Gatineau – September 5, 2025 – Global Affairs Canada has determined that the proposed Targeted Support for Irrigated Lands and Opportunities for Nutrition is not likely to cause significant adverse environmental effects. 

This determination was based on a consideration of the following factors: 

• community knowledge; 

• comments received from the public; and 

• technically and economically feasible mitigation measures. 

Mitigation measures taken into account for this determination are:  

1. Reliability of KfW's Environmental Due Diligence Approach 

All projects financed by KfW must comply with KfW's Sustainability Guideline. This means that projects must adhere to: 

• The respective national laws; 

• The Exclusion List and Supplementary Requirements (Exclusion List and Supplementary Requirements | KfW), as well as KfW Group's sector guidelines aligned with the Paris Agreement (Sector Guidelines – Steering KfW's new financing activities according to the targets of the Paris Climate Agreement | KfW); 

• The fundamental labor standards of the International Labour Organization (Ratifications of fundamental conventions) (10 conventions and one protocol); 

• The guidelines of the BMZ (German Federal Ministry for Economic Cooperation and Development). 

The basis for assessing the environmental, social, and climate impacts of a financial cooperation measure is its compliance with relevant national legislation and with KfW Development Bank's evaluation requirements. KfW's evaluation standards provide for systematic environmental and social due diligence for all financed projects and are aligned with international best practices, including the Environmental and Social Standards of the World Bank Group and relevant Operational Policies of the World Bank. 

The World Bank's Environmental and Social Framework, in effect since 2018, is normative and detailed and includes 10 Environmental and Social Standards, such as: 

• ESS 1 – Assessment and Management of Environmental and Social Risks and Impacts; 

• ESS 3 – Resource Efficiency and Pollution Prevention and Management; 

• ESS 4 – Community Health and Safety; 

• ESS 5 – Land Acquisition, Restrictions on Land Use, and Involuntary Resettlement; 

• ESS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources; 

• ESS 7 – Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities; 

• ESS 10 – Stakeholder Engagement and Information Disclosure, which requires meaningful consultation, access to information, and grievance mechanisms for stakeholders. 

KfW Development Bank applies its own directive titled "Sustainability Guideline – Assessment of Environmental, Social and Climate Aspects" (July 2024), based on the following principles: 

• Systematic Environmental and Social Assessment (ESA) for all projects; 

• Project categorization according to environmental and social risk level (A, B, C); 

• Stakeholder engagement and grievance mechanisms; 

• Climate integration: mitigation and adaptation to climate change; 

• Monitoring and transparency: regular reporting, audits, and publication of results. 

The KfW Sustainability Guideline outlines the structured approach used to assess environmental and social risks of the projects it finances. This approach involves classifying projects into four categories based on their environmental and social risk level: 

• Category A: Severe, widespread, irreversible environmental and social risks and impacts. Requires a full Environmental and Social Impact Assessment (ESIA). 

• Category B+: Moderate to high risks, but localized and reversible. Requires thorough due diligence and often a simplified ESIA. 

• Category B: Moderate risks, generally localized and manageable with standard mitigation measures. An Environmental and Social Impact Notice (ESIN) or an Environmental and Social Management Plan (ESMP) is often sufficient. 

• Category C: Low or negligible risks. No formal environmental study required, but compliance verification is conducted. 

 

2. Diligent Application of KfW Procedures to the ACTION Initiative 

The 2024 monitoring mission observed that both national E&S requirements and KfW's standards are being acceptably met. The risk management framework includes the Environmental and Social Commitment Plan (ESCP), the Environmental and Social Management Framework (ESMF), Environmental and Social Impact Notices (ESINs) developed for various sub-projects (with corresponding Environmental and Social Management Plans – ESMPs), and Construction Site ESMPs (C-ESMPs) for sub-projects. The bidding documents for construction companies include the necessary E&S requirements. 

Environmental and Social Management Framework (ESMF): 

The initiative as a whole is not covered by a single environmental study due to the unknown number of sites at the project's outset. However, an ESMF was developed to define major risk categories and propose mitigation measures. Identified potential negative environmental risks include: workplace accidents, pollution (air, noise, soil, and water), erosion, reduction of water resources, spread of waterborne diseases, proliferation of invasive aquatic vegetation, and loss and/or degradation of natural habitats. 

Mitigation measures are grouped into five categories: 

1. Participatory planning procedures to avoid land and social conflicts and promote project ownership by beneficiaries; these include the development of rules/conventions/terms of use for the constructed/rehabilitated infrastructure. 

1. Application of good construction and operational practices. 

1. Reforestation and other biological measures to compensate for deforestation, improve soil stability, conserve water and soil resources, enhance local flora and fauna, and protect hydro-agricultural infrastructure from siltation. 

1. Water and soil conservation and restoration measures to minimize erosion caused by land clearing and infrastructure use. 

