CAO Cases

Arne Hoel, The World Bank

Europe & Central Asia

Georgia / Trans-Anatolian Pipeline-01/Vale

Former worker at ENKA
Date Filed
March 29, 2017
Working conditions, health and safety conditions
Case Status



MIGA is actively considering providing a guarantee to the Southern Gas Corridor (SGC) against non-honoring of sovereign financial obligations for a loan of up to USD 750M in respect of SGC’s investment in the Trans-Anatolian Natural Gas Pipeline (TANAP). The project consists of the construction and operation of the pipeline, a part of the Southern Gas Corridor value chain, which aims to transport natural gas from Shah Deniz Gas Field in Azerbaijan to Turkey and Europe.


In March 2017, CAO received a complaint from former worker of ENKA INSAAT VE SANAYI AS (ENKA) in Georgia. ENKA is a subcontractor working on the the South Caucasus Pipeline Expansion Project (SCPX), which MIGA recognizes to be an associated facility to the TANAP project. The complaint raises concerns with regards to the working conditions at the Vale site in Georgia, especially health and safety conditions applied by ENKA. 


CAO Action

On the basis that MIGA considers the South Caucasus Pipeline to be an associated facility to TANAP, CAO found the complaint eligible for assessment in April 2017. During the assessment, there was a lack of consensus amongst the parties to engage in a CAO facilitated dispute resolution process. Hence, in accordance with CAO’s Operational Guidelines, the complaint was referred to CAO’s compliance function for appraisal.


CAO completed the compliance appraisal in March, 2018. Through this process, CAO determined that a compliance investigation is not the appropriate response to the complaint. In reaching this conclusion, CAO considered the following:

the construction work, which is the subject of the complaint, has been completed and ENKA is no longer working on the SCPX project

the issues raised by the complainant occurred prior to MIGA providing a guarantee for project

available evidence does not suggest that the impacts alleged constitute a legacy issue of such a serious nature as would require MIGA to refrain from supporting a proposed project on the basis of third-party risk.

All documents relating to this case are available under "View Documents" below.



The case closed on March 13, 2018, after compliance appraisal. 


Status as of March 19, 2018

Project information

Project Name & Number
Trans-Anatolian Pipeline 13661
Southern Gas Corridor (SGC)
Oil, Gas and Mining
Europe & Central Asia
Azerbaijan, Georgia, Turkey
Environmental Category
US$1.1 billion

Case Tracker


  • Eligible: Completed
  • Assessment Period: Completed


  • Under Appraisal: Closed