Cambodian Transmission II Co., Ltd.

MIGA has been asked to provide a guarantee for a period of up to 15 years to cover loans provided by  Mizuho Bank, Ltd. (Mizuho, the Guarantee Holder, or the GH) of Japan, and potentially other commercial lender(s), participating in a brownfield project financing to Cambodian Transmission II Co., Ltd. (CTL II, the Project Enterprise, or the PE), following its acquisition of an existing high voltage transmission line in Cambodia from Diamond Power Limited (DPL). CTL II, whose ultimate parent company is HNG Capital Sdn. Bhd., is an operator and owner of an existing transmission line that comprises a 125km long 230kV double circuit transmission line with 310 towers connecting a 230/115kV substation in Kampong Cham (GSKC) and a 230/22kV substation in Kratie (GSKTE) (“the Project”) in the Kingdom of Cambodia. The Project is a build, own, transfer project which is designed for 25 years of operation and sells power to the state-owned company Electricité du Cambodge (EDC) under a power transmission agreement. Since it commenced operations in 2018, the Project has been providing reliable electricity to the national grid.

The GSKTE substation, in Kratie is located 130 km north of Phnom Penh, incorporates worker accommodations and connects to EDC's SCADA system for remote monitoring. Primary equipment includes a 50 MVA 230/22 kV step-down transformer. Similarly, the GSKC substation, near Kampong Cham and 80 km northeast of Phnom Penh, utilizes EDC's SCADA system and houses a 200 MVA 230/115 kV step-down transformer. Both substations include equipment storage. The transmission line transverses three provinces, eight districts, 71 villages, and comprises 310 towers with a 30-meter right-of-way.
 

The Project is categorized as Category B according to MIGA’s Policy on Environment and Social Sustainability (2013). Key potential operational environmental and social (E&S) risks and impacts relate to workers occupational health and safety (including electrocution risks), right-of-way management, public safety (including tower bases being flooded and increasing risk of electrocution, especially for fishermen; mango and banana farmers along the transmission line can be harmed by lightning during rains), emergency preparedness and response, hazardous and solid waste management and disposal (including oils spills management), stakeholder engagement, community health and safety and grievance mechanism (including gender-based violence (GBV) and security). Impacts can be readily mitigated based on good international industry practice.

While all Performance Standards (PSs) are applicable to this investment, our current information indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

• PS1:  Assessment and Management of Environmental and Social Risks and Impacts
• PS2:  Labor and Working Conditions
• PS3:  Resource Efficiency and Pollution Prevention
• PS4:  Community Health, Safety and Security

As this is an existing operational transmission line, PS5 Land Acquisition and Involuntary Resettlement is not applicable. PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable. PS7 Indigenous Peoples is not applicable to the Project as there are no Indigenous Peoples, as defined under PS7, in the project area. PS8 Cultural Heritage is not applicable as there is no planned soil disturbance activities.

The following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project: 

• General EHS Guidelines (2007)
• Guidelines for Electric Power Transmission and Distribution (2007).

The following documents were reviewed by MIGA: 

• Technical, Environmental and Social Review Report: 230 kV Transmission Line & Substation Asset in Cambodia, AFRY Southeast Asia Ltd, August 2024. 
• Initial Environmental and Social Impact Assessment (IESIA) for Power Transmission Line Project 230 kV from Kampong Cham Substations to Kratie Substation. Developed by Creative Green Design Co Ltd (November 2017).
• CTL II E&S Management Plans and Procedures (e.g., Environmental Management Procedure, Environmental Aspect and Impact, Environmental Management Plan (EMP), Health and Safety Manual Procedure, Grievance Mechanism, Security Management Plan, Emergency Response Procedure, Hazard Material Communication, Traffic and Safety Management Plan etc.)
• CTL II Quality Health, Safety and Environment Policy. 
• CTL II E&S Documentation and work procedures (e.g., CTL II Safety Committee meeting minutes, stakeholders meeting minutes, training presentations, Incident Report form and procedures, near miss report, E&S monitoring reports, save work procedures, work permits procedures etc.)

