The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific measures agreed, comply with applicable host country laws and regulations and World Bank/IFC requirements. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow.
1. Environmental and social management - CNO has applied an integrated approach to address the environmental and health and safety impacts of its projects since 1999. This integrated approach is based on the ISO 14.000 and BS 8.800 international standards. The Integrated Program Manual (“PI Manual”) is the main corporate document of CNO’ system for managing environmental and health and safety issues. Presently, large contracts are already in compliance with the PI Manual’s guidelines and procedures. CNO is committed to extend the application of the PI Manual to medium and small contacts and to improve environmental and health and safety control measures and monitoring systems for these contracts. CNO will submit to IFC satisfactory environmental management plans and implementation procedures for medium and small projects. These plans and procedures will be submitted to IFC prior the first disbursement of the IFC loan.
2. Environmental Certification - CNO holds ISO 14.000 formal certificates of compliance issued by Bureau Veritas Quality International – BVQI in the areas of petrochemical plants and thermal electric power plants. CNO is the only Brazilian engineering construction company to hold such certificates. CNO also holds formal certificates of compliance to the ISO 9000 Quality Standard for a number of engineering projects.
3. Environmental Management System - CNO’s management system is decentralized; much of the decision making power is delegated to the contract level. Consequently, the corporate structure dedicated to environmental, health and safety and social issues delegates the implementation of these aspects to the manager in charge at each of the work sites. Capacity is built at the construction project level and resources are assigned accordingly. The system’s general policies, guidelines and procedures are defined at the corporate level, while the leader of the integrated management system at the construction contract level is responsible for their implementation. .
4. Specific Safeguard Policies - The goals of CNO’s environmental and social management system are similar to those of IFC’s environmental and social policies. However, CNO’s system does not specifically address certain IFC requirements, particularly those contained in IFC’s safeguard policies on resettlement, cultural property and indigenous peoples. CNO is committed to i) develop policies and procedures to address these requirements; ii) integrate these policies and procedures into CNO’s environmental and social management system; iii) designate, train and hire (if necessary) the personnel needed to ensure compliance with the new policies and procedures; and (iv) develop specific guidelines that CNO sub-contractors must follow to ensure they comply with CNO environmental management systems. These plans and procedures will be also submitted to IFC prior the first disbursement of the IFC loan.
5. Assessment and screening of construction projects - As part of its effort to ensure that CNO’s projects comply with IFC’s safeguard policies, CNO will develop formal procedures to review and screen construction projects. The review of projects under the new procedures will lead to the following outcomes: i) the acceptance of contracts in which the Company’s environmental and social standards (including those of IFC’s safeguard policies) can be met; and ii) the re-evaluation, renegotiation, or decision on rejection of contracts that cannot be implemented according to CNO’s requirements. IFC will assist CNO in the development of assessment and screening procedures as necessary.
6. Environmental performance of existing contracts - CNO implements environmental programs at the site in practically all contracts. Their scope varies according to the project’s type and size, number of employees, site location and requirements of the client or regulatory agencies. Environmental programs at the site typically focus on controls and treatment of wastes, reclamation of degraded areas, information and education of employees, minimization of risks, and reduction of adverse impacts. Some of the standard procedures for addressing environmental prevention and control measures related to construction activities include:
- sanitary wastes –stabilization ponds and anaerobic biologic systems;
- oily wastes –sedimentation and oil-water separator chambers according to API standards;
- cement and concrete effluents –sedimentation chambers;
- solid waste –landfill to handle domestic and inert wastes;
- medical wastes –gas fired incinerator to destroy medical wastes;
- burrow and fill areas including quarries – design a project for the use and recovery of degraded areas; and
- fuel tanks and used oil –design of facilities to avoid spill and contamination of soil and waters by fuel and other oily products.
7. Health and safety programs - CNO has ambitious health and safety programs designed to ensure that workplace accidents/incidents are reduced to the minimum. CNO’s rigorous training program is provided to all its employees, including managers. With the assistance of CNO full-time physicians, CNO has developed sound ergonomic practices at the worksites reducing significantly the number of work related accidents and thereby protecting the overall health of their employees. In addition, CNO requires its subcontractors to implement environmental and health and safety training programs. In some instances, CNO provides the training and the subcontractor covers the cost.
8. Programs for employees and their families - Programs for employees and their families are in place in most contracts, especially those in the large and medium range. These programs focus on improving the health conditions of the employees and their families through prevention programs and information campaigns. Large contracts normally designate regular staff to work in these programs, while temporary assistants have this responsibility in medium and small contracts.
