The ENSURE project team based in the UK and Nigeria have recently provided specialist support and reports on Health, Safety, Environment, Social & Security (HSESS/ESG/CSR) issues against the IFC Performance Criteria and other EHS standards (WBG EHS guidelines, SDG’s, BAT, GIIP) for a client seeking direct IFC Investment in the acquisition of OML’s in Nigeria.
The program of works included:
· A comprehensive baseline assessment of existing in-country management systems and issues on the ground;
· The review of the Client and Joint Venture Partners existing HSESS Management systems and upgrading them to meet IFC Performance Standards;
· Identification of existing and legacy Environmental, Social and Governance issues including an evaluation of potential Remediation costs to address legacy spills;
· Identification of key opportunities for ESG improvements, including flare reduction, gas capture and energy supply to communities;
· Development of new Operational Management Systems (OMS) including Stakeholder Engagement Plan (SEP) with comprehensive Grievance Mechanism;
· Development of an in-country communications programme to satisfy the potentially conflicting expectations and requirements of different Stakeholder Groups, including local communities, interest groups and NGO’s;
· Presentations on the systems, issues and recommended solutions to the IFC and other interested Lenders;
In the end, it was concluded that there was no realistic timeframe option to bring a project with so many Legacy issues into ESG Compliance with either Company Policy or IFC Guidelines, so the client walked away from the opportunity.