The Lenders and the Borrower appointed AFRY Southeast Asia Ltd, the Lenders’ Technical Advisor (“TA”, “AFRY”) to undertake a Technical and Environmental & Social Review for the Project.  The TA conducted a site visit between July 1st -3rd, 2024 to assess compliance of the Project against the PSs and the national laws and requirements.  In addition to reviewing the above documents, MIGA, GH and potential lenders conducted an Environmental and Social Due Diligence (ESDD) site visit to the project from August 26th -29th 2024. The visit included meetings with CTL II senior management, project managers, engineers and HSE teams in Phnom Penh and visiting the two substations, selected transmission line footing’s locations, and workers accommodations in Kratie substation. MIGA also met with CTL II staff and managers responsible for E&S matters and community members in both substations.

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project, and identified gaps, if any, between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards.

Key environmental and social (E&S) issues associated with the Project business activities are summarized in the paragraphs that follow. 

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System:  The PE has developed a project- specific Environmental and Social Management System (ESMS) for the operation phase. The PE has also developed the following plans and procedures including Environmental Management Procedure, Environmental Aspect and Impact, Environmental Management Plan (EMP), Health and Safety Manual Procedure, Grievance Mechanism, Security Management Plan, Emergency Response Procedure, Hazard Material Communication, Traffic and Safety Management Plan. CTL II is planning to be ISO 14001 (environmental management) and ISO 45001 (Occupational Health and Safety Management Systems (OHSMS)) with the goal to be certified by June 2025.

Policy: CTL II has established a Quality, Health, Safety and Environmental, (QHSE) Policy for the Project dated July 4th, 2024.  The PE’s QHSE policy set out the company’s commitment to sustainability, including protecting the environment and enhancing the livelihoods of local communities. It also describes commitments to protecting the environment, statutory and moral responsibility, provide a safe workplace, transparent governance, compliance with laws and regulations. The policy is communicated to all the staff, contractors and supplier and is posted on display boards at the work areas. The PE also ensures that all the contractors and stakeholders adhere to and align with the PE’s QHSE policy.

Identification of Risks and Impacts:   In accordance with the Cambodian Law on Environmental Protection and Natural Resource Management and the EIA sub-decree of Cambodia, project proponents are responsible for preparing environmental assessment reports and implementing stipulated project approval requirements, including mitigation measures and monitoring.   The project Initial Environmental and Social Impact Assessment (IESIA) was developed and submitted by the previous operator in line with applicable Cambodian regulation, and an environmental protection agreement was issued on March 27, 2017. Once the project was transferred to CTL II, in June 2023, CTL II obtained environmental approval from Ministry of Environment (MoE) to comply with the environmental protection agreement on May 31st, 2023. As a requirement, CTL II will submit environmental and social monitoring reports to MoE every 6 months.

Key potential operational environmental and social (E&S) risks and impacts relate to workers occupational health and safety (including electrocution risks), right-of-way management, community health and safety  (including tower bases being flooded and increasing risk of electrocution, especially for fishers; mango and banana farmers along the transmission line can be harmed by lightning during rains), Emergency preparedness and response, hazardous and solid waste management and disposal (including oils spills management), stakeholder engagement, community health and safety and grievance mechanism (including gender-based violence (GBV) and security) and transportation risks (for patrolmen) The PE will identify and manage key risks and impacts through the implementation of their respective ESMSs and Environmental Management Plans (EMPs).

Management Programs: Various procedures and plans are detailed in the existing ESMS and EMPs as detailed above in the Environmental and Social Assessment and Management System section. The ESMS will provide the framework for the EMPs. The EMP consists of a set of mitigation measures that will be implemented to eliminate, offset or reduce adverse environmental impacts to acceptable levels during operation & maintenance of the project. The EMP include management of environmental aspects such as air quality, noise, water, solid waste, ecological impact, and health, safety and security amongst other topics. The management plans include details on monitoring actions, and the frequency of monitoring, along with the performance indicators and the responsible entity. However, in reviewing the documents, the project lacks a detailed waste (solid and hazardous) management plan. Therefore, the PE will be required to develop a Waste Management Plan (including solid and hazardous) in line with national laws and MIGA PS3 requirements (ESAP).

