Namibia Power Corporation (Proprietary) Limited Namibia Transmission Expansion and Energy Storage Project – P177328 Draft ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) January 18, 2024 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Namibia Power Corporation (Proprietary) Limited (the “Borrower�) will implement the Namibia Transmission Expansion and Energy Storage Project (the “Project�), as set out in the Loan Agreement. The International Bank for Reconstruction and Development (the “Bank�) has agreed to provide financing (P177328) for the Project, as set out in the referred agreement. 2. The Borrower shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Bank. The ESCP is a part of the Loan Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreement. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Borrower shall carry out or cause to be carried out, including, as applicable, the timeframes of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, and grievance management. The ESCP also sets out the environmental and social (E&S) instruments that shall be adopted and implemented under the Project, all of which shall be subject to prior consultation and disclosure, consistent with the ESS, and in form and substance, and in a manner acceptable to the Bank. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the Bank. 4. As agreed by the Bank and the Borrower, this ESCP will be revised from time to time if necessary, during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to Project performance. In such circumstances, the Borrower and the Bank agree to update the ESCP to reflect these changes through an exchange of letters signed between the Bank and the Borrower’s Senior Manager Strategic Finance. The Borrower shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Namibia Transmission Expansion and Energy Storage (P177328) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit quarterly reports to the Bank Namibia Power Corporation Prepare and submit to the Bank regular monitoring reports on the environmental, social, throughout Project implementation (Proprietary) Limited health and safety (ESHS) performance of the Project, including but not limited to the commencing after the Effective Date. (NamPower) implementation of the ESCP, status of preparation and implementation of E&S Submit each report to the Bank no later instruments required under the ESCP, stakeholder engagement activities, and than 14 days after the end of each functioning of the grievance mechanism, as well as updates on any ongoing easement reporting period. arrangements along the route of the transmission line financed by the Project and implementation of the Biodiversity Management Plan. B INCIDENTS AND ACCIDENTS Notify the Bank no later than 48 hours NamPower after learning of the incident or Promptly notify the Bank of any incident or accident related to the Project which has, or accident. is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers, including, inter alia, cases of sexual exploitation and Provide subsequent report to the Bank abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or within a timeframe acceptable to the multiple injury. Provide sufficient detail regarding the scope, severity, and possible Bank. causes of the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and/or supervising firm, as appropriate. Subsequently, at the Bank’s request, prepare a report on the incident or accident and propose any measures to address it and prevent its recurrence. C CONTRACTORS’ MONTHLY REPORTS Submit the monthly reports to the Bank NamPower Require contractors and supervising firms to provide monthly monitoring reports on upon request by the Bank as annexes to ESHS performance in accordance with the metrics specified in the respective bidding the reports to be submitted under documents and contracts, and submit such reports to the Bank. action A above. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Maintain a PIU as set out in the Loan NamPower Agreement. Maintain a Project Implementation Unit (PIU) with qualified staff and resources to support management of ESHS risks and impacts of the Project including one (1) health and safety specialist, one (1) environmental specialist and a social specialist. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Namibia Transmission Expansion and Energy Storage (P177328) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS 1.Update and disclose a draft Environmental and Social Impact Assessment (ESIA) 1. The Draft ESIA and ESMP for the NamPower inclusive of a critical habitat assessment and corresponding draft Environmental and 400kV transmission line was disclosed Social Management Plan (ESMP) for the 400kV transmission line of the Project, on December 7, 2023. consistent with the agreed ToR and relevant ESSs. 2. Adopt and implement the ESIA, and corresponding ESMP, under action 1.2(1) for the 400kV Transmission line of the Project, consistent with the relevant ESSs. 2. Adopt and re-disclose the ESIA and ESMP prior to launching of bids for construction, and thereafter implement the ESIA and ESMP throughout Project implementation. 3. Adopt and implement the ESIA, and corresponding ESMP for the Battery Energy Storage System (BESS) for the Project, consistent with the relevant ESSs. 3.Adopt and disclose an ESIA and ESMP for BESS prior to launching of bids and thereafter implement the ESIA and ESMP throughout Project implementation. 4.Cause the contractor to adopt and implement the management plans as stipulated in the ESMPs under action 1.2(1) and 1.2(3) to the satisfaction of the PIU and Bank. 4. Submit at least 30 days prior to the commencement of construction activities for PIU and Bank review and approval and thereafter implement for the duration of the construction phase. 1.3 MANAGEMENT OF CONTRACTORS As part of the preparation of NamPower Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S procurement documents and respective instruments, the Labor Management Procedures, and code of conduct, into the ESHS contracts. Supervise contractors specifications of the procurement documents and contracts with contractors and throughout Project implementation. supervising firms. Thereafter ensure that the contractors and supervising firms comply and cause subcontractors to comply with the ESHS specifications of their respective contracts. 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. NamPower Ensure that any consultancies, studies (including feasibility studies, if applicable), capacity building, training, and any other technical assistance activities under the Project including are carried out in accordance with terms of reference acceptable to the Bank, that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Namibia Transmission Expansion and Energy Storage (P177328) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Adopt and re-disclose LMP (as part of NamPower Adopt and implement the Labor Management Procedures (LMP) for the Project (as part ESIA) prior to launching of bids for of ESIA), including, inter alia, provisions on working conditions, management of workers construction, and thereafter implement relationships, occupational health and safety (including personal protective equipment, the ESIA and ESMP throughout Project and emergency preparedness and response), code of conduct (including relating to SEA implementation. and SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish grievance mechanism prior NamPower Establish and operate a grievance mechanism for Project workers, as described in the engaging Project workers and LMP and consistent with ESS2. thereafter maintain and operate it throughout Project implementation. 