Abbreviated Stakeholder Engagement Plan (Sep)

ABBREVIATED STAKEHOLDER ENGAGEMENT PLAN (SEP)

APPLICABLE TO ALL SUBSIDIARIES WITHIN THE SOLARISE AFRICA GROUP

1. INTRODUCTION AND BACKGROUND

Solarise is a pan-African Energy-as-a-Service company. Solarise provides reliable and affordable decentralised energy solutions for C&I businesses in Sub-Saharan Africa. Through close collaboration with Partners, Solarise offers innovative full-service solutions that cover designing, building, financing, and maintaining renewable energy and energy saving installations. Solarise has expertise in leasing, financing, and investing in Africa’s renewable energy sector, and collaborate with only the most experienced and quality-focused solar and other energy solution companies in each country to provide a range of tailor-made solutions. Partners are vetted through a technical and financial due diligence to ensure that clients are provided with a full-service solution. Solarise specialises in captive rooftop and ground mounted solar and solar/battery projects ranging from 50kW to 3MW, and the company is fast expanding. Solarise (hereafter ‘Solarise’) was established with the aim of providing tailor made finance solutions for captive solar installations and other renewable energy and energy savings assets to selected clients in Africa. Solarise will work closely with selected Partners & Agents to offer a one-stop shop to the clients, which will pro-vide a competitive advantage to the Partners & Agents through their ability to provide in-house finance solutions to their own clients. This document is Solarise’s Abbreviated Stakeholder Engagement Plan (SEP), which sets out Solarise’s stake-holder engagement approach. It has been established because Solarise believes that effective public consultation and disclosure is a cornerstone of the approach to planning, preparation and implementation of projects. Consultation planning helps identify organisations and individuals residing near the proposed site or having an interest in the project activities. This document forms part of Solarise’s Environmental and Social Management System (ESMS), as updated and amended from time-to-time. Due to the scale (relatively small, ~1.3MW and 1.8MW), short term construction duration of Solarise’s projects (regularly approximately 3 months months) and the fact that Solarise projects are developed in clients’ existing developed commercial and industrial premises, external stakeholder engagement is primarily managed by Solarise’s clients. This means that:

Solarise’s clients are responsible for engagements with:

Affected, neighbouring, host or interested communities because Solarise is essentially a ‘contractor’, engaged to work on the clients’ premises. Subsequently, Solarise (unless there are exceptional circumstances) does not engage in what may traditionally be recognised as ‘community engagement’ under the IFC Performance Standards; and,
Regulators, as they provide permits/licenses (when required) for clients’ to be able to install small scale solar systems on their premises. In exceptional circumstances, Solarise may support clients’ to obtain regulatory approvals because regulators are known to Solarise.
Solarise does not acquire land, thus cause resettlement impacts (i.e., IFC PS 5 is not triggered); and,
Solarise does not engage with indigenous peoples (i.e., IFC PS 7 is not triggered) given that their clients’ are private/commercial entities, i.e. projects are not implemented on community/public land.

Solarise’s stakeholder engagement responsibilities primarily last until completion of construction, following which Solarise’s responsibilities largely reduce to ensuring that clients’ are satisfied with their installed solar systems. Cognisant of our stakeholder engagement responsibilities (despite the level of engagement being low for the types of projects implemented by Solarise), we have developed this Abbreviated SEP to guide our approach to stakeholder engagement so that the approach is properly managed and corresponds with the projects’ sizes and scopes. This SEP orients information disclosure, consultation, and engagement processes so they can best contribute to the establishment and maintenance of meaningful stakeholder relationships. This SEP proposes how to engage in ways that help protect the interests of local groups and enhances understanding among the Project role players and stakeholders. This SEP aims to ensure adequate and timely information is provided to stakeholders. It is based on ensuring the following consultation commitments:
Stakeholders will be informed why consultation is taking place and how their views will be taken into account;

Consultation activities will be organised in ways that are convenient and accessible for the people, if any, whose views are sought; and,

2. REGULATORY AND OTHER REQUIREMENTS

2.1 Host Nation’s Legislative Framework and Permitting

This document has been developed to be Kenya and South Africa-centric, thus Chapters 2.1.1 and 2.1.2 provide relevant legislative content for these two countries. However, Solarise is also committed to adhere to other host nations’ relevant E&S legislation. Therefore, Solarise’s due diligences of new projects in countries located outside of Kenya and South Africa will also identify relevant E&S legislation and determine its applicability.

