiversity Area (IBA) and surrounding area. 

APPLICABLE STANDARDS: The Project is subject to DFC’s 2020 

Environmental and Social Policy and Procedures (“ESPP”). Under 

DFC’s ESPP, the Insured is required to comply with applicable national 

laws and regulations related to environmental and social performance. 

In addition, DFC’s preliminary environmental and social due diligence 

indicates that the Project will have impacts that must be managed in a 

manner consistent with the following of the International Finance 

Corporation’s (IFC) 2012 Performance Standards:
B-2

• PS 1: Assessment and Management of Environmental and Social 

Risks and Impacts;

• PS 2: Labor and Working Conditions;

• PS 3: Resource Efficiency and Pollution Prevention;

• PS 4: Community Health, Safety, and Security; and

• PS 6: Biodiversity Conservation and Sustainable Management of 

Living Natural Resources

The Project will be developed on vacant land owned by the Egyptian 

government’s New and Renewable Energy Authority and made 

available to the Project under a Usufruct Agreement. A desk-based due 

diligence assessment indicates that the land has no inhabitants or active 

land use, and the Project will not have significant impacts with respect 

to indigenous people and cultural heritage. Therefore, PS 5, 7, and 8 are 

not triggered at this time. Applicable provisions of the IFC General 

Environmental, Health and Safety (EHS) Guidelines, EHS Guidelines 

for Wind Energy, and EHS Guidelines for Transmission and 

Distribution also apply to the Project. The Project will also be required 

to adhere to the IFC/EBRD Processes and Standards for Workers’ 

Accommodations. 

ESIA Disclosure: The ESIA package was posted on DFC’s website for 

public disclosure on September 21, 2023 and is available for public 

comment until November 20, 2023. No comments had been received at 

the time this summary was drafted. If any comments are received, they 

will be shared with the Board along with DFC’s responses at least five 

days prior to the Board meeting.

Environmental and Social Risks and Mitigation Measures: Primary 

environmental and social issues of concern include the potential for 

impacts on resident and migrating birds, community health and safety, 

social risks connected to the supply chain, construction labor 

management, and the need for appropriate stakeholder engagement, 

particularly with the Bedouin community. 

The Project overlaps by less than 1km2 with the northern edge of the 

Gebel El Zeit Important Bird and Biodiversity Area (IBA), which is also 

a Key Biodiversity Area (KBA). The Gebel El Zeit IBA/KBA is 

situated within the Rift Valley / Red Sea flyway, a globally important 

corridor for migratory soaring birds (MSBs) and is located where large 

numbers of birds are funneled along the Gulf of Suez during their spring 

and autumn migration, often landing in large numbers and flying at low 

altitudes. Therefore, the Project has the potential to impact MSBs during 

their migration. To mitigate these potential impacts, the Project will be 

required to develop, implement, and manage: a Post Construction 

Fatality Monitoring (PCFM) program for turbines and the transmission 
B-3

line, a radar-assisted turbine shutdown on-demand program (SOD), and 

an operations phase Biodiversity Management Plan. The PCFM and 

SOD programs will be conducted by staff trained at the Migratory 

Soaring Birds Center of Excellence in Ras Ghareb, or otherwise 

qualified/experienced to conduct these types of monitoring and 

mitigation activities for MSBs in the Gulf of Suez.

A Critical Habitat Assessment (CHA) determined that the Project is 

within Critical Habitat for five MSB species: Steppe Eagle (IUCN Red 

List – Endangered), Levant Sparrowhawk (IUCN Red List – Least 

Concern), Black Stork (IUCN Red List – Least Concern), Great White 

Pelican (IUCN Red List – Least Concern), and White Stork (IUCN Red 

List – Least Concern). The Project will develop and finalize a fit-forpurpose Biodiversity Action Plan (BAP) and Biodiversity Monitoring 

and Evaluation Plan.

In terms of the Project’s overall environmental and social management, 

AMEA has prepared a project-specific Environmental and Social 

Management System (ESMS) Manual, which requires the EPC and 

O&M Contractor to develop and implement their own ESMS manuals

and related site-specific E&S management plans in compliance with PS 

1. In addition, the Project has a Stakeholder Engagement Plan, which 

will be updated regularly, and has appointed a Community Liaison 

Officer. An external grievance mechanism will be available for 

questions and complaints from members of the public.

Peak construction will require roughly 1,500 workers. The Project will 

be required to develop and implement a robust labor management 

system that covers directly employed, contracted, and supply chain 

workers. An internal grievance mechanism will also be available to all 

workers, including workers employed through third parties. 

AMEA has a corporate level procedure that addresses child and forced 

labor risks in the supply chain. The Project will also be required to 

develop and implement a supply chain management system for labor 

risks, which will include supplier mapping, risk assessment, monitoring, 

and a supplier code of conduct. A previous third-party labor audit 

commissioned to assess the Project’s wind turbine generator supplier 

facilities did not uncover evidence of forced or child labor. 

Potential impacts to community health and safety include those 

resulting from worker influx, security, and traffic-related risks due to 

transport of Project equipment, construction materials, and workers to 

and from the Project site. The Project will develop and implement a 

Community Health and Safety and Labor Influx Management Plan. In 

addition, the Project will be required to implement control measures to 
B-4

protect local community members from road traffic accidents and use 

in-vehicle monitoring systems to monitor all project-assigned vehicles. 

The Project will also be required to develop and implement a Security 

Management Plan, which will include a security risk assessment and a 

Code of Conduct for security personnel. 
B-1

Public Information Summary

Host Country Arab Republic of Egypt (“Egypt”)

Name of Insured Party AMEA Power, Ltd (the “Insured” or “AMEA”) 

Private Insurer 

Participation

Private Reinsurers 

Project Description Development, construction, and operation of an approximately 500 

megawatt solar photovoltaic power plant and associated infrastructure 

located in Aswan Governorate, Egypt.

Investment Amount Up to $110,000,000

Investment Type Equity

Insurance Amount Up to $110,000,000

Total Project Costs $320,950,000

U.S. Involvement None 

Foreign Enterprise Abydos Solar Power Company S.A.E

Policy Review

Developmental Objectives The Project is expected to have a positive development impact in Egypt 

by fueling the government’s energy diversification strategy, helping to 

decarbonize its grid through solar power, and terminating the 

development of a coal fired power plant as part of the award agreement. 

The 500 MW solar power plant will be Egypt’s largest single solar 

independent power producer (IPP).

Environment and Social 

Assessment

SCREENING: The Project has been reviewed against DFC’s 

categorical prohibitions and determined to be eligible. The Project is 

screened as Category B under DFC’s environmental and social policies 

and procedures because potential adverse environmental or social risks

and/or impacts are limited, few in number, site-specific, largely 

reversible, and readily addressed through mitigation measures. 

APPLICABLE STANDARDS

The Project is subject to DFC’s 2020 Environmental and Social Policy 

and Procedures (“ESPP”). Under DFC’s ESPP, the Project Sponsor is 

required to comply with applicable national laws and regulations related 

to environmental and social performance. In addition, DFC’s 

preliminary environmental and social due diligence indicates that the 

Project will have impacts that must be managed in a manner consistent 

with the following of the International Finance Corporation’s (IFC) 

2012 Performance Standards: 

• PS 1: Assessment and Management of Environmental and Social

Risks and Impacts;
B-2

• PS 2: Labor and Working Conditions;

• PS 3: Resource Efficiency and Pollution Prevention; and

• PS 4: Community Health, Safety, and Security.