Organizational Capacity: The PE has established HSE organization which consists of one HSE supervisor, one HSE officer and one HSE coordinator each for GSKC and GSKTE substations. The HSE supervisor is based in the HQ and oversee the overall E&S risks management for the project.  The HSE supervisor, officer and coordinators are responsible for the implementation of the ESMS and related plans and procedures including monitoring and reporting. They are also responsible for managing communities and stakeholders’ and any communities’ related issues/concerns and grievances. The PE will ensure that all the contractors and subcontractors comply with the national laws and MIGA PSs. The PE have established HSE Committee which is chaired by General Manager. The committee comprises of the Head of Department & Section Heads (HR, Admin, Accounts, QMS, ICT, technical, transmission Lines, HSE Personnel), emergency response team, Security team & worker representative as members of the committee. HSE supervisor and HSE officer will support the chairman while HSE coordinators will act as secretary committee to prepare minutes of meeting.

Emergency Preparedness and Response:  PE has developed an Emergency Preparedness and Response Plan (EPRP) for the substation, transmission line and project offices. The EPRP details emergency response procedures in the event of fire/explosion, electrical fires medical emergencies, natural disasters, severe weather/storms, and chemical spills. The EPRP outlines procedures and organization, such that the PE personnel understand and effectively implement environmental protection procedures for both routine activities and unplanned events associated with proposed work. The project has in place an Emergency Response Team (ERT) that comprises personnel from different departments who are tasked to deal and/or execute the EPRP Plan in the event of fire, rescue operation, medical evacuation, site or building evacuation & handling the emergency. The EPRP  procedures is applicable during operations and it outlines (i) Accident and emergency risk identification, communication and management procedure; (ii) Emergency response procedures; iii) evacuation procedure, evacuation route/assembly points and emergency telephone numbers;  iv) Roles and responsibility of the management, HSE committee, emergency response and evacuation teams, HSE teams and staff; (v) Liaison with local emergency authorities; (vi) Engagement with communities on incidents and emergencies; (vii) Specific response procedures for key risks details of emergency back-up system and emergency drills; (viii) Emergency response training; (ix) Inspection and maintenance of the fire extinguishers and  fire suppression systems (FM200/Pyrogen Generator); and (x) Record keeping on emergency response procedures and incidents. In August 2024, the PE has conducted trainings to all staff, contractors and communities living around the substation on emergency preparedness & response.

 Monitoring and Review: As part of the ESMS, the PE will monitor and review the E&S performance of the project and undertake regular on-site E&S monitoring of the implementation of key E&S plans and programs during the Project operation. The key E&S aspects to be monitored include: (i) solid and hazardous waste materials management, (ii) OHS, (iii) life and fire safety, (iv) equipment maintenance, (iv) energy use, (v) water usage, and (vi) birds and bats collisions among others, and to implement key E&S plans and procedures. The PE also prepares E&S monthly reports to the parent company, Leader Energy Group Berhad (formerly known as Leader Energy Holding Berhad) and E&S Assessment Monitoring Reports (including HSE performance) every 6 months for the MoE as part of the permit’s conditions and requirements. Furthermore, the PE is currently monitoring the risks associated with bird and bat collisions involving the transmission line. Based on MIGA review of monitoring reports, the PE will be required to update bird and bat collisions monitoring plans and methodology to conform to the Wildlife Conservation Society's standards for tracking and documenting bird and bat collisions (ESAP).

As a condition of MIGA’s contract of guarantee, the PE will be required to provide MIGA with an annual E&S performance report that evaluate E&S performance against MIGA’s E&S requirements and will include sections on E&S risks and impacts, updates on development effectiveness indicators throughout the guarantee period.

 Stakeholder engagement:  The stakeholder engagement was undertaken as part of the IESIA. The PE has established a Stakeholders Engagement Plan (SEP) and ensures that the local communities and key stakeholders are properly informed of project operations, community engagement, Community Social Responsibility (CSR) activities. The SEP outlines a comprehensive list of stakeholders, including community members, NGOs, vendors, customers, and government entities, and addresses their concerns based on their interests in the project's activities. Ongoing engagements with communities and stakeholders are conducted through regular meetings, with meeting minutes recorded. Patrolmen engage with villages and farmers, receive and document grievances, and patrol transmission lines to prevent illegal activities within the right-of-way (including encroachment). If any illegal activities are observed the patrolman will report to the general manager and senior engineer in charge, who then raises the matter with EDC to work to resolution.