2.1.1 Kenya

Chapter Five: Land and Environment of Kenya’s Constitution recognises the right of citizens to participate in governance decisions that directly affect them, including consenting on natural resource issues and development projects. In addition, Article 10(2) (see box below) sets out the principles and values for good governance, integrity, transparency and accountability and sustainable development. Article 31 (3 and 4) (see box below) also includes the right to Privacy which is relevant to this SEP with regard to information relating to personal or private affairs and the protection of communications. Contents from Kenya’s Constitution:

10.(2) The national values and principles of governance include:

Patriotism, national unity, sharing and devolution of power, the rule of law, democracy and participation of the people;
Human dignity, equity, social justice, inclusiveness, equality, human rights, non-discrimination and protection of the marginalised;
Good governance, integrity, transparency and accountability; and Sustainable development.

31. Every person has the right to privacy, which includes the right not to have-
Their person, home or property searched;

Their possessions seized;
Information relating to their family or private affairs unnecessarily required or revealed; or
The privacy of their communications infringed.

Applicable public participation legislation in Kenya includes:

Environmental Management and Coordination (EMCA) Act 1999 (revised 2012);
County Government Act 2012 (which allows citizens to petition for a referendum on planning and development decisions);
The Constitution of Kenya, 2010;
The Employment Act, 2007;
The Urban Areas and Cities Act, 2011;
County Governments Act, 2012;
Intergovernmental Relations Act, 2012;
Land Registration Act, 2012;
National Land Commission Act, 2012;
Prevention, Protection and Assistance to Internally Displaced;
Persons and Affected Communities Act, 2012;
Transition to Devolved Government Act, 2012;
Kenya Wildlife Conservation & Management Act, 2013;
Public Private Partnership Act, 2013;
Environmental Management & Coordination Act, 2015;
Protection of Traditional Knowledge and Traditional;
Cultural Expressions Act, 2015;
Access to Information Act, 2016;
Climate Change Act, 2016;
Community Land Act, 2016; and,
Land Laws Amendment Act, 2016.

The EMCA (1999) and its supporting legislation set out requirements for public disclosure and consultation in tandem with the ESIA process.

2.1.2 South Africa

The need for enhanced community consultation and participation is clearly articulated in the Constitution of the Republic of South Africa, 1996 (Constitution), and also in terms of a variety of developmental local government legislation. Sections 59(1)(a), 72(1)(a) and 118(1)(a) of the Constitution establish public participation in the legislative process. The 2013 Public Participation Framework for the South African Legislative Sector has become the overarching guideline, setting out norms and standards for Public Participation legally. The Parliament of South Africa has also developed a Public Participation Model (PPM) which should be followed. Applicable public participation legislation in South Africa includes:

Constitution of the Republic of South Africa, (Act No. 108 of 1996);
Promotion of Access to Information Act, 2000 (Act No. 2 of 2000) (PAIA);
National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA);
NEMA EIA Regulations 2014 (Government Notice (GN) 324, 325 and 327), as amended;
Department of Environmental Affairs (DEA) Integrated Environmental Management Guideline Series, Guideline 5: Assessment of the EIA Regulations, 2012 (Government Gazette 805);
DEA Integrated Environmental Management Guideline Series, Guideline 7: Public Participation in the Environmental Impact Assessment Process, 2012 (Government Gazette 807);
Public Participation Framework for the South African Legislative Sector (2013);
National Heritage Resources Act, 1999(Act No 25 of 1999) (NHRA); and,
Restitution of Land Rights Act, 1994 (Act No. 22 of 1994), as amended in 2014.

2.2 International Lenders’ Standards

Solarise intends that its engagement with stakeholders is consistent with good international industry practice and has adopted the 2012 version of the International Finance Corporation (IFC) Performance Standards. This SEP is therefore intended to meet the requirements described in Performance Standard (PS) 1 – Assessment and Management of Environmental and Social Risks and Impacts and further requirements for relevant stakeholder consultation and engagement included in the other PSs. Those requirements and lessons learned from the PS Guidance Notes are integrated into this Plan where applicable, particularly in respect of project size. In addition, this Plan draws upon the IFC guidelines set out in “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets”, May 2007, the IFC Good Practice Handbook on Strategic Community Investment and the UN Guiding Principles on Business and Human Rights. Solarise has accepted and will adhere to the requirements of specific investors and/or lenders standards in addition to the 2012 IFC Performance Standards. Where differing levels of performance are detailed among the various standards, the most stringent requirement will be applied.