The Project will be developed on land leased through the Egyptian 

government’s New and Renewable Energy Authority. A desk-based due 

diligence assessment indicates that the land has no inhabitants or active 

land use, and the Project will not have significant impacts with respect 

to biodiversity, indigenous people, and cultural heritage. Therefore, PS 

5, 6, 7, and 8 are not triggered at this time. Applicable provisions of the 

IFC General Environmental, Health and Safety (EHS) Guidelines and 

EHS Guidelines for Transmission and Distribution also apply to the 

Project. The Project may also be required to adhere to the IFC/EBRD 

Processes and Standards for Workers’ Accommodations. 

Environmental and Social Risks and Mitigation. The key 

environmental and social risks associated with the Project include the 

need for a robust environmental and social management system, 

oversight of EPC and O&M contractors to ensure the Project is 

constructed and operated in accordance with IFC Performance 

Standards, management of community health and safety impacts, water 

and waste management, management of labor risks in the supply chain, 

robust stakeholder engagement, and management of bird collision risks 

from associated facilities. 

AMEA has prepared a project-specific Environmental and Social 

Management System (ESMS) Manual, under which the EPC and O&M 

Contractors are required to develop site-specific Environmental and 

Social Management Plans. The Project previously carried out an 

Environmental and Social Impact Assessment, aligned with local 

requirements and IFC Performance Standards. AMEA has provided an 

updated Environmental and Social Action Plan developed during due 

diligence from other Lenders, including IFC, showing progressive 

closeout of outstanding gaps. DFC will require that AMEA provide to 

DFC ESAP deliverables within the timelines dictated by the Lenders’ 

ESAP.

The Project has in place a Stakeholder Engagement Plan and plans to 

employ two Community Liaison Officers to manage relationships with 

nearby communities. In addition, the Project will be required to have an 

external grievance mechanism, in alignment with IFC Performance 

Standard 1.

Peak construction will require roughly 1,500 workers. The Project will 

be required to develop and implement a robust labor management 

system, including an internal grievance mechanism, that encompasses 

all Project workers, including those employed through third parties. In 
B-3

addition, the Project will be required to develop and implement an 

Occupational Health and Safety Management System for both the 

construction and operation phases. 

AMEA has a corporate level procedure that addresses child and forced 

labor risks in the supply chain. The Project will also be required to 

develop operationalized Project-level procedures for supply chain 

management with respect to labor risks. 

Potential impacts to community health and safety include those 

resulting from worker influx and accommodations, security, and trafficrelated risks. The Project will be required to develop and implement a 

workers’ accommodation plan, workers’ code of conduct, and traffic 

management plan. The Project previously undertook a Security Risk 

Assessment and will be required to develop and implement a Security 

Management Plan, in alignment with IFC Performance Standard 4.

The Project is expected to include the development of associated 

facilities, namely a 10.9 km Overhead Transmission Line built and 

operated by the Egyptian Electricity Transmission Company (EETC) 

that may contribute to cumulative impacts from existing transmission 

lines in the area, especially as they relate to bird collisions and fatalities. 

Additional environmental risks include waste and water management. 

The Project will be required to develop and implement management 

plans to address these issues in line with DFC’s E&S Requirements. 
Annex B – Public Information Summary

Host Country Nigeria

Name of Borrower Indorama Eleme Fertilizer and Chemicals Limited/SPV Line III 

Project Description The development, design, financing, construction, operation and 

maintenance of the Borrower’s third ammonia-urea fertilizer facility in 

Port Harcourt (the “Project”). 

Proposed DFC Loan $250,000,000

All-Source Funding Total $1,250,000,000

Policy Review

Developmental Objectives The Project is expected to have a positive development impact through 

supporting global food security, particularly in developing and 

emerging economies, while also providing economic benefits to 

Nigeria. Fertilizer is a critical commodity for global food security: it is 

estimated that only half of the world’s population could be sustained 

without nitrogen fertilizer. Yet fertilizer supply has been severely 

disrupted in recent years, contributing to surging food prices and 

decreased income for farmers. The Project is expected to result in 1.4 

million metric tons per annum of additional urea fertilizer to be 

exported from Nigeria, largely to destinations in Latin America and 

Africa. The Project is also anticipated to create hundreds of full-time, 

formal operations and maintenance jobs as well as thousands of 

construction jobs in the Niger Delta, to generate local income through 

domestic procurement, and to support Nigeria’s balance of trade 

through hundreds of millions of dollars of additional exports annually. 

Environment and Social 

Assessment

SCREENING: The Project has been screened as Category A because it 

requires an expansion of a large-scale fertilizer manufacturing complex 

and has the potential for accidental releases of hazardous gases 

(methane, hydrogen, and ammonia). In addition, the Project’s 

greenhouse gas (GHG) emissions have been estimated to be 688,100 

tons of carbon dioxide equivalent per year (DFC’s share of GHG 

emissions has been estimated at 130,945 tons of carbon dioxide 

equivalent per year) which exceeds DFC’s threshold of 100,000 tons of 

carbon dioxide per year for Category A projects. 

A jetty will be used to export ammonia and urea produced by the 

Project but is not part of the Project scope for DFC financing. 

Therefore, the jetty is considered an Associated Facility. Based on the 
information received to date the jetty aspect of the project will be able to 

meet applicable guidelines and there will be limited impacts on biodiversity 

and worker and community safety.

APPLICABLE STANDARDS: DFC’s environmental and social due 

diligence indicates that the Project will have impacts that must be 

managed in a manner consistent with the following International 

Finance Corporation’s (IFC) 2012 Performance Standards (PS): 

 

PS 1: Assessment and Management of Environmental and Social Risks 

and Impacts; 

PS 2: Labor and Working Conditions; 

PS 3: Resource Efficiency and Pollution Prevention; and 

PS 4: Community Health, Safety, and Security. 

 

Based on the information currently available, the Project will not 

acquire land as the Sponsor already owns the Project site, which is 

located in an industrial estate. No significant biodiversity resources or 

settlements have been identified at or near the Project site or its 

associated facilities. In addition, there are no indigenous people or 

cultural resources that have been identified at or near the Project site. 

Therefore, PS 5, 6, 7, and 8 are not currently triggered by the Project. 

 

Environmental Guidelines applicable to the Project include: World 

Bank Group’s General Environmental, Health, and Safety (EHS) 

Guidelines (April 2007) and Nitrogenous Fertilizer Production EHS 

Guidelines (2007). 

Workers’ accommodation used during both construction and operations 

will be required to meet the recommendations of the IFC/EBRD 

Guidance Note -Workers’ Accommodation: Process and Standards.). 

In addition to compliance with the applicable environmental, health, and 

safety regulations of Nigeria, the Project will be required to perform a 

Hazard and Operability (HAZOP) study which complies with both the 

requirements of paragraph 18 of IFC’s Guidance Note of Performance 

Standard 3 and is consistent with the applicable requirements of 40 U.S. 