The PE actively supports local communities through CSR initiatives, including scholarships, environmental cleaning, donation and installation of 8 solar pole lamps at a high school, donating basketball equipment and painting basketball court at a public high school, and donation of electronic blood bags monitoring to a blood transfusion center in Kampong Cham. A CSR procedure is established under ISO 9001:2015, with a committee responsible for bi-annual meetings with village officials to discuss key issues and CSR requests.

External Communication and Grievance Mechanisms: The PE has established a Grievance Redress Mechanisms (GRM) for the project. The PE has an ongoing engagement with the communities during periodic meeting and as part of its patrol program for the transmission lines. To date the project has no unresolved grievances. The GRM procedure details how all formal grievances are received, assessed, addressed and recorded in the external grievance register. The external grievance mechanism was communicated to external stakeholders, posted on sign boards at the Project site, and explained to its neighboring communities to raise awareness and offer transparency how stakeholders can raise their grievances. Various channels for stakeholders to raise grievances and concerns formally include telephone and face to face communications, as detailed in PE’s grievance mechanism procedure. 

PS2:  Labor and Working Conditions

During the O&M, the Project employs 48 direct employees (8 female 40 male) and approximately 24 contractor employees. The staff include engineers, operators, site administrators, linesmen and cleaners.

Working Conditions and Management of Worker Relationship: The PE has established Human Resources (HR) Internal Rules and Regulation in line with the national laws and PS2 requirements. These Rules and Regulations stipulate the terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity leave, vacation and holiday, and health insurance. The PE is an equal opportunity employer which does not discriminate against any candidate or employee based on race, color, religion, sex, national origin, age, disability, sexual orientation, gender identity, or any other characteristic. The Rules and Regulations also details the discipline and appeal procedure, sexual harassment, occupational health and safety, and safety and hygiene. The PE has established a Worker Grievances Mechanism (GRM) to facilitate resolution of employment-related issues through designated channels. Upon reviewing documents, it was noted that the project lacked grievances register. Therefore, the PE will be required to develop a worker grievance register template to ensure documentation and response to all verbal and non-verbal complaints. Furthermore, the PE will provide refresher training on grievances mechanisms and channels for all workers. Additional suggestion boxes will be installed at HQ and substations to provide staff with avenues for raising complaints and concerns. (ESAP).

The Rules and Regulations do not restrict employee’ freedom of association and collective bargaining. Although the PE workforce remains non-unionized, employees are permitted to form workers associations and collectively negotiate with management. They have elected a representative to present their concerns and issues to senior management. 

The PE provides workers’ accommodation for workers at the GSKTE substation. Currently, 17 staff are accommodated in the workers’ accommodations which are located next to the substation. The PE will be required to accommodate staff in the rooms with ventilation and windows in line with the IFC/EBRD Guidance Note on Workers’ Accommodations. (ESAP).

Protecting the Workforce: The PE is committed to avoiding all forms of discrimination against their employees based on age, gender, sexual orientation, health, race, nationality, political opinions, or religious beliefs. The PE’s Rules and Regulations policy prohibits the use of any form of forced or compulsory labor. On child and forced labor, the PE do not employ forced labor or children and have committed to enforcing this requirement per the national labor laws and MIGA’s PS2 requirements. 

