Power One E&S Due Diligence - AVGroup

Power One E&S Due Diligence

Client: Dragon Capital, Amber Infrastructure

Amber Dragon Infrastructure Fund I (ADUIF), established by Dragon Capital and Amber Infrastructure, considered providing financing to Power One for the development, construction, and operation of decentralized power generation and energy storage facilities in Ukraine.

The Project comprises Gas Engine Power Plants (GEPPs) and Battery Energy Storage Systems (BESS). To support ADUIF’s investment decision-making process and future engagement approach, AVG was commissioned to independently assess and verify the Project against a comprehensive Reference Framework, identify compliance gaps, and determine the necessary mitigation measures and follow-up actions.

PROJECT PHASES AND TASKS:

01
PHASE 1: Policy Screening

Conduct a comprehensive assessment against the ADUIF Exclusions, Restrictions and Eligibility Policy, E&S Policy, and Human Rights Policy to confirm compliance.

02
PHASE 2: Legal and Regulatory Compliance

Review key permits and evidence of compliance, with particular focus on environmental, land, labour, and occupational health and safety (OHS) requirements.

03
PHASE 3: IFC Performance Standards Assessment

Evaluate applicable IFC Performance Standards in areas of elevated risk, assess the robustness of the Environmental and Social Management System (ESMS), and verify the adequacy of stakeholder engagement processes.

04
PHASE 4: World Bank EHS Guidelines Review

Apply the General and applicable Sector Environmental, Health and Safety (EHS) Guidelines to identify deviations from Good International Industry Practice (GIIP) and recommend technical improvements.

05
PHASE 5: EBRD Requirements Assessment

Review compliance with applicable EBRD Environmental and Social Requirements (ESRs 1–10), focusing on elevated-risk areas and additional requirements beyond IFC standards where relevant.

06
PHASE 6: EIB Standards Review

Assess compliance with relevant European Investment Bank (EIB) Environmental and Social Standards and identify any required corrective actions.

07
PHASE 7: Climate Risk Assessment

Conduct climate risk screening and limited scenario testing in line with the Paris Agreement and TCFD recommendations to identify key vulnerabilities and recommend proportionate resilience measures.

08
PHASE 8: EU Taxonomy and SFDR Assessment

Complete DNSH (Do No Significant Harm) and Minimum Safeguards assessments, evaluate potential Substantial Contribution, verify SFDR Article 8 indicators, and assess data readiness.

09
PHASE 9: Impact Indicators Assessment

Evaluate the Project’s contribution to the UN Sustainable Development Goals (SDGs) and identify measurable project-level indicators aligned with designated E&S Performance Indicators.

10
PHASE 10: Institutional Delta Requirements

Incorporate investor-specific ESG requirements, including enhanced governance expectations, diversity, equity and inclusion (DEI) commitments, and disclosure obligations.

KEY RESULTS:

1.  Environmental and Social Due Diligence Report

Delivered a comprehensive report summarizing assessment findings against each component of the multi-layered Reference Framework.

2. Risk Register and Gap Analysis

Developed a detailed gap analysis and risk register identifying both material and residual environmental and social risks, as well as the Project’s positive environmental and social attributes.

3. Executive Summary

Prepared a targeted executive summary outlining the key environmental and social considerations required to support the Fund’s final investment decision.

4. Environmental and Social Action Plan (ESAP)

Developed a proportionate Environmental and Social Action Plan (ESAP) comprising specific, measurable, and time-bound actions.

All identified compliance gaps and technical mitigation measures were structured as distinct, clearly described, and standalone actions to facilitate effective compliance monitoring and auditing while avoiding unnecessary consolidation of separate requirements.

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