Code of Federal Regulations (CFR) Part 68.

ESIA DISCLOSURE: The ESIA for the Project was disclosed on 

DFC’s website from September 20, 2023 to November 20, 2023. The 

comments received and the DFC response can be found on the DFC 

disclosure page for this Project.

SITE VISIT: The Lenders’ Independent Environmental and Social 

Advisor visited the Indorama Complex in January 2023, and undertook 

a virtual site visit in May 2023 as a part of the environmental and social 
due diligence. DFC visited the site of the existing facility (during DFC’s 

due diligence for an earlier, potential investment to Line 2, which did 

not move forward) in 2018. During DFC’s site visit, meetings were held 

with nearby communities and local and national regulators.

KEY ENVIRONMENTAL AND SOCIAL RISKS AND 

MITIGATION: The major environmental and social risks (E&S) 

associated with the Project include the potential for ammonia, 

particulate matter (including urea), and nitrogen oxides (NOx) releases 

beyond the Project boundary, occupational health and safety (OHS) 

risks associated with the handling of hazardous materials (including 

hydrogen, ammonia, and methane), potential risks to community health, 

safety, and security (including managing project induced influx), and 

labor management, especially contractor management during 

construction.

Environmental and Social Management

As a result of IFC’s prior investment in the existing Lines 1 and 2, 

Indorama has established an environmental and social management 

system (ESMS) that is consistent with the requirements of the IFC’s 

Performance Standards. For the Project, Indorama conducted an ESIA 

for Line 3 development as well as the jetty associated facility. Indorama 

will be required to develop and implement an Environmental and Social 

Management Plan (ESMP) to address the construction related E&S 

issues and occupational and community health and safety risks. Prior to 

the commencement of operations, another ESMP will be required to be 

developed to address E&S issues (including air emissions, noise, 

effluent discharges, and hazardous materials management) related to the 

operations phase. The Project’s air emissions, including nitrogen oxide 

and process emissions, are expected to be controlled to levels that 

comply with the relevant World Bank Group’s EHS Guidelines.

Hazardous Materials Management

Current information indicates that the nearest residences to the Project 

are located outside the safety exclusion zone needed to protect the 

nearby communities from accidental releases of hazardous gases. 

However, further verification is underway via the ongoing Hazard and 

Operability (HAZOP) studies. In the event of a major fire or explosion, 

damage may be expected to other facilities within the Indorama 

complex and the HAZOP that is currently being performed will identify 

opportunities to reduce the potential for accidental release of hazardous 

gases, fire, and explosion. The Project will adopt detailed procedures 

relating to the safety of facilities’ operations, including any 

recommendations made in the HAZOP analysis. The Project will also 

be required to develop and implement Fire Prevention and Control Plan 

which will be designed to ensure fire safety. The Project will be 
required to develop and implement an Emergency Preparedness and 

Response Plan (EPRP) to ensure that appropriate emergency response 

measures are in place.

Occupational Health and Safety

Occupational health and safety risks unique to this Project include those 

associated with construction activities and the operations phase 

(including the handling of ammonia and flammable and explosive 

hydrogen and methane). These risks are expected to be adequately 

managed through the implementation of the Project’s ESMPs and 

Occupational Health and Safety Plans (OHSP; both for construction and 

operations). Employees will be trained on OHS and environmental and 

social impacts management. 

Community Health and Safety

The Project has received the required approval from the Federal 

Ministry of the Environment, which requires that the Project maintain 

community safety. Indorama will develop and implement a community 

health and safety plan to ensure compliance with IFC’s Performance 

Standard 4 and the local regulations. The community health and safety 

plan is expected to address environmental releases (including dust, 

noise, and effluent discharges), transport management, and other 

construction and operations-related community health and safety issues. 

In addition to existing businesses operating in the immediate vicinity of 

the Project area, primarily food industries, there is the possibility of 

other industrial establishments being constructed in the foreseeable 

future. Cumulative impacts associated with the Project have been 

identified in the ESIA and are manageable as only food industries are 

currently planned in the industrial estate. However, there exists a 

possibility of a few light industrial establishments to be constructed in 

the foreseeable future. All of these could contribute to air emissions, 

noise, and effluent discharges in the immediate area of the Project. 

These impacts are planned to be mitigated through the implementation 

of the Project’s Environmental and Social Management Plans (ESMP).

Labor Management

The Project anticipates that construction will require approximately 

5,000 workers of whom 90% are expected to be Nigerian. The EPC 

contractor and its subcontractors will be required to align its labor and 

working conditions to the Project’s labor policies and IFC Performance 

Standard 2. A local hiring plan has been developed to guide the EPC 

contractor and its subcontractors. In order to address the potential for 

additional in-migration, the Project will communicate labor needs and 

required skills to local stakeholders, update local supplier database, 

implement a local content and recruitment plan, implement policies to 

address code of conduct and gender-based violence risks, and partner 
Annex A-1: Comments Received during the ESIA Public Posting and DFC Responses

DFC received comments on the Indorama Eleme Fertilizer Manufacturing Project from Bank Information 

Center (BIC) and signed by approximately 30 local, regional and international civil society organizations.

Number Comment Response

1. Our concerns reflect both 

local and global impacts. 

Effluent discharges (and their impact on river water quality) and 

air emissions (and their impact on ambient air quality) will 

comply with both the local regulatory and IFC requirements. 

with government and other industries in the area to undertake 

interventions to alleviate the impact of Project induced in-migration. For 

operations, the Project will require a staff of 150.

Two unions are active to represent workers for current operations. 

These contracts expire in 2023 and it is anticipated that employees for 

the expansion will be included in the negotiations for renewal. The 

Project is currently addressing gaps identified as a result of a CAO 

complaint filed in April 2018. These include improvements to its 

internal grievance mechanism, including ensuring that grievance 

management is free from retaliation. This CAO process remains open as 

the Sponsor continues to address the identified gaps. 

Stakeholder Engagement

The Sponsor has developed and continues to implement a Stakeholder 

Engagement Plan (SEP) for the Project that builds upon the Sponsor’s 

existing policies. The SEP maps stakeholders, highlights previous 

engagement, analyzes organization capacity, identifies needed 

engagement throughout the Project life, and outlines monitoring and 

reporting. The Project undertook external consultation as part of its 

ESIA process, which was confirmed by the Federal Ministry of 

Environment to have met all national requirements for public 

consultation and disclosure. The Project has in place and continues to 

utilize its current external grievance mechanism for the expansion. The 

Project will be required to conduct training to ensure the process is 

accessible to all parties impacted by the Project, including vulnerable 

populations. The Project has committed to quarterly reporting on Project 

status to concerned citizens and community groups. 

Security Management

The Project will utilize the Sponsor’s current security management plan, 

which will be required to align with the Voluntary Principles on 

Security and Human Rights. The Sponsor currently utilizes armed 

private security personnel and public security officers when necessary 

to protect Project assets and escort visitors. The Project conducts human 

rights training for its own security personnel, as well as public security 

personnel engaged by the Project.
At the local level, we 

expect 

the expansion of 

Indorama at Eleme in 

Rivers State to contribute 

to effluent discharge, 

especially at Okulu River 

in Aleto, Eleme, and 

possible air pollution, 

which would impact both 

local terrestrial and 

marine biodiversity and, 

critically, the health of 

people living in the 

project’s vicinity given 

increased ammonia 

emissions. How will 

these impacts be 

addressed?