Occupational Health and Safety (OHS): Key OHS risks related to the Project primarily comprise of working with live power lines (electric shock), working at heights, slips and falls, grass fires, exposure to electric and magnetic fields, exposure to chemicals, transportation risks (for patrolmen) during patrol on narrow and muddy roads and safety issues. The PE has established several plans and procedures related to OHS, including a Health and Safety (H&S) Manual Procedure to provide H&S guidelines to employees, contractors, visitors, and suppliers who are visiting and working in PE premises; Health and Hygiene Procedure to control health hazards and to prevent sickness or illness while working; Safe Work Procedure to guide how to work safely; Emergency Response; Traffic Safety and Journey Management and Hazard Identification Risk Assessment & Control for operations and maintenance of substations and transmission lines. OHS procedures are aligned with the EPRP, which will include fire risk assessment and control systems, fire alarm systems and drills, and emergency preparedness and response. PE is maintaining a right of way of 30 m for the transmission line to minimize potential fire risk from farmers burning grass. PE provides workers with appropriate personal protective equipment and training. Accident/incident reporting procedures have been implemented as part of the Project’s ESMS.  PE prepares monthly internal safety reports which detail all safety inspections, safe man hours, near miss reporting, safety training, safety tests, safety meetings and environmental issues.  The PE follows a permit-to-work system when carrying out maintenance tasks, and all routine and non-routine activity should have an approved risk assessment.  This system requires a method statement, job hazard analysis and isolation checklist to be developed. The work schedule and list of workers also need to be provided for review and approval by the General Manager. Safety inductions are carried out for contractors coming onsite to perform work. Supervision is provided by the PE Senior Engineer during works. 

The PE assess, track, and record its OHS performance during operations. The HSE officer records, and track OHS incidents through an incident tracker and includes OHS performance in its monthly reports to PE’s management. In 2024, the PE had zero reported lost time incidents and zero environmental incidents.

Workers Engaged by Third Parties: The PE currently engages contractors and third parties who employs workers for the project. Nevertheless, during the review of documentation it was observed that there was lack of procedures for monitoring workers engaged by third parties. Therefore, the PE will be required to develop and implement policies and procedures for managing and monitoring the performance of contractors and third-party in relation to MIGA’s PSs as well as integrating these requirements in contractual agreements with such third-party. (ESAP).

Supply Chain: The procurement of energy equipment will largely be managed by the PE. Locally sourcing may be done for smaller items depending on in-country availability. The PE sources energy equipment from the following countries: SCADA from Japan, Power Transformer from China, Current Transformer & Voltage Transformer from Italy, Power Cables from China, Circuit Breakers from Sweden & China, Disconnector Switch from Italy, Inverters from China, Chargers from China and Line & Transformer Protection from Japan. 

PS3:  Resource Efficiency and Pollution Prevention

Resource Efficiency: The Project has insignificant consumption volumes of resources including energy and water. The PE has plans to install Solar Street Lights and Solar LED Lights in the Switchyards in both substations to promote energy efficiency and reinforcing its commitment to sustainable energy solutions. Water is mainly used for domestic use and the estimated water consumption during the operations is expected to be approximately 1850 m3/year.

Pollution Prevention: Impacts during operations are limited. Soil erosion is monitored at the transmission tower foundations as part of regular patrols.  Fire hazards such as cut vegetation is removed from the safety zone and a right of way of 30 m is maintained. Vegetation maintenance including managing invasive plant species within the rights-of-way are carried out by appointed contractors on a yearly basis.  Most work is carried out by hand and herbicides are not used. 

Sulfur hexafluoride (SF6) is being used as a gas insulator at the substations and is sealed and enclosed in the electrical equipment. During maintenance, SF6 is captured in empty cylinder containers.

For the operational phase the main solid waste generated mainly consist of paper, wood, and scrap metals. Hazardous wastes include used chemicals, oil, paint, grease, etc. Electronic wastes like discarded laptop batteries, electricity ordinary lamps, etc. Oil water separator systems are used at the substations. Both solid waste and hazardous waste are collected, stored, labelled and disposed to an approved landfill by a licensed vendor in line with national requirements. However, per MIGA review, it was observed that a standalone project specific WMP was lacking. Therefore, the PE will develop a project specific standalone WMP (solid and hazardous) to include a clear process of how solid and hazardous waste are generated (identifies various waste streams) from each site are stored, segregated, and disposed to an approved landfill by a licensed vendor in line with national requirement and MIGA PS3 requirements. (ESAP).  Also, as part of the WMP, the PE will be required to; (i) develop a hazardous waste tracking and documentation mechanisms to ensure that the hazardous waste is disposed by a licensed vendor to an approved facility/landfill site; ii) store all hazardous waste in a secluded, secure, and locked area and assigned an individual responsible to manage that area; and (iii) improve the hazardous material storage in both substation, and separate, and store hazardous materials in a secluded area away from other materials that are flammable (ESAP).