3. STAKEHOLDER IDENTIFICATION AND MAPPING

3.1 Overview

The purpose of stakeholder identification is to identify organisations and individuals who may be directly or indirectly affected (positively or negatively) or have an interest in a specific project. Stakeholder identification is an approach that requires regular reviews and updates. By nature of its operations, Solarise has some stakeholders that are largely consistent across their projects and other stakeholders that differ on a project-by-project basis. Consequently, this document provides an overview of stakeholders that are largely relevant across Solarise’s portfolio. However, to enable more effective stakeholder engagement (when appropriate), Solarise will carry out a context-specific assessment of potential stakeholders on a project-by-project basis, taking into account their interest in the respective project(s), their need for participation, levels of vulnerability, expectations in terms of participation and priorities. This will be carried out as part of the due diligence and the findings will be used to tailor participation to each type of stakeholder (as applicable). As such, Solarise’s process of identifying individual and organisational stakeholders is an ongoing one.

3.2 Categories of Stakeholders

For the purposes of the analysis, Solarise groups its stakeholders under the following four categories:
Affected parties: Individuals, groups and other entities in the project area that are directly impacted (effectively or potentially, positively or negatively) by projects and/or which have been identified as most likely to be affected by project(s) and which must be closely involved in the identification of impacts and their significance, as well as in decision- making on mitigation and management measures. Primarily, clients, contractors and Solarise’s employees.

For avoidance of doubt: Solarise’s stakeholder engagement largely focuses on this group.

Interested stakeholders: Individuals/groups/entities that may not directly feel the impacts of project(s) but consider or perceive their interests as being affected by projects and/or that could affect projects and the process of its implementation in some way. Examples include:

Government entities, including regulators, departmental services and territorial administration and other entities that control the use of natural resources and the protection of the environment, the health and safety of communities, human well- being, social protection and employment, etc.;
Local and regional authorities, host/neighbouring communities, and residents of working areas who may benefit from work, employment and training opportunities arising from the project(s);
Civil society organisations (NGOs and CBOs) and local chieftains that pursue environmental and socio-economic interests as well as mediation and protection rights of the communities and can become partners in the realization of the project;
Companies and suppliers of services, goods and materials that will be involved, or interested in the work more broadly;
Investors and Lenders; and,
Media and associated interest groups, including spoken, written and audio-visual media and their associations.

3.3 Stakeholder Analysis and Evaluation

Stakeholder analysis and evaluation determines the likely relationship between stakeholders, Solarise and projects and helps to identify appropriate consultation methods for each stakeholder group. Some of the most common methods used to consult stakeholders include:
Phone/email;
Individual interviews/discussions;
Workshops/focus groups;
Distribution of brochures and newsletters; and,
Newspapers/magazines/radio.

The assessment of stakeholder fears and expectations will make it possible to make some decisions on how much effort should be devoted to addressing their needs.

In general, engagement is directly proportional to impact and influence, thus, as the impact of a project on a stakeholder group increases so does the interest/influence of a particular stakeholder increases. Engagement with such stakeholders must be intensified in terms of the frequency and intensity of the engagement method used. Stakeholders with a strong interest and power over the project will be closely managed and their expectations taken into account. This will involve communication and consultation actions and the implementation of project commitments. For stakeholders with low interest and power in relation to Solarise, communication actions will most often be sufficient to meet their needs.

3.4 Stakeholder Database

Solarise will develop and maintain a stakeholder database. This database should contain information on the various stakeholder groups (their representatives, interests and issues), details of the consultations held (including where they took place, topics addressed and outcomes), all commitments made by Solarise and its projects, those outstanding and those achieved, and the recording of specific grievances in a register and the status of their resolution. The maintenance of such a database is important for continuity, especially during transitions between phases of the project where staff changes are quite common.

4. PLANNED STAKEHOLDER ENGAGEMENT ACTIVITIES

4.1 Overview

Solarise will primarily have three types on stakeholder engagement going forward, namely:

Engagements with stakeholders of ongoing/future projects;
Engagements with stakeholders of completed projects (i.e., in operations); and,
Engagements with Solarise regular stakeholders (e.g., investors and funders), primarily those that are interested in Solarise’s general development (rather than project-specific).