IEFCL is required to expand, upgrade, and enhance its ESMS to 

manage and mitigate incremental and cumulative impacts 

resulting from the planned expansion. The expansion project is 

located within the existing site boundary, so land and 

biodiversity-linked impacts are not expected. Biodiversity 

impacts (both terrestrial and marine) are also planned to be 

mitigated to levels that would comply with both the local 

regulations and IFC requirements as indicated in Chapter 8.3 of 

the ESIA and Chapters 8, 9, and 10 of the Jetty. These sections 

of the ESIA package demonstrate that the Project will not have 

adverse health impacts on the people living in the project’s 

vicinity. Appendix C of the ESIA package presents the 

Environmental and Social Management and Monitoring Plan 

which illustrates how the Project will manage and monitor E&S 

impacts to ensure compliance with both the local regulations 

and IFC Performance Standards and EHS Guidelines.

2. We note that no new 

stakeholders have been 

identified during the 

stakeholder engagement 

for Train 3. Given that 

this will expand 

Indorama’s operations 

there by 50%, this is 

surprising. Will 

additional people, 

including employees and 

their families, not be 

impacted?

The Train 3 Project site is adjacent to Indorama Eleme 

Fertilizer & Chemicals Limited’s (“IEFCL”) existing Train 1 

and 2 operations and all three trains are located within a larger, 

fenced industrial complex. The land for the industrial complex 

was acquired by the national petroleum company from the 

local government in 1985. As such, the affected stakeholders 

identified for Train 3 are expected to be similar to those from 

IEFCL’s current operations. 

The Stakeholder Engagement Plan (SEP) for Train 3, which 

builds upon stakeholder engagement from the first two trains, 

extends for the life of the project and includes a process for 

regular stakeholder identification and mapping. Identified 

stakeholders include local committee advisory committees, 

women leaders, youth councils, worker unions, local leaders, 

and business associations. 

3. IFC also does not 

anticipate any project 

impacts that require 

management under PS 6, 

Biodiversity 

Conservation and 

Sustainable Management 

of Living Natural 

Resources. Given the 

With respect to CSO’s concerns around increased quantities of 

discharged ammonia and urea, DFC would like to clarify that 

the operations will produce ammonia and urea as core saleable 

products, and therefore, as in the current lines, there are not 

expected to be any ongoing emissions of ammonia or urea. The 

Indorama Train 3 Project will comply with PS 6 requirements 

as explained in Section 9.2.7 of the ESIA and Jetty Chapters 8, 

9, and 10. These sections of the ESIA package demonstrate 

that biodiversity impacts in the project’s vicinity will be at 
scale of the investment, 

projected increases in 

production, and related 

increases of discharged 

ammonia and urea, we 

are concerned this 

assessment is inaccurate. 

How has IFC (or 

Indorama) assessed these 

impacts and related 

mitigation needs?

acceptable levels. Appendix C of the ESIA package presents 

the Environmental and Social Management and Monitoring 

Plan which illustrates how the biodiversity impacts will be 

managed and monitored to ensure compliance with both the 

local regulations and IFC Performance Standard 6. The Project 

will use Good Industry Practices during dredging to minimize 

biodiversity impacts which will ensure compliance with both 

the local regulations and IFC Performance Standards. 

4. At the global level, the 

regular use of chemical 

fertilizers is not an 

appropriate way to boost 

agricultural productivity 

in the Global South or 

anywhere else. While 

nitrogen fertilizers can 

boost productivity in the 

short term, they are 

damaging to the 

environment and human 

health and risk 

undermining soil fertility 

and quality. Indeed, the 

World Bank’s recent 

report Detox 

Development highlights 

that inefficient use of 

nitrogen fertilizers leads 

to “diminishing crop 

productivity.” The use of 

chemical fertilizers is 

also a key factor in 

nitrogen and phosphorus 

pollution, the planetary 

boundaries of which 

have already been 

transgressed. How does 

IFC plan to mitigate 

these and other 

downstream impacts of 

the use of Indorama’s 

products?

DFC takes comfort in IEFCL’s efforts to improve the 

efficiency of downstream fertilizer application. IEFCL 

provides smallholder farmers in Nigeria with training to 

improve crop productivity and yields. As part of these efforts, 

agronomists across the country train farmers on the appropriate 

use of fertilizer and provide assistance on soil testing. This 

program has been replicated in Senegal and Mali, and 

Indorama has plans to further expand this approach in Burkina 

Faso and Niger. 

IEFCL is also focused on product innovation, and in 2022, the 

company has developed a neem-coated urea product that 

ensures a slower release of nitrogen. In addition, Indorama has 

plans to collaborate with the International Institute of Tropical 

Agriculture on further product innovation.
5. Many of these fertilizers 

are used to produce feed 

crops for factory farmed 

animals. On a global 

basis, increased 

industrial livestock 

production is a key 

driver of climate change, 

deforestation, 

biodiversity loss, and the 

pollution of the planet’s 

air, land, and water, and 

overconsumption of 

water resources. As the 

IPCC has pointed out, 

these impacts are already 

negatively impacting 

agricultural production 

and food security in 

Africa, particularly 

among smallholders and 

rural populations who 

are already struggling 

with rising temperatures 

and water shortages. To 

the extent IFC’s 

investment in Indorama 

will support the 

expansion of industrial 

livestock production and 

the diversion of finite 

resources toward feeding 

factory-farmed animals 

in Africa and elsewhere, 

the Bank should account 

for and seek to mitigate 

relevant negative impacts 

on food security, human 

health, and economic 

stability in the region, 

especially given that 

acute food insecurity 

recently reached a 10-

year high in West and 

Central Africa.

DFC understands the environmental and climate concerns 

associated with fertilizers and the agriculture sector that 

fertilizers support. DFC also agrees with the concerns raised 

around food security in Africa. It is for this reason that DFC is 

seeking to finance this agriculture related investment that will 

expand urea production, while following high environmental 

standards. IEFCL uses best-in-class technology, is among the 

least carbon intensive urea producers globally (on a CO2 per 

ton of urea produced basis), and continues to invest in 

decarbonizing its production process. As noted previously, 

IEFCL will be required to follow IFC Performance Standards 

as it relates to environmental protections. 

The Project will also contribute the economic stability of 

Nigeria by improving the country’s net trade balance, creating 

Nigerian jobs, and boosting local income. 
6. Whatever the end-use of 

Indorama’s products, 

IFC’s proposed loan 

offers financing on 

favorable terms for the 

expansion of an 

industrial approach to 

agriculture while the 

World Bank itself has for 

years emphasized the 

need for public support 

for more sustainable 

agroecological and 

regenerative approaches. 

Given evidence that in 

Africa, nature-based 

agriculture such as 

agroecology can boost 

yields and farmer 

livelihoods while 

benefiting the 

environment, shouldn’t 

IFC be focusing its 

limited resources on such 

approaches? 