The project generates at approximately 550 m3/year of sewage mainly from the substation offices and the accommodation facilities in GSKTE substation that has an underground septic tank within the project premises. The septic tanks were designed and constructed in 2018. Given that the septic tank is designed with an overflow pipe, and to minimize the impacts of effluent discharge to the environment, the PE will be required to undertake water testing at the discharge point for the septic tanks to ensure that any effluents discharged from the septic tank is not contaminated and all the parameters meets local and WBG EHS guidelines levels. Additionally, the PE will replace the septic tank concrete lid, secure and fence off the area for staff safety and place hazard signs in the area. (ESAP).

 PS4:  Community Health, Safety and Security

Community Health and Safety: During operations, potential risks to communities include structural and site access issues, fire and safety issues, accidents, and risks of electrocution and electrical faults. Risks are minimized by restricting access to the substation and to equipment through 24-hour security. Substation are fitted with fire suppression and fire extinguishers and teams and security guards are trained in their use.  Power lines (HV), transformers and components are designed and installed according to Good international Industry Practices.

The transmission lines are located primarily in agricultural lands (rice fields). PE confirmed that the Project complied with the transmission grid code for Cambodia and the International Electrotechnical Committee for electromagnetic pulse. The Project maintains a right-of-way of 30 m for the transmission line and a safety perimeter of 5 m away from the land boundaries belonging to the substations, which the PE has confirmed complies for safety standards for nearby communities (including for Electric and Magnetic Fields (EMFs)). Barbed wire is installed on transmission towers to discourage uncontrolled access. Danger signs for electrocution are posted on transmission towers, and information boards in the local language are erected at each tower explaining the dangers to community members. The PE holds village briefings to explain safety signage and risks related to transmission towers. The PE has installed lightning protection on every tower to protect people who have rice fields or plantations under or near the rights-of-way. All transmission towers and the rights-of-way are inspected during routine patrols for a variety of conditions, including integrity, deformation, degradation, wire breaks, soil erosion, vegetation height, and illegal activities (including encroachment within the rights-of-way). Patrolmen regularly interact with community members to explain activities allowed under the transmission lines and remind communities of the hazards of live electricity. Cropping is allowed within the right-of-way as long as vegetation is under 3 m tall. Vegetation above 3 m in height is manually cleared annually during operations.  After a natural hazard event, system upsets or accidents, special patrols are carried out to assess the condition of the Project.

On traffic and transportation, the PE has established a Traffic Safety and Journey Management procedure that details the traffic related risks and how the project plans to reduce travel-related risks and ensuring safety for drivers, vehicle users and passengers. The procedure is applicable to substation access roads, Transmission Lines Right of Way, public roads, and journey or travel to the site. It also outlines the process for reporting accidents.  

Security Personnel: The PE has established a security management plan for the Project and includes commitments to protect project employees, contractors, visitors, suppliers, facilities, property and other assets from security threats.  The substations are fenced and monitored through closed circuit cameras. Third party security guards are stationed at the substations gates to control access and PE has confirmed that hours of work for security guards is in compliance with host country regulations. 

MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:

Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
E-mail: cao-compliance@ifc.org

G.  Availability of Documentation

The following documentation is available electronically as PDF attachment to this ESRS at www.miga.org:

• Initial Environmental and Social Impact Assessment (IESIA) for Power Transmission Line Project 230 kV from Kampong Cham Substations to Kratie Substation. Developed by Creative Green Design Co Ltd (November 2017). 

The above report is also available for viewing at the following locations: 

• Mr. Felimonito Cuevas Lirasan, CTL II General Manager
  • CTL II Office contact number: T +855 23 221703, F +855 23 221783
  • CTL II Office address: No 113, Corner of Norodom Boulevard (St. 41) and Street 240, Phum 4, Sangkat Chak Tomuk, Khan Daun Penh, Phnom Penh, Kingdom of Cambodia.