4.2 Engagement Methodologies

To carry out its stakeholder engagement activities, Solarise will use a variety of methodologies. Disclosure methods will vary to address various stakeholder groups, taking into account their capacity to understand the information being communicated. Considering guidance in the International Association for Public Participation (IAP2) and it is a public participation toolbox, Solarise anticipates using a mixture of:

Visual representations (photographs and videos) accessible on the Solarise website and social media platforms, for general public use;
Print materials in a range of formats will be prepared and made available as required for specific topics. For instance, Solarise may develop a brochure for a specific project in order to make stakeholders aware of the potential health and safety issues surrounding a particular project;
Hazard warning signage will be erected to inform stakeholders of specific risks, e.g. relating to construction works;
Press: Newspapers, radio and/or television announcements and social media messaging will be used as necessary for reaching the widest possible audience at national/international levels; and,
Community meetings, and face-to-face sessions with neighbouring communities (unlikely, but if necessary, led by the client(s)), especially where a high level of illiteracy or a potential lack of understanding of written information is anticipated.

Solarise respects the privacy and the confidential nature of discussions about some specific issues. Stakeholders’ views and feedback will be protected as much as the various mediums allow. In public disclosure and reporting, Solarise will not attribute specific feedback to any individual stakeholder or organisation without seeking their permission. For each planned engagement campaign or individual activity, Solarise’s Head of Engineering (projects pre-COD) and Asset Manager (projects post-COD) will determine the precise approach and tools to be used to take account of what information is to be disclosed, in what format, and how it will be communicated, and how neighbouring groups may react.

4.3 Planned Engagements

Table 1 below provides an overview of usually planned stakeholder engagement activities, depending on the projects’ stages and stakeholders.

Table 1: Overview of Planned Stakeholder Engagement Activities

Stage	Stakeholders	Engagement Methods	Purpose
Pre-feasibility	Clients	Meetings and Client E&S Assessment.	To determine clients/projects’ E&S risks and decide on whether to proceed or not.
Feasibility	Clients	Visualrepresentations(e.g., presentations and designs), meetings and print materials.	To determine suitable project design, mitigating against potential E&S risks and impacts(e.g., relating to health and safety risks).
Pre‑construction	Clients	Meetings (e.g., relating to contract negotiations and signing, or to support with regulatory compliance (when/if applicable)).	To formalise project. To communicate project timelines and anticipated impacts. To disclose project grievance mechanism.
	Contractors	Meetings, (on a case-by‑case basis) visitsto existing working sites to observe how contractors manage E&S matters (in particular, relating to occupational, health and safety) and Contractors ESHS Assessment.	Meetings (e.g., relating to contract negotiations and signing). To identify possible ESHS risks of working with potential contractors and to decide on whether or not to engage them. Where the decision is made to proceed, to formalise engagement and ensure that Solarise’s E&S expectations are documented in contractors’ contracts. To communicate project timelines and anticipated impacts. To disclose project grievance mechanism.
Construction	Clients, construction contractors and employees	Visual representations (e.g., presentations and designs), meetings, site visits, print materials and hazard warning signage.	To ensure management of E&S impacts and risks as per Solarise’s standards and to document accordingly.
	Others (e.g., local communities)	Display of Solarise contact persons for stakeholder engagement and grievances.	To disclose Solarise contact persons and project grievance mechanism. Display of Solarise’ grievance mechanism.
Operations	Clients and Operations and Maintenance contractor	Visual representations (e.g., presentations and designs), meetings, site visits, print materials and hazard warning signage.	To ensure management of E&S impacts and risks as per Solarise’s standards and to document accordingly.
Throughout projects’ lifecycle	Solarise’s, employees	Visualrepresentations(e.g., presentations and designs), meetings, site visits, print materials and hazard warning signage.	To ensure that Solarise’s employees (as necessary) are aware and implementing, Solarise’s ESMS.
	Media	As per Solarise’s Africa Media Policy.	To (i) monitor media coverage of Solarise and (ii) manage media mentions. Note: To date, Solarise has not received negative media mentions.
	Other	Determined on a case-by‑case basis, depending on stakeholder and purpose of engagement.	To maintain meaningful and respectful engagements.

5. EXTERNAL GRIEVANCE MECHANISM

Effective and timely response to community complaints is essential for maintaining good community relations. Solarise is committed to open dialogue and building trustful and lasting relationships with communities. As a general policy, Solarise will work proactively towards preventing complaints and grievances through the implementation of impact mitigation measures, the ESMS and community liaison. Solarise will manage grievances in the spirit of the UN Guiding Principles on Business and Human Rights, i.e. with the objective to protect and respect those involved, while working to remedy grievances. A grievance can be defined as an actual or perceived problem that might give grounds for a claim. Solarise is open to receiving comments, feedback, concerns, complaints and grievances from stakeholders through various mediums: orally, in print, and via the website (enter address and enable grievance submission on the Solarise website). Anyone will be able to submit a grievance to Solarise if they believe a practice is having a detrimental impact on the community, the environment, or on their quality of life. They may also submit comments and suggestions.

