The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with the host country laws and regulations and the World Bank/IFC (WBG) environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the Sponsor is summarized in the paragraphs that follow.
- Corporate environmental, social, and health and safety management systems:
CCS management is sensitive to environmental, social, occupational health and safety (EHS) aspects of their operations. The company has implemented the The Coca-Cola Quality System (TCCQS) and has a program in place to ensure that all operations - existing, new or acquired (as and when they are acquired) - are progressively made compliant with TCCQS. TCCQS is an integrated, three-tiered quality, environment, safety and loss prevention management system with a statement of quality policy (top tier), a management system standard and operating procedures (tier two) and performance standards (founding tier). In accordance with the TCCQS requirements, CCS requires an independent Initial Environmental Examination/Environmental Impact Assessment (EIA) for any new ‘greenfield’ plant it develops, as well as a comprehensive audit of any existing plants it acquires. Annual EHS audits are carried out by TCCC environment staff and the results of these incorporated into the facility Compliance Action Plan (CAP). The company has deployed dedicated EHS staff in each country, in addition to regional EHS co-ordinators. Under CCS’s employee performance management system, “People Plan”, each management staff is assigned a set of key performance indicators (KPIs), which amongst other indicators also include EHS indicators. Monthly/Quarterly review of KPIs is undertaken by CCS country and regional management. CCS will include the relevant World Bank Group safeguard policies and guidelines into the environmental management processes.
- National and local government permitting requirements:
CCS’s environment, occupational health, safety and labor policies and programs are dictated by:
- compliance with Coca-Cola’s global policies and standards, and
- the host country policies and regulatory requirements.
CCS has reviewed relevant World Bank group (WBG) policies and guidelines and has confirmed that its facilities will comply with these. CCS’s EHS and human resources managers regularly monitor changes in the host country regulatory environment in each of the countries in which CCS operates, to ensure that CCS’s own policies and program keep pace with host country requirements. The company’s EMS has a process in place to ensure that all facilities file returns to host country regulatory authorities as per relevant and applicable regulations.
- Land acquisition, compensation and physical and/or economic resettlement:
The company has reviewed OD 4.30 and the WBG Operational Policy note (OPN) 11.03 (Management of Cultural Property in Bank Financed Projects). In the event of any future land acquisition, the company will ensure full compliance with these policies. In case of all land acquisition (for capacity expansion at existing facilities or for Greenfield plants), to document compliance with World Bank Group (WBG) policy Operational Directive (OD) 4.30 (Involuntary Resettlement), the company will document and