The Bujagali Energy project involves the development, construction, and maintenance of a run-of-the-river power plant with a capacity of up to 250 megawatts (MW) on the River Nile in Uganda. Bujagali Energy Ltd. (BEL) also manages the construction of approximately 100 kilometers of 132 kilovolt (kV) transmission line on behalf of the Uganda Electricity Transmission Company Ltd. to improve transfer of electricity from the plant. IFC’s investment comprises US$100 million in A and C loans, and MIGA issued a $115 million guarantee to World Power Holdings Luxembourg S.à.r.l., a subsidiary of Sithe Global Power, for its investment in the project.

In April 2013, CAO received a complaint submitted by the Chairman of an informal association of former Bujagali construction workers acting on behalf of himself and over 300 workers at the construction camp and dam site, citing concerns related to labor issues, specifically unpaid wages and benefits from as far back as 2008.

In April 2013, CAO found the complaint eligible and conducted an assessment. During the assessment, the parties agreed to engage in a voluntary dispute resolution process. However, during discussions on the design of the dispute resolution process, the parties were unable to reach consensus on how to proceed.

In November 2014, CAO ended the dispute resolution process and the case was transferred to CAO’s compliance function for appraisal, in accordance with CAO’s Operational Guidelines. Considering the similarity of the labor issues raised, CAO decided to merge this case with Bujagali-04 for the purposes of the compliance process.

In April 2015, CAO completed its compliance appraisal for the Bujagali-04 and 06 cases concluding that a compliance investigation was merited. 

In December 2017, CAO published its Compliance Investigation Report. In relation to the Bujagali Energy-06 case, CAO found that while IFC initially established a framework to ensure subcontractors adhered to IFC's labor standards, it later determined that these standards did not apply to subcontractor workers during a wage dispute. CAO concluded that this decision was incorrect, leading to unaddressed allegations of significant adverse effects on the subcontractor's employees. In December 2017, IFC provided a management response to the CAO investigation report and  CAO started monitoring IFC’s actions in response to the investigation findings.

In April 2018, CAO merged a later case also concerning worker health, safety, and compensation (Bujagali Energy-08) with the ongoing monitoring of the Bujagali Energy-04 and -06 cases.

In May 2018, IFC provided CAO with an addendum to its management response to the Bujagali Energy-04 and 06 investigation, and the Bujagali Energy-07 investigation and in June 2018, IFC provided CAO with it Terms of Reference ”Review of Available Information – Underpaid Construction Workers, Uganda Consulting Assignment.” CAO initiated the monitoring of the actions listed in the addendum and compliance with the Performance Standards. 

CAO Monitoring Reports

In March 2019, CAO published its First Monitoring Report on IFC/MIGA's management response to the Bujagali Energy-04, 06, 07, and 08 cases. In response to the Bujagali-06 complaint, CAO awaited a consultant's report commissioned by IFC to validate the complainants' claims for lost wages. The monitoring report highlighted delays in implementing IFC's proposed actions to address CAO's findings.

In May 2020, CAO published its Second Monitoring Report. In response to the Bujagali-06 complaint , IFC’s consultant found insufficient documentation to validate the former workers' claims about wages and benefits. CAO expressed concerns about the methodology used and noted that the report did not address the workers' claims regarding compensation for workplace injuries.

In September 2022, CAO published a Third Monitoring Report. The report analyzed whether IFC adequately addressed CAO’s non-compliance findings, building on the 2019 and 2020 monitoring reports.  

IFC initiated an Advisory Services program to support skills and capacity development for some workers injured during project construction. This action would partially address CAO’s findings regarding impacts on injured workers. However, other non-compliances and associated impacts identified by CAO, including those affecting dependents of workers who were killed, remained largely unaddressed.

Concerning unpaid wages and benefits, evidence of the amount owed to former subcontractor workers surfaced and was verified by IFC. However, IFC did not take further action. The legally binding commitments made by BEL, requiring subcontractor compliance with IFC’s labor standards, remained unfulfilled, as the project construction workers remained unpaid.

In May 2024, CAO published its fourth Monitoring Report.  CAO found IFC's response to non-compliance regarding unpaid wages unsatisfactory. Although IFC verified the wages owed to workers based on new evidence, it refused to address the non-compliance issues, citing fulfillment of its commitment to review the claims.

As the Bujagali hydropower project remains active and IFC has not resolved its non-compliances and addressed related impacts raised by the complainants, CAO will continue to monitor this case.

The Omnibus Monitoring Report, which includes the monitoring report for this case, is available in English.