Lomé Container Terminal (LCT) is a nationally incorporated company operating in 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 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 loans to LCT were fully repaid on December 15, 2023, ending the financial relationship.    

On August 20, 2022, CAO received a complaint from the Collectif des personnes victimes d’érosion côtière (Collective of persons victims of coastal erosion), a community association representing riverine settles who claim to be negatively impacted by the construction of the project. The complaint  cites concerns about land erosion in their communities, as well as property damage, displacement, loss of livelihood, damage to sacred sites, community division, safety issues, and delays in resolving a previous 2015 complaint (LCT-01). 

In April 2024, CAO released a monitoring report. The report covered IFC actions between August 2021 and December 2023. CAO observed that the finalization of a coastal erosion study in 2022 is a significant milestone for IFC and included, among other sources of erosion, an estimate of the LCT project’s contribution to coastal erosion. CAO acknowledged that IFC actively supported its client in commissioning and finalizing this study and had made efforts to encourage disclosure of the study in accordance with Performance Standard (PS) 1 requirements. However, these efforts had been unsuccessful, and the study had still not been disclosed more than two years after its completion. This lack of disclosure remained a non-compliance with PS1.  

In addition, delayed disclosure of the study’s findings prevented any mitigating and remedial actions from being taken to address coastal erosion impacts related to the LCT project’s construction. Based on the coastal erosion study and additional expert advice received, CAO stated it was satisfied that the link between the IFC-financed project and erosion impacts had been demonstrated. CAO found that, consistent with the Sustainability Policy and PS1, IFC should have worked with its client and other relevant stakeholders to assess project-related erosion impacts on coastal communities. Finally, the report mentioned allegations of client intimidation during the monitoring period and the related low-trust environment between the client, the complainants, and other coastal community members.  

On the basis that the monitoring report was published after the end of IFC’s financial relationship with its client, CAO recommended the following actions for prompt implementation by IFC to address the remaining non-compliances:  

• Increase efforts and use remaining leverage with stakeholders to ensure the disclosure of the coastal erosion study and its findings; 
• Work with LCT to assess project-related erosion impacts on coastal communities downdrift of the project, in consultation with affected communities, and identify related mitigating and remediating measures; and 
• Continue supporting LCT to improve its stakeholder engagement and awareness of risks to communities according to good international industry practice and guided by PS1.  

In April 2025, CAO published an Omnibus Monitoring Report for Q3 2025, which included a monitoring update for this case. CAO noted that IFC had continued to engage with LCT regarding the pending publication of the coastal erosion study by the government of Togo. However, as IFC no longer had an active investment in LCT, there is no reasonable expectation of further action by IFC to address the non-compliance findings. Therefore, CAO decided to close the case.