2.3 OCCUPATIONAL HEALTH AND SAFETY Submit at least 30 days prior to the NamPower Require the contractor to prepare an Occupational Health and Safety Management Plan commencement of construction as stipulated in the ESMPs under actions 1.2(1) and 1.2(3) consistent with ESS2 and to the activities for PIU and Bank review and satisfaction of the Bank. approval and thereafter implement for the duration of the construction phase. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN 1. Adopt the WMP prior to commencing NamPower 1. Cause the contractor to prepare, adopt and implement a Waste Management Plan with construction, and thereafter (WMP), to manage hazardous and non-hazardous wastes for the Project, as stipulated in implement the WMP throughout the ESMPs under action 1.2(1) and 1.2(3) and consistent with ESS3. Project implementation. 2. Investigate and adopt best cost effective and environmentally responsible measures 2. Adopt end-of-life disposal measures for disposal of end-of-life batteries in line with GIIP as part of the operational procedures for batteries prior to commencing with to be prepared by NamPower for the BESS part of the Project. operations of the BESS. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Same timeframe as for the adoption NamPower Incorporate resource efficiency and pollution prevention and management measures in and implementation of the ESMPs. the ESMPs to be prepared under actions 1.2.(1) and 1.2(3) above. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY Same timeframe as for the adoption NamPower 1. Incorporate measures to manage traffic and road safety risks as required as part of and implementation of the ESMPs. the ESMPs to be prepared under action 1.2(1) and 1.2(3) above. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Namibia Transmission Expansion and Energy Storage (P177328) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 2. Cause the contractor to incorporate measures to manage traffic and road safety risks as required as part of the contractors Occupational Health and Safety Plan to be prepared as per the ESMP under action 1.2(1) and 1.2(3) above. 4.2 COMMUNITY HEALTH AND SAFETY Same timeframe as for the adoption Assess and manage specific risks and impacts to the community arising from Project and implementation of the ESMPs. NamPower activities, including, inter alia, behavior of Project workers, risks of labor influx, response to emergency situations, and include mitigation measures as stipulated in the ESMPs under action 1.2(1) and 1.2(3) above. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 EASEMENT IMPACTS 1. Ensure that before commencement NamPower 1. Implement section of ESIA on Land Risks and Impacts under component financing of any civil works, full compensation has transmission line, in line with principles of ESS5. been provided and necessary easement 2. Provide updates to ESIA as easement processes make progress during Project processes finalized in line with implementation. Borrower’s applicable laws and ESS5 principle of replacement cost value. 2. Throughout Project implementation. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES BIODIVERSITY RISKS AND IMPACTS Prepare and submit for review prior to Finalize the avifauna study as set out in the Plan of Study in the biodiversity and critical construction. NamPower habitat assessment report. 6.1 BIODIVERSITY RISKS AND IMPACTS Adopt the BMP prior to start of NamPower Prepare, adopt and implement a Biodiversity Management Plan (BMP) in accordance construction activities and thereafter with the guidelines of the Critical habitat assessment prepared as part of action 1.2(1) implement the BMP throughout Project for the Project and with additional inputs from the updated avifauna study in action 6.1 implementation. consistent with ESS6. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 GRIEVANCE MECHANISM The grievance mechanism, as described NamPower in the SEP, has been established, and the Establish, publicize, maintain, and operate an accessible grievance mechanism, to said mechanism shall be maintained and receive and facilitate resolution of concerns and grievances in relation to the Project, shall operate throughout Project promptly and effectively, in a transparent manner that is culturally appropriate and implementation. readily accessible to all Project-affected parties, including any vulnerable and disadvantaged groups/Indigenous Peoples, at no cost and without retribution, including concerns and grievances filed anonymously, in a manner consistent with ESS10. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Namibia Transmission Expansion and Energy Storage (P177328) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS Describe the chance finds procedures in NamPower Describe and implement the chance finds procedures, as part of the ESMPs under action the ESMP. Implement the procedures 1.2(1) and 1.2(3) of the Project. throughout Project implementation. ESS 9: FINANCIAL INTERMEDIARIES This Standard is not considered applicable to the project. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Implement the SEP (disclosed both by NamPower Prepare, adopt, disclose, and implement a Stakeholder Engagement Plan (SEP) for the the Bank and by NamPower on Project, consistent with ESS10, which shall include measures to, inter alia, provide December 18, 2023 and January 17, stakeholders with timely, relevant, understandable and accessible information, and 2024, respectively) throughout Project consult with them in a culturally appropriate manner, which is free of manipulation, implementation. interference, coercion, discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM NamPower Establish, publicize, maintain, and operate an accessible grievance mechanism, to The grievance mechanism, as described receive and facilitate resolution of concerns and grievances in relation to the Project, in the SEP, has been established, and promptly and effectively, in a transparent manner that is culturally appropriate and the said mechanism shall be maintained readily accessible to all Project-affected parties, at no cost and without retribution, and shall operate throughout Project including concerns and grievances filed anonymously, in a manner consistent with implementation ESS10. The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT CS1 Training shall be provided for staff and contractors on : Throughout Project implementation NamPower • Requirements of this Environmental and Social Commitments Plan • stakeholder mapping and engagement • specific aspects of environmental and social assessment including but not limited to biodiversity awareness (identification of protected trees, interaction with wildlife, cultural heritage and chance finds procedure) • emergency preparedness and response • community health and safety. • Code of Conduct 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Namibia Transmission Expansion and Energy Storage (P177328) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY CS2 Cause the contractors to provide training to its employees and sub-contractors on Throughout Project construction phase. NamPower Project/activity related occupational health and safety risks and hazards Biodiversity awareness and conservation requirements (trees and birds among other) Chance finds procedure Specific aspects of the environmental and social assessment Site rules (Code of conduct) Labor management plan 8|Page