Environmental and Social Action Plan (ESAP)
Project: Project Mercury – Hyperscale Data Centre, Johor Bahru, Malaysia
Framework: Equator Principles IV (EP4)
Issue # 1:
Stakeholder Engagement Plan requires strengthening
Action:
Update and implement the Stakeholder Engagement Plan (SEP) to: (i) identify vulnerable and at‑risk groups, including migrant workers; (ii) define proactive engagement and disclosure measures during construction and operations
Completion Indicator:
Revised SEP approved and implemented; disclosure evidence available.
Deadline:
Prior to first disbursement on revised documents/ES instruments
Verification:
Disclosure of approved SEP; website / noticeboard disclosure
Responsibility:
Project Owner
Issue # 2:
Grievance mechanism not fully formalised or accessible to all stakeholders, including AIIB independent mechanism
Action:
Establish and operationalize a formal, project‑level Grievance Redress Mechanism (GRM) covering workers, communities, and other stakeholders, with defined timelines, escalation procedures, roles and responsibilities, confidentiality provisions, and clear distinction from AIIB’s Project‑affected People’s Mechanism (PPM). Ensure GRM information is communicated in relevant languages and accessible formats.
Completion Indicator:
Grievance mechanism operational and communicated to workers and stakeholders.
Deadline:
Prior to first disbursement
Verification:
Disclosure of Grievance redressal mechanism and PPM
Responsibility:
Project Owner / PMX
Issue # 3:
No independent environmental and social audit programme
Action:
Conduct annual independent environmental and social audits during the construction phase to assess compliance with CESMP and AIIB requirements.
Completion Indicator:
Independent E&S audit report completed annually during the construction phase.
Deadline:
Annually during construction, starting 2026.
Verification:
Independent E&S audit reports submitted to AIIB.
Responsibility:
Project Owner
Issue # 4:
Operations ESMP(O-ESMP) not yet developed
Action:
Prepare and implement an O-ESMP covering pollution control measures and environmental monitoring, waste management, GHG emissions, water management, occupational H&S and emergency response and business continuity.
The O-ESMP will also include a corporate management system with policies, procedures, organizational structure and ES processes to manage ES risk during operations.
The O-ESMP will also include a corporate management system with policies, procedures, organizational structure and ES processes to manage ES risk during operations.
Completion Indicator:
Operations ESMP approved and implemented prior to operations phase.
Annual ES monitoring report to AIIB
Implement ES training program
Annual ES monitoring report to AIIB
Implement ES training program
Deadline:
Prior to operations
Annual reporting during operations until 3years
Onboarding and regular training sessions. Updates in annual reporting
Annual reporting during operations until 3years
Onboarding and regular training sessions. Updates in annual reporting
Verification:
Disclosure of approved ESMP document and implementation procedures.
Responsibility:
Project Owner / HSE Officer
Issue # 5:
No community investment plan (CIP)
Action:
Prepare and implement a CIP to provide digital skills training to people living in Johor Bahru, with a target of ≥50% female participation.
Completion Indicator:
CIP documentation, including board approved budget, and annual implementation updates
Deadline:
Starting 2026
Verification:
CIP to AIIB.
Responsibility:
Project Owner
Issue # 6:
Water Stress
Action:
Prepare Water Resource Impact Assessment covering water layout and demand forecasting to ensure sufficient supply without competing uses
Completion Indicator:
Assessment of water demand and availability in the WRIA
Deadline:
6 months after first disbursement
Verification:
WRIA to AIIB
Responsibility:
Project Owner
Issue # 7:
Labour management arrangements require strengthening due to contractor‑heavy and migrant workforce
Action:
Update and implement the project‑specific Labour Management Procedure (LMP) to: (i) confirm total workforce numbers for construction and operations; (ii) define contractor and subcontractor responsibilities; (iii) address migrant worker risks, recruitment practices, accommodation and transport standards; and (iv) prohibit recruitment fees, in line with ILO standards and AIIB ESS2.
Completion Indicator:
Updated LMP approved and implemented; workforce profile disclosed in E&S monitoring reports.
Deadline:
Prior to first disbursement
Verification:
Approved LMP; workforce data in monitoring reports
Responsibility:
Project Owner together with EPC Contractor
Issue # 8:
Human rights risks have not been systematically assessed
Action:
Conduct a documented human rights risk screening proportionate to project risks, with particular attention to migrant labour and contractor‑managed workforce. Integrate identified risks and mitigation measures into the LMP, contractor management procedures, audits, and GRM.
Completion Indicator:
Human rights risk screening completed, and mitigation measures integrated into project ES instruments.
Deadline:
Prior to first disbursement
Verification:
Human rights risk screening note; updated ES instruments
Responsibility:
Project Owner
Issue # 9:
Gender and social inclusion considerations are not systematically integrated into project E&S management
Action:
Integrate gender equality and social inclusion measures across relevant project E&S instruments, including the Labour Management Procedure, Stakeholder Engagement Plan, and Grievance Redress Mechanism. Measures shall include, where feasible: (i) sex‑disaggregated workforce and grievance data; (ii) gender‑sensitive and confidential grievance handling; and (iii) worker and contractor awareness on inclusive and non‑discriminatory workplace practices.