Please see the 

attachment, Chemical 

Fertilizers' Issues vs. 

Better Options for 

Africa’s Agricultural 

Development, which 

outlines in more detail 

the evidence of how 

chemical fertilizers offer 

minimal benefits at a 

high cost to the 

environment, climate, 

and human health– and 

the better alternatives 

that are available for 

agricultural development 

in Africa. In light of this 

information, how will 

IFC change its Africa 

Agribusiness strategy 

and portfolio?

DFC recognizes the value of organic fertilizers, and it is 

actively seeking to support other organic fertilizer projects. 

Nonetheless, nitrogen fertilizers play a critical role in feeding 

the world: it is estimated that only half of the world’s 

population could be sustained without nitrogen fertilizers, the 

most commonly used fertilizers globally. Hence, DFC is 

looking to support IEFCL to expand the production of urea, 

which will help meet growing global demand and contribute to 

the stabilization of fertilizer prices. 
7. Indorama has a long and 

fraught history of 

violating E&S and labor 

standards, including 

engaging in child and 

forced labor. Indorama 

has been the subject of 

many accountability 

mechanism complaints 

across MDBs, including 

IFC's CAO.

With regards to IEFCL’s existing operations in Nigeria (Train 

1 and 2), which DFC is not involved in, DFC is aware of the 

ongoing CAO case at IFC. We understand through that CAO 

process and subsequent financing a number of gaps have been 

identified and incorporated into an ESAP by IFC and that the 

company has made significant progress in implementation. 

The CAO is still actively monitoring the corrective actions 

regarding the Project’s worker grievance mechanism to ensure 

it fully aligns with IFC Performance Standard 2. DFC 

continues to monitor progress towards resolution of the CAO 

case, as well as engage with IFC and will track the Project’s 

ongoing performance and implementation. 

The CAO complaint regarding Trains 1 and 2, while alleging 

violations of PS2, does not reference issues of any forced or 

child labor. We are aware of a separate accountability case 

related to issues of forced and child labor in the supply chain 

that pertains to a different subsidiary that produces textiles in 

Uzbekistan. DFC is not involved in financing that subsidiary.

The human resources policies, which covers prohibitions of 

child and forced labor and are currently being applied to trains 

1 and 2, will be applied to train 3. Furthermore, the Train 3 

Project will be required to implement an Employment and 

Procurement Management plan that aligns the Project’s 

operations to IFC Performance Standard 2. DFC will monitor 

IEFCL’s compliance with PS 2 and its own HR policies 

throughout project development and operations. 
Annex B – Public Information Summary

1

If a clearance is not complete at the time that a report is circulated to a particular approver or approver group, 

simply state “Clearance is in process.” Please ensure, however, that the section is updated with the ODP language 

prior to posting of the public information summary on DFC’s external website.

Host Country Indonesia

Name of Borrower PT Medco Cahaya Geothermal

Project Description Direct loan to PT Medco Cahaya Geothermal for the development of an 

up to 31.4 MW net geothermal power unit for the first phase of the 

planned 110 MW Blawan Ijen Geothermal Power Plant in East Java.

Proposed DFC Loan $126,000,000

All-Source Funding Total $238,900,000

Policy Review1

Developmental Objectives The Project is expected to have a positive development impact in 

Indonesia by expanding access to renewable energy via the construction 

of a geothermal energy plant. According to the International Energy 

Agency, coal, oil and natural gas combined account for approximately 

80% of Indonesia’s energy supply, whereas geothermal represents less 

than 5%. The Government of Indonesia has estimated that the country’s 

potential geothermal capacity is approximately 24 gigawatts, yet a 

number of factors have inhibited development, including high-risk 

exploration processes, substantial up-front capital costs, and long 

timelines needed to obtain investment returns. Further, Indonesia’s 

greenhouse gas emissions have increased and are projected to rise along 

with energy demand. The DFC-supported Project is expected to add 

geothermal energy to the East-Java-Bali region and support climate 

objectives through the avoidance of CO2 emissions. U.S.-based and 

New York Stock Exchange listed Ormat Technologies Inc is a part 

owner and developer of the Project. 

Environment and Social 

Assessment

SCREENING: The Project has been reviewed against DFC’s 

categorical prohibitions and determined to be categorically eligible. The 

Project is screened as Category A because it involves greenfield 

development of a geothermal power generation project. The Project is 

located near a protected area and may result in economic displacement 

and impacts to Indigenous Peoples and critical habitat. 
APPLICABLE STANDARDS: The Project is subject to DFC’s 2020 

Environmental and Social Policy and Procedures (“ESPP”). Under 

DFC’s ESPP, the Project Sponsor is required to comply with applicable 

national laws and regulations related to environmental and social 

performance. In addition, DFC’s preliminary environmental and social 

due diligence indicates that the Project will have impacts that must be 

managed in a manner consistent with the following of the International 

Finance Corporation’s (IFC) 2012 Performance Standards: 

• PS 1: Assessment and Management of Environmental and Social 

Risks and Impacts; 

• PS 2: Labor and Working Conditions; 

• PS 3: Resource Efficiency and Pollution Prevention; 

• PS 4: Community Health, Safety, and Security; 

• PS 5: Land Acquisition and Involuntary Resettlement; 

• PS 6: Biodiversity Conservation and Sustainable Management of 

Living Resources; and

• PS 7: Indigenous Peoples 

• PS 8: Cultural Heritage 

The ESIA identified no cultural heritage within the Project footprint, but 

some areas of cultural heritage importance are located within 1km of 

Project works. The potential for impacts to these sites will be further 

evaluated during due diligence. Therefore, PS 8 is triggered at this time 

but subject to further confirmation. In addition to the Performance 

Standards listed above, the World Bank Group’s Environmental, Health, 

and Safety (EHS) General Guidelines (April 30, 2007), EHS Guidelines 

for Geothermal Power Generation (2007); and EHS Guidelines for 

Electrical Power Transmission and Distribution (2007) are applicable to 

the Project. 

ESIA Disclosure: The ESIA package was posted on DFC’s website for 

public disclosure on September 22, 2023 and is available for public 

comment until November 21, 2023. No comments had been received at 

the time this summary was drafted. If any comments are received, they 

will be shared with the Board along with DFC’s responses at least seven 

days prior to the Board meeting. 

Environmental and Social Risks and Mitigation Measures: The key 

environmental and social risks of the Project are those related to 

economic displacement and potential impacts to Indigenous Peoples, 

critical habitat, tourist sites, and community health and safety. 

The Project is located within the Kawah Warang (Wurung) Park which 

is a tourism hiking area known for scenic views and a number of crater 

features such as Kawah Wurung and Kawah Ilalang, which are adjacent 

to the Project’s access road and transmission line. The Project is also 
located near Kawah Ijen Crater Park, which is located within the Kawah 

Ijen Nature Reserve, an IUCN Category III legally protected area. The 

Kawah Ijen Carter Park is another popular tourism site, which hosts the 

Kawah Ijen crater and the largest natural acidic lake in the world. At its 

closest point, the park is located 300 m from the transmission line route 

and around 2.5 km from the main construction area. The Project may 

result in potential visual and nuisance impacts to the tourism area and 

landscape that are used for panoramic views. The Project will be 

required to implement mitigation measures to reduce these impacts. 