1. Awareness, training, and mobilization campaigns during infrastructure operation. 

Environmental and Social Commitment Plan (ESCP): 

The ESCP for the ACTION project is an annex to the contract between KfW and Mali's Ministry of Agriculture, outlining KfW's environmental and social requirements and the obligations of the Malian government. This plan references Environmental and Social Standards (ESS) that must be respected. These standards are grouped into 10 categories: 

• Environmental and social risk assessment and management; 

• Employment and working conditions; 

• Resource efficiency and pollution prevention and management; 

• Community health and safety; 

• Land acquisition, restrictions on land use, and involuntary resettlement; 

• Biodiversity conservation and sustainable management of biological natural resources; 

• Indigenous peoples/Sub-Saharan African historically underserved traditional local communities; 

• Financial intermediaries. 

• Stakeholder Engagement and Information 

This Environmental and Social Commitment Plan (ESCP) ensures that communities are taken into account and that public consultations have been conducted. The rights and interests of Indigenous Peoples are also systematically considered. In the case of water infrastructure projects, particularly the construction of micro-dams, the absence of land conflicts must be confirmed prior to the start of works. Field engineers review all Environmental and Social Impact Assessments (ESIAs), Environmental and Social Impact Notices (ESINs), and Environmental and Social Management Plans (ESMPs), and ensure their proper implementation. 

 

3. Environmental Risk Assessment and Mitigation for Physical Infrastructure under the ACTION Initiative 

Under the ACTION project, risk categorization and the production of required deliverables are managed in accordance with Malian law. This means that site-specific environmental deliverables are required for each location and physical intervention. 

The only Category A physical infrastructure is the construction of the large bridge-dam, for which a full ESIA was prepared and reviewed by AMC. 

Other physical infrastructures fall under Category B or C, and where required, ESINs were prepared and reviewed by AMC. For example, small-scale irrigation projects are classified as Category "B" by KfW (while Malian law assigns them Category C). 

The main mitigation measures planned include: 

• To protect surface water quality, construction waste will be systematically collected and removed, and washing of machinery will be prohibited near watercourses to prevent pollution. 

• To preserve soil stability and quality, anti-erosion structures such as stone bunds and windbreak hedges will be installed in sensitive areas, and contaminated soils will be treated in sealed containers. 

• To limit vegetation destruction, the construction base camp will be set up in a sparsely wooded area, tree felling will require prior approval from forestry services, and compensatory and enhancement reforestation operations will be carried out (e.g., 5 hectares in Sangarébougou and 7 hectares in Kolessebougou), including the planting of live hedges (henna), néré, and mango trees, with the creation of water points for irrigation. Additionally, in Toukoto, a 500-hectare protected area will be established and enriched with local species (eucalyptus, baobab, moringa, etc.) to restore affected plant biodiversity. A local convention will also be developed and validated by the municipality to regulate forest and pastoral resource use and prevent conflicts. Trees with cultural significance (e.g., sacred trees) or ecological importance (e.g., protected or rare species) are prioritized for on-site preservation. Additionally, certain species are protected under Malian or international regulations, which prohibit their removal. The process begins with an inventory of trees conducted by environmental experts from consulting firms during technical field studies, aimed at identifying which trees should be preserved and which may be cut down. This inventory includes characteristics such as species, age, size, and location, and also takes into account concerns expressed during public consultations (with beneficiaries).

• To preserve wildlife habitats, signage will be installed to reduce disturbances caused by construction and traffic, a site management plan will be implemented, and anti-poaching measures will be enforced. Animal harvesting will be prohibited, and deforested areas will be revegetated to preserve natural habitats. A collective fishing agreement will be established to regulate use of the developed pond. 

• To reduce noise and dust emissions, roads will be regularly watered, trucks will be covered, and vehicle speed will be limited near inhabited areas. 

• To protect surface and groundwater quality, latrines will be built on-site, along with waste sorting systems and wastewater treatment via soak pits. To prevent soil pollution, machinery will be serviced and drained in designated areas, and hydrocarbons will be handled with care to reduce contamination risks. Oils and waste will be collected to avoid pollution through infiltration or discharge of harmful substances. 

• To reduce erosion and soil degradation, 500 linear meters of stone bunds will be constructed on the slopes of the lowland area, and borrow pits and quarries will be restored after works. Excavated materials will be reused for dike construction, deposit and parking areas will be rehabilitated, and anti-erosion structures will be installed to maintain soil stability. 

• No animals will be harmed in the project, and no animal testing will be conducted.

Global Affairs Canada is satisfied that that the carrying out of the project is not likely to cause significant adverse environmental effects. 

Therefore, the KfW may carry out the project, exercise any power, perform any duty or function, or provide financial assistance to enable the project to be carried out in whole or in part.