9. Community development activities - CNO views community-related activities as an important component of its construction contracts. The Company’s “Practical Guide to Institutional Relations” is used to orient field teams on appropriate interaction with communities near projects and on preparing community related programs. CNO’s track record of community projects reflects a corporate philosophy that contributing to community development is both good business and good ethics.
10. CNO supports two types of community projects: those that are contemporaneous with the project and long-term projects that are not linked to a particular construction contract. Both types of projects must conform to three principles: i) no community project can be solely based on CNO’s donations or support; ii) CNO should not replace government functions or programs; and iii) CNO should mobilize and activate local resources and emphasize self-sustainable programs. While the specifics of the social programs vary, their shared objective is to leave a positive imprint of CNO presence that goes beyond the construction site.
11. As part of its community outreach efforts, CNO contributes to the Odebrecht Foundation through Odebrecht parent company. This Foundation promotes the education, health and general well being of adolescents.
12. CNO collaborates with environmental and socially oriented NGOs, such as IDES – “Instituto para o Desenvolvimento Sustentável do Litoral Norte da Bahia” and Biodiversitas, a well-known Brazilian NGO dedicated to conservation and the preservation of biodiversity. CNO is supporting the preparation of the “red book” to be published in 2002 containing the updated list of the Brazilian fauna threatened by extinction. This work is being conducted by Biodiversitas, as part of an agreement with the Ministry of the Environment and IBAMA, the Brazilian Environmental Agency.
13. CNO’s role in projects involving resettlement - CNO has participated in a number of projects involving resettlement, but has not been responsible for planning and implementing resettlement activities. CNO’s role has been confined to construction activities, while other parties (public or private) have been responsible for the acquisition of occupied areas needed by the project and the relocation of affected families and businesses. However, CNO has been able to play an important role by facilitating resettlement activities and mediating the interests of the project owner/investor and other parties, such as government agencies, NGOs and organized squatter movements.
14. Protection of cultural property - In all projects that have the potential to affect cultural property, CNO i) reviews all relevant information and requirements contained in the environmental permits and impact reports; ii) makes sure that the site area has been cleared by officially approved archaeological experts; iii) follows relevant impact evaluation procedures described in the Company’s booklet on the environment; iv) maintains records of relevant construction activities, such as site clearing, excavation and earth work, and ensures that these activities are carried out according to approved plans and procedures; and v) reports any findings that may indicate presence of cultural property to the project owner/investor and the relevant authorities. CNO made direct contributions to the preservation of the “Chan Chan” remains in Peru and supported the archaeological studies for the Sauípe Project in Brazil.
15. Labor issues - CNO projects rely on a mix of staff and temporary employment, often of workers from both local areas and other regions. While this has a short-term positive effect, there is the inevitable reduction of the work force that occurs at the end of all CNO’s projects. In order to mitigate the impacts of this unavoidable feature of the construction industry, the Company i) makes it a priority to hire local and regional labor; ii) establishes training programs at construction sites for local people who do not have the skills required by the project; iii) implements communication programs designed to provide local communities with clear information on labor force requirements, timing of the project and training opportunities; iv) provides information on labor requirements to private and public agencies that are responsible for identifying prospective candidates; and v) provides assistance to workers who must return to their regions after project completion.
16. Public hearings and grievance processes - CNO’s teams participate in public hearings related to projects of interest of the Company. The objective of CNO’s participation is normally to support the project’s owner/investor in presenting and discussing specific aspects of a construction project before public audiences. In the case of a some large projects, CNO has been directly involved in the preparation and holding of public hearings.
17. The ways in which CNO handles grievances depend on the size and type of contract. Larger contracts have a formal organization to address complaints or concerns of employees. A social assistant is commonly the head of the group that deals with employee relationships at the construction site. Most medium size contracts have a group in charge of grievance processes and a social assistant is also available to deal with employee concerns. Smaller size contracts generally do not have a formal organization to handle grievance processes.
18. Complaints and observations from external groups or members of the local community are handled either at each contract or at the corporate level. In any case, the corporate organization in charge of environmental and health and safety issues and/or the Director of Institutional Relations will support the contract in handling such matters.
19. Construction projects that interact directly with local communities usually have a community information center. The guidelines for preparation and handling community affairs are in the booklet entitled “Guia Prático de Relações Institucionais”.