The critical habitat screening for the Project determined that the 

Project’s ecologically appropriate area of analysis (EAAA) potentially 

qualifies as critical habitat under IFC PS 6 criteria 1, 2 and 4. A total of 

seven species (one insect species, one mammal species, and five bird 

species) have been identified as potentially critical habitat-qualifying 

biodiversity features. In addition, the forest ecosystem present in the 

EAAA is recognised as a high priority for conservation at the national 

level and is also likely to qualify the area as critical habitat. The Project 

will be required to develop a Biodiversity Action Plan that demonstrates 

no net loss of natural habitat and net gain in biodiversity for critical 

habitat.

Impacts to community health and safety resulting from worker influx 

and increase in traffic due to Project vehicles will be mitigated through 

implementation of a traffic management plan, Workforce Code of 

Conduct, and robust stakeholder engagement and community grievance 

mechanism. 

Land for Project is in the process of being acquired from parcels 

associated with 250 households, resulting in economic displacement. 

There is no physical displacement anticipated. The Project is in the 

process of determining potential livelihood impacts associated with the 

establishment of the transmission line. The Project has provided a draft 

land acquisition and livelihood restoration plan which is still being 

reviewed by DFC and its Independent Environmental and Social 

Consultant. 

Of the 250 households affected by economic displacement, 18 

households identify as Osing, a recognized Indigenous group in 

Indonesia. While ongoing stakeholder engagement has been 

implemented by the Project in the area in general, specific engagement 

with the Osing has not adequately addressed potential language and 

literacy limitations or governance processes that would comply with 

IFC PS 7. The Project is expected to undertake further Osing-specific 

consultations, disclosures and socialization to appropriately identify 

impacts specific or particular to the Osing people and to develop any 
differentiated mitigation plans that are identified through this process. 

This will be further assessed in ongoing due diligence. 
Public Information Summary

Host Country Bulgaria

Name of Borrower and 

Guaranteed Party

Borrower: Bulgartransgaz EAD (Bulgaria)

Guaranteed Party: Citibank N.A. (United States)

Project Description The Project is the expansion of the Borrower’s Chiren underground gas 

storage facility (“UGS”) in Bulgaria from a current active gas volume of 

550 million cubic meters (“mcm”) to 1 billion cubic meters (“bcm”) 

(the “Project”). The Project will support energy security by providing 

Bulgaria and other European countries with additional storage capacity 

and greater flexibility as to when and from where to source gas as the 

region seeks to diversify its gas supply away from Russia.

Proposed DFC 

Loan/Guarantee

Up to USD 364,678,800; 9-year door-to-door tenor 

All-Source Funding Total EUR 330,323,131

Policy Review

Developmental Objectives The Project is expected to have a positive impact in Bulgaria and its 

neighboring countries by providing these countries with greater 

flexibility to diversify gas supply away from Russia by facilitating 

improved gas supply management. This will help to address disruptions 

in the gas supply chain caused by Russia halting gas exports to Bulgaria 

and surrounding economies and help to ensure a stable supply of this 

critical input to support the region’s economic growth and energy 

security. More specifically, the Project will nearly double the gas 

storage capacity of the existing UGS in Bulgaria, which will be used as 

hub for both gas imports for domestic consumption as well as gas 

exports throughout the region via interconnection with Romania, Serbia, 

North Macedonia, Greece, and Turkey. As a result of increasing 

Bulgaria’s gas storage capacity, the Project will positively impact 

industrial, commercial, and residential gas end-customers in Bulgaria 

and throughout the region.

Environment and Social 

Assessment

SCREENING: The Project has been screened as Category A because 

it involves the expansion and operation of a major gas storage, 

processing, and transportation system that has potential significant 

adverse environmental and social risks and/or impacts that are diverse, 

irreversible, or unprecedented, in particular, due to potential impacts to 

local infrastructure and the potential for accidental releases of methane. 

APPLICABLE STANDARDS: The Project is subject to DFC’s 2020 

Environmental and Social Policy and Procedures (“ESPP”). Under 

DFC’s ESPP, the Borrower is required to comply with applicable 
national laws and regulations related to environmental and social 

performance. In addition, DFC’s preliminary environmental and social 

due diligence indicates that the Project will have impacts that must be 

managed in a manner consistent with the following of the International 

Finance Corporation’s (“IFC”) 2012 Performance Standards (“PS”): 

PS 1 Assessment and Management of Environmental and Social Risks 

and Impacts; 

PS 2 Labor and Working Conditions; 

PS 3 Resource Efficiency and Pollution Prevention; 

PS 4 Community Health, Safety, and Security; 

PS 5 Land Acquisition and Involuntary Resettlement; and 

PS 6 Biodiversity Conservation and Sustainable Management of Living 

Natural Resources. 

Based on the information currently available, no indigenous peoples and 

cultural heritage sites have been identified at or near the Project 

sites. Therefore, PS 7 (Indigenous Peoples), and 8 (Cultural Heritage) 

are not triggered at this time. 

IFC’s Environmental Health and Safety (EHS) Guidelines applicable to 

the Project include: General EHS (2007), Gas Distribution Systems 

(2007), and Crude Oil and Petroleum Product Terminals (2007).

The Project’s greenhouse gas (carbon dioxide equivalent) emissions (for 

both Scope 1 and Scope 2) have been estimated to be less than 90,000 

tons of carbon dioxide equivalent (CO2eq) per year. 

ESIA Disclosure: The Project’s ESIA was disclosed on DFC’s Website 

on August 15, 2023 and the comment period ended on October 14, 

2023. No comment was received during the ESIA disclosure period.

Environmental and Social Risks and Mitigation: The major 

environmental and social risks associated with the Project include: life 

and fire safety; the potential for volatile organic compounds (“VOCs”) 

(including methane) releases beyond the Project fence-line (including 

pipeline right-of-way) limits; small quantities of effluent discharges and 

hazardous and solid wastes disposal; occupational health and safety 

risks associated with the handling of hazardous materials (including 

methane); labor management and potential risks to community health, 

safety, and security. 

The Project has an environmental and social management system 

(ESMS) which is being augmented to achieve consistency with the 

requirements of PS 1. The Project has put in place procedures to address 

both occupational and community safety risks associated with the 
accidental release of methane and other VOCs, fire, and explosion. The 

gas processing, storage, and transportation infrastructure will be 

developed in compliance with the Bulgarian regulations (that have been 

deemed by the DFC’s independent consultant to be equivalent of the 

European Union’s) which will ensure both worker and community 

safety. The Project has yet to finalize a number of key environmental 

and social plans and will be required to do so as a condition of DFC 

financing.

The Project is anticipated to require 1,100 workers across multiple 

phases and intends to hire locally to the extent possible. BTG has in 

place HR documents in line with Bulgarian labor legislation that is 

harmonized with EU legislation and ILO standards. The Project will be 

required to develop a Contractor Management Plan as part of its overall 

ESMS. 