Completion Indicator:
Gender and inclusion measures reflected in updated SEP/o-ESMP and reported through E&S monitoring.
Deadline:
Prior to first disbursement
Verification:
Updated ES instruments; E&S monitoring reports
Responsibility:
Project Owner together with EPC Contractor
#
Issue
Action
Completion Indicator
Deadline
Verification
Responsibility
1
Stakeholder Engagement Plan requires strengthening
Update and implement the Stakeholder Engagement Plan (SEP) to: (i) identify vulnerable and at‑risk groups, including migrant workers; (ii) define proactive engagement and disclosure measures during construction and operations
Revised SEP approved and implemented; disclosure evidence available.
Prior to first disbursement on revised documents/ES instruments
Disclosure of approved SEP; website / noticeboard disclosure
Project Owner
2
Grievance mechanism not fully formalised or accessible to all stakeholders, including AIIB independent mechanism
Establish and operationalize a formal, project‑level Grievance Redress Mechanism (GRM) covering workers, communities, and other stakeholders, with defined timelines, escalation procedures, roles and responsibilities, confidentiality provisions, and clear distinction from AIIB’s Project‑affected People’s Mechanism (PPM). Ensure GRM information is communicated in relevant languages and accessible formats.
Grievance mechanism operational and communicated to workers and stakeholders.
Prior to first disbursement
Disclosure of Grievance redressal mechanism and PPM
Project Owner / PMX
3
No independent environmental and social audit programme
Conduct annual independent environmental and social audits during the construction phase to assess compliance with CESMP and AIIB requirements.
Independent E&S audit report completed annually during the construction phase.
Annually during construction, starting 2026.
Independent E&S audit reports submitted to AIIB.
Project Owner
4
Operations ESMP(O-ESMP) not yet developed
Prepare and implement an O-ESMP covering pollution control measures and environmental monitoring, waste management, GHG emissions, water management, occupational H&S and emergency response and business continuity.
The O-ESMP will also include a corporate management system with policies, procedures, organizational structure and ES processes to manage ES risk during operations.
The O-ESMP will also include a corporate management system with policies, procedures, organizational structure and ES processes to manage ES risk during operations.
Operations ESMP approved and implemented prior to operations phase.
Annual ES monitoring report to AIIB
Implement ES training program
Annual ES monitoring report to AIIB
Implement ES training program
Prior to operations
Annual reporting during operations until 3years
Onboarding and regular training sessions. Updates in annual reporting
Annual reporting during operations until 3years
Onboarding and regular training sessions. Updates in annual reporting
Disclosure of approved ESMP document and implementation procedures.
Project Owner / HSE Officer
5
No community investment plan (CIP)
Prepare and implement a CIP to provide digital skills training to people living in Johor Bahru, with a target of ≥50% female participation.
CIP documentation, including board approved budget, and annual implementation updates
Starting 2026
CIP to AIIB.
Project Owner
6
Water Stress
Prepare Water Resource Impact Assessment covering water layout and demand forecasting to ensure sufficient supply without competing uses
Assessment of water demand and availability in the WRIA
6 months after first disbursement
WRIA to AIIB
Project Owner
7
Labour management arrangements require strengthening due to contractor‑heavy and migrant workforce
Update and implement the project‑specific Labour Management Procedure (LMP) to: (i) confirm total workforce numbers for construction and operations; (ii) define contractor and subcontractor responsibilities; (iii) address migrant worker risks, recruitment practices, accommodation and transport standards; and (iv) prohibit recruitment fees, in line with ILO standards and AIIB ESS2.
Updated LMP approved and implemented; workforce profile disclosed in E&S monitoring reports.
Prior to first disbursement
Approved LMP; workforce data in monitoring reports
Project Owner together with EPC Contractor
8
Human rights risks have not been systematically assessed
Conduct a documented human rights risk screening proportionate to project risks, with particular attention to migrant labour and contractor‑managed workforce. Integrate identified risks and mitigation measures into the LMP, contractor management procedures, audits, and GRM.
Human rights risk screening completed, and mitigation measures integrated into project ES instruments.
Prior to first disbursement
Human rights risk screening note; updated ES instruments
Project Owner
9
Gender and social inclusion considerations are not systematically integrated into project E&S management
Integrate gender equality and social inclusion measures across relevant project E&S instruments, including the Labour Management Procedure, Stakeholder Engagement Plan, and Grievance Redress Mechanism. Measures shall include, where feasible: (i) sex‑disaggregated workforce and grievance data; (ii) gender‑sensitive and confidential grievance handling; and (iii) worker and contractor awareness on inclusive and non‑discriminatory workplace practices.
Gender and inclusion measures reflected in updated SEP/o-ESMP and reported through E&S monitoring.
Prior to first disbursement
Updated ES instruments; E&S monitoring reports
Project Owner together with EPC Contractor