5.1 Confidentiality and Anonymity

Solarise will aim to protect the confidentiality of any person or organisation contacting the project as a matter of course and especially when requested. Solarise will guarantee anonymity in reporting. Individuals will be asked permission to disclose their identity. Investigations will be undertaken in a manner that is respectful of the aggrieved party and the principle of confidentiality. The aggrieved party will need to recognise that there may be situations when disclosure of identity isrequired, and the projects will identify these situations to see whether the aggrieved party wishes to continue with the investigation and resolution activities.

5.2 Grievance Mechanism Procedure

Grievances from stakeholders can be raised verbally or in writing (including using Solarise’s Grievance Form, which is included as Appendix C: Example Grievance Form). They can be submitted at Solarise, clients or contractor offices. Contact details for submission of grievances are provided in Chapter 7. All grievances received – including any anonymous, group, unclear, potentially problematic grievances – will be recorded in Solarise’s Grievance Register (refer to Appendix B: Template External Grievance Register) within 24 hours. The E&S Officer (based in Nairobi) is responsible for logging and documenting all grievances. The receipt of community grievances will be acknowledged within seven working days, and the close-out decision will be communicated to the complainant(s) within 30 days. The date on which the grievance is closed and how thisis communicated to the complainant(s) islogged in the respective grievance log. Where grievances cannot be resolved between the party responsible for the grievance and the person(s) raising the grievances, the latter can choose to raise their grievance through a Second Order Mechanism such as the judiciary system.

5.3 Community Grievances

Community grievances are managed by Solarise’s clients. However, these too can be raised directly with Solarise at each project site or at the Solarise Office. Solarise will subsequently communicate such grievances to the client and agree on a way forward. When necessary, community grievances may be discussed with relevant local chiefs and community forums. Relatedly, Solarise is aware that its grievance mechanism may be used by plaintiffs to raise grievances about aspects that are not related to Solarise (e.g. by host communities/neighbouring communities to raise grievances about clients’ wider working conditions, or other issues that are not related to the project). In such cases, Solarise will:

Record the grievances in its Grievance Register;
Forward the grievance to the responsible party (e.g., the Client); and,

6. RESPONSIBILITIES

Due to the scale (relatively small) of Solarise’s projects, external stakeholder engagement is primarily managed by Solarise’s clients. Subsequently, all communication with affected, neighbouring, host or interested communities and regulators is expected to be managed by Solarise’s clients. Solarise’s Head of Engineering (projects pre-COD) & Asset Manager (projects post-COD) have overall responsibility for ensuring the establishment and maintenance of good working relationships between Solarise and all its stakeholders. Their responsibilities include:

Communicating the stakeholder engagement strategy internally and to contractors;
Integrating team activities with other core business functions;
Managing and implementing Solarise’s stakeholder engagement programme, including identifying any special requirements for involving vulnerable stakeholders, whether individual or groups;
Coordinating the resources needed for site visits and stakeholder engagement (as applicable); and,
Maintaining the Stakeholder Engagement Log (refer to Appendix A: Template Stakeholder Engagement Register) and Grievances Log (refer to Appendix B: Template External Grievance Register).

Should Solarise employees or contractors receive communication directly, they should notify Solarise’s Head of Engineering or Asset Manager as appropriate. As required and appropriate, the Head of Engineering and the Asset Manager work closely with the E&S Coordinator/E&S Officer and contractor HSE staff. The E&S Coordinator/E&S Officer’s primarily stakeholder engagement responsibilities are in the early stages of development, when they assess potential clients/projects E&S risks (using the Client E&S Assessment procedure) and contractors’ environmental, social, health and safety risks (using the Contractors ESHS Assessment procedure). Once contracts have been signed and construction/operations have commented, they provide a supporting role to the Asset Manager.

Solarise’s Head of Marketing & Communications is responsible for media monitoring activities as well as updating Solarise’s social media platforms. All press enquiries are forwarded to the Head of Marketing & Communications, who in turn may involve other Solarise employees/representatives as deemed fit. At each project site, Solarise will display the contact details provided in Chapter 8, which can be used for stakeholder engagement matters and external grievances. The services of specialiststakeholder engagement practitioners or consultants (e.g. a website designer or a social media expert) may also be needed from time to time in exceptional circumstances.