The Project is expected to follow internationally recognized best 

practices in gas processing safety and properly manage hazardous 

materials including methane. The Project will implement a 

comprehensive ESMP which will address: process safety; accidental gas 

releases, fire and explosion; gas storage management; air emissions; 

wastewater treatment and sewage discharges; solid and hazardous waste 

disposal; emergency management; occupational health and safety; spill 

response; monitoring; and stakeholder engagement.

The nearest residential community is located approximately 1 kilometer 

or greater from the Project gas processing plant and storage facilities. It 

should be noted that there are two sections of the gas transportation 

pipeline where the distance to nearest receptors is less than 1 km and 

therefore, the gas pipeline will be adequately buried along such sections 

to reduce the community safety risks to acceptable levels. Air dispersion 

modeling of a potentially harmful vapor cloud resulting from an 

accidental methane release at gas processing and storage facilities 

indicates that hazardous concentrations of methane will be limited to 

less than a 600 meters radius around the point of release, which is 

expected to be within the Project fence-line. Similarly, all residences 

near the gas pipeline will be outside the Project’s impact zone. 

Therefore, all residences will be outside of the Project’s impact zone for 

all the three components of Project facilities. To further mitigate this 

unique safety risk, an emergency response plan will be in effect which 

includes evacuation of on-site personnel. In the event of a fire or an 

explosion, minor damage may be expected to buildings and facilities 

within the Project fence-line and some injuries may occur to facility 

personnel. A detailed hazard analysis was undertaken by an independent 

expert to identify opportunities to reduce the potential risks associated 

with the accidental release of methane and other VOCs, fire, and 
explosion.

The Project facilities will properly treat small quantities of process 

wastewaters. . Mixed wastewater streams (process, cooling, sanitary, 

and rain) will be discharged into surface water bodies in full compliance 

with the integrated permit conditions.

Process emissions of VOCs will comply with the recommended air 

emission levels in the IFC’s Guidelines. Small quantities of hazardous 

wastes will be sent to the facilities licensed to manage hazardous 

wastes.

Solid wastes will be disposed in a manner which prevents 

environmental releases. The Project will follow acceptable industrial 

safety provisions. Past waste management practices did not result in any 

significant contamination of onsite or off-site soil, water courses, and 

sediments. 

Standard industry practices will be followed to ensure that OHS impacts 

are properly managed in conformance with both the state and EU

regulations and IFC Guidelines. Training will be provided to all workers

on standard operating procedures to ensure their safety. Personal 

protective equipment will also be provided to all workers. BTG’s 

current OHS record is consistent with the industry benchmarks.

Community Health, Safety, and Security Impacts. The Project will 

develop and implement a Community Health, Safety, and Security Plan 

to ensure compliance with PS 4. A buffer zone has been established to 

ensure community safety and security and a perimeter fence has been 

established.

The Project will make use of a private, armed security contractor for 

construction and operation. A Security Management Plan needs to be 

developed to manage any risks posed by security arrangements in 

alignment with IFC PS 4.

Land Acquisition. No physical displacement is envisaged while 911 

different landowners will experience limited economic displacement 

due to the establishment of easement rights along the interconnecting 

pipeline route. The Project has developed a draft Land Acquisition and 

Livelihood Restoration Plan that is under review. 

Biodiversity. Based on informational available to date, the key potential 

risk from a biodiversity perspective is due to the new interconnecting 

gas pipeline passing through agricultural land within the eastern part of 

a 435 km2 Natura 2000 site classified as a Special Protected Area (SPA) 
under the EU Birds Directive. An additional potential risk for aquatic 

ecosystems and/or riverine vegetation might be represented by the 

crossing of the Ogosta river during the interconnecting pipeline 

construction. Detailed design of the pipeline and the river crossing are 

currently under finalization. The screening EIA procedure for the wells 

has been completed and the screening decision confirms that no 

significant impacts on biodiversity are expected. The Borrower will be 

required to develop and submit a Biodiversity Management Plan that 

complies with PS 6.
Annex B – Public Information Summary

Host Country(ies) Bangladesh, Cambodia, India, Indonesia, Malaysia, the Philippines, 

Singapore, Sri Lanka, Thailand, Vietnam

Name(s) of Fund Eversource Climate Investment Partners II L.P. (“Fund II”)

Name of Fund Manager Everstone Capital Asia Pte. Ltd. (the “Fund Manager”).

Project Description Eversource Capital Pte. Ltd., India’s largest and most experienced fund 

manager dedicated to investing in climate investments, is raising its 

second fund, Eversource Climate Investment Partners II (“Fund II”). A

target $900 million fund, Fund II will replicate the strategy of the Fund 

Manager’s first fund, the Green Growth Equity Fund (“Fund I”), by 

investing in operating companies solving critical climate change 

adaptation and mitigation challenges (“climate investments”), including 

renewable energy, energy transition (grid efficiency and storage), electric 

mobility, circular economy, water management, and sustainable food and 

agriculture. Fund II’s primary geographic remit is India, with a secondary 

focus on South and Southeast Asia.

Proposed DFC Equity 

Investment

up to $50 million, ten-year commitment

Target Fund Size $900 million

Policy Review

Developmental Objectives Fund II seeks to have a positive development impact in India and 

Southeast Asia by providing capital, management, strategy, and expertise 

to innovative companies using new and existing capabilities to address 

climate change. 

Environment and Social 

Assessment

SCREENING: The capitalization of this fund is screened as a Category 

FI-A activity for the purposes of environmental and social assessment. 

Based on DFC’s due diligence, some of Fund II’s downstream 

investments are anticipated to pose high environmental and social risks. 

Downstream investments made by Fund II will be screened for 

categorical prohibitions and will be subject to DFC’s public disclosure 

requirements for projects deemed by DFC to be Category A projects.

APPLICABLE STANDARDS: Fund II has been reviewed against 

DFC's 2020 Environmental and Social Policy and Procedures ("ESPP") 
and has been determined to be categorically eligible. DFC direct 

investments into investment funds that will subsequently support mid-tolarge sized companies classified as a Financial Intermediary - A (“FI-A”) 

activity for the purposes of environmental and social assessment. Based 

on DFC’s due diligence, Fund II’s downstream investments are 

anticipated to pose environmental and social risks that are site specific 

and can be readily mitigated through the application of sound 

environmental and social management practices. 

Under the ESPP, Fund II will be required to comply with applicable local 

and national laws and regulations related to environmental and social 

performance and applicable provisions of the 2012 International Finance 

Corporation’s Performance Standards (“PS”) 1 and 2. A virtual due 

diligence assessment indicates that because Fund II involves an 

investment in a financial intermediary that will focus on infrastructure 

sectors including logistics, transportation, and utility-scale electricity 

generation projects in India and Southeast Asia, significant adverse 

impacts with respect to community health and safety, biodiversity, land 

acquisition and resettlement, indigenous peoples and cultural heritage are 

not anticipated. Therefore, PS 3, 4, 5, 6, 7, and 8 are not triggered at this 

time. Because Fund II will potentially invest in Category A subprojects, 

DFC will require in those cases that the Fund Manager submit and 

Environmental and Social Impact Assessment that will be disclosed by 

DFC for public comment. 

Environmental and Social Risks and Mitigation:

The key mitigation for environmental risks and impacts is anticipated to 

come from Fund II’s ability to identify and manage environmental and 

social risks and impacts in portfolio companies, and to adequately 

identify, require and monitor the implementation of the respective 

management plans. Fund II will replicate the investment strategy of Fund 

I and based on that experience, DFC expects that some of Fund II’s 

potential downstream investments may pose high environmental and 

social risks to be managed.

The Fund Manager has an Environmental Social and Governance 

Management System (“ESGMS”) for Fund I that contains an 

environmental and social policy, organizational structures,

environmental and social monitoring system at fund and portfolio level, 

reporting and disclosure requirements, grievance mechanisms, a 

stakeholder engagement plan, gender action plan, and health and safety 

plans generally commensurate with its investment strategy and applicable 

IFC Performance Standards. It has an established procedure for risk 

categorization, screening, due diligence, and monitoring of 

environmental, social, health and safety risks for its projects. It has also 
identified some of the infrastructure-specific risks and assessments for its 

potential investments.

However, Fund II will be required to provide a fund-specific ESGMS 

modeled on the Fund I ESGMS with limited updates and revisions, 

including changes to the stakeholder management plan, due diligence 

processes and checklists, grievance mechanisms, supply chain 

management, and a human capital management plan to meet the 

requirements of the IFC Performance Standards and DFC’s ESPP. To 

further strengthen its ESGMS, Fund II will be required to incorporate 

explicit consideration of gender-based violence and harassment at the 

portfolio company level.

Fund II will be required to develop and provide a detailed organizational 

structure explaining the ESG roles and responsibilities at the Fund 

Manager level. The structure will include a list of all ESG-relevant 

documents, policies and procedures applicable to Fund II, and the level 

within the organizational structure at which these documents reside and 

are managed. The Fund Manager’s human resources policy already 

satisfies most applicable requirements, but the Fund Manager will be 

required to align its internal grievance mechanism with PS 2.

Fund II will be required to provide annual monitoring reports on the 

environmental and social performance of the portfolio throughout the 

term of the DFC investment.
Public Information Summary

Host Countries Tanzania, Burundi

Name of Borrower CRDB Bank Plc.

Project Description SME on-lending facility in Tanzania and Burundi with a carve out 

for women-owned/-led SME loans. 

Proposed DFC Loan $300,000,000

All-Source Funding Total $375,000,000

Policy Review

Developmental 

Objectives 

An up to $300 million loan to support CRDB Bank Plc’s lending to 

SMEs in Tanzania and Burundi. Up to $350 million is expected to serve 

SMEs in Tanzania, and the remaining $25 million will serve SMEs in 

Burundi. Within the $350 million allocated to Tanzania, DFC expects to 

allocate up to $60 million to women-owned and -led enterprises. 

Environment and Social 

Assessment

The Project has been reviewed against the DFC’s 2020 Environmental 

and Social Policies and Procedures manual (“ESPP”) and has been 

determined to be categorically eligible. DFC direct investments to banks 

for the expansion of lending to small, and medium enterprises (“SME”) 

are screened as a Category C for environmental and social assessment. 

These downstream investments are expected to result in minimal adverse 

environmental and social impacts. Therefore, all those downstream 

investments have been pre-screened as Category C and further review 

and consent is not required for these investments.

To ensure that the Bank’s investments are consistent with the DFC’s 

statutory and policy requirements, the DFC loan will be subject to 

conditions regarding the use of proceeds. The primary environmental and 

social issues identified in this transaction relate to the need for an 

Environmental and Social Policy (“ESP”) that meets the 2012 IFC 

Performance Standards.

Under the DFC’s ESPP, the Bank is required to comply with applicable 

local and national laws and regulations related to environmental and 

social performance and applicable provisions of the 2012 International 

Finance Corporation’s Performance Standard (“PS”) 1 and 2. A deskreview based due diligence assessment indicates that because the Project 

will use DFC support for the expansion of its on-lending to SMEs in 

Tanzania, significant adverse impacts concerning community health and 

safety, biodiversity, land acquisition and resettlement, indigenous people, 

and cultural heritage are not anticipated; therefore, PS 3, 5, 6, 7, and 8 are 

not triggered at this time. The Bank does utilize private security and 
therefore, relevant aspects of PS4, Community Health, Safety, and 

Security are triggered.
Public Information Summary

Host Countries DFC eligible countries

Name of Borrower Prodigy Finance Ltd (“Prodigy”)

Project Description A securitization of graduate school student loans to international 

students from DFC-eligible countries.

Proposed DFC 

Loan/Guaranty

$250,000,000

All-Source Funding Total $294,000,000

Policy Review

Developmental 

Objectives 

The Project is expected to have a positive development impact globally 

by facilitating access to graduate studies for students from developing 

and emerging economies. Many students in developing and emerging 

markets face significant financial barriers to accessing high-quality 

tertiary education abroad, with underdeveloped student loan markets 

resulting in punitively high interest rates or the need for cosigners or 

significant collateral. Prodigy Finance uses a proprietary algorithm based 

on expected future earnings to lend in developing and emerging countries 

at affordable interest rates without cosigners or collateral. This will allow 

the Project to result in loans to over 8,000 students, the majority of whom 

will come from lower or lower-middle income countries but will be able 

to access high-quality graduate education abroad. Over 86% of Prodigy’s 

borrowers as of 2022 come from developing and emerging economies 

report that their graduate degrees resulted in at least a doubling of their 

salaries, and 90% reported that they had no alternative options for 

financing their graduate education.

Environment and Social 

Assessment The Project has been reviewed against the DFC’s 2020 Environmental 

and Social Policies and Procedures manual (“ESPP”) and has been 

determined to be categorically eligible. DFC direct loans to financial 

intermediaries for the expansion of student loans are screened as a 

Financial Intermediary C (FI-C) for environmental and social assessment. 

These downstream investments are expected to result in minimal adverse 

environmental and social impacts. Therefore, all those downstream 

investments have been pre-screened as low risk and further review and 

consent is not required for these investments.

To ensure that the Borrower’s investments are consistent with the DFC’s 

statutory and policy requirements, the DFC loan will be subject to 

conditions regarding the use of proceeds. The primary environmental and 

social issues identified in this transaction relate to the need for an 

Environmental and Social Policy (“ESP”) that meets the 2012 IFC 

Performance Standards.
Under the DFC’s ESPP, the Borrower is required to comply with 

applicable local and national laws and regulations related to 

environmental and social performance and applicable provisions of the 

2012 International Finance Corporation’s Performance Standard (“PS”) 1 

and 2. A desk-review based due diligence assessment indicates that 

because the Project will use DFC support for the expansion of 

educational loans worldwide, significant adverse impacts concerning 

community health and safety, biodiversity, land acquisition and 

resettlement, indigenous people, and cultural heritage are not anticipated; 

therefore, PS 3, 5, 6, 7, and 8 are not triggered at this time. The 

Guaranteed Party does utilize armed private security and therefore, 

relevant aspects to IFC PS 4, Community Health, Safety, and Security are 

triggered.

The Borrower has a Sustainability Policy, grievance mechanisms, and 

human resources policies generally commensurate with its investment 

strategy but will require updating and strengthening to meet the 

expectations listed in the DFC’s 2020 Environmental Policy and 

Procedures and IFC PS 1.