Lomé Container Terminal (LCT) is a nationally incorporated company operating on the Gulf of Guinea. In December 2008, the Government of Togo awarded the company a 35-year concession—with an optional 10-year extension—to develop, construct and operate a container cargo terminal within the Port of Lomé. In 2011, IFC provided a total of €82.5 million in loans to LCT and also mobilized approximately €142.5 million from other lenders. Construction works started in 2012 and the terminal has been operational since October 2014. In 2015, IFC provided LCT with additional financing of €10 million. IFC’s loan to LCT is scheduled to be fully repaid in December 2023.

On August 20, 2022, CAO received a complaint from the Collectif des personnes victims d’érosion côtière (the Collectif), a Togolese community-based nongovernmental organization representing themselves and a group of residents from six coastal villages to the east of the port and container terminal. The complainants are supported by the Washington DC-based organization Bank Information Center (BIC). The complaint raised concerns about the impacts of coastal erosion caused by the construction and operation of the container terminal, port, and breakwater in Lomé, which the Collectif asserts are impacting around 2,500 people.  Specifically, they allege damage and loss of property as well as wider displacement impacts, loss of livelihood and land, damage and loss of sacred sites, community division and safety concerns, and overall concerns about delays in the ongoing process for an earlier complaint filed in 2015 (LCT-01).

On December 20, 2022, CAO found the complaint eligible for assessment. CAO completed the assessment process on June 23, 2023. During the assessment, the complainants and company did not wish to engage in a CAO dispute resolution process. Consequently, the case proceeded to a compliance appraisal.

CAO completed the compliance appraisal in November 2023. In the compliance appraisal report, CAO found preliminary indications of harm to the complainants, specifically in relation to coastal erosion impacts and community division. CAO also found preliminary indications of potential non-compliance with IFC’s environmental and social requirements to address issues relating to coastal erosion impacts, third-party performance, and stakeholder engagement. In addition, CAO found a plausible link between the alleged harm and potential IFC non-compliance.

While the complaint met the criteria for a compliance investigation, CAO found that the complaint is substantially related to the issues raised in the LCT-01 complaint, which is currently in the compliance monitoring phase. Therefore, in accordance with para. 93 of the CAO Policy, CAO decided to merge this complaint with the LCT-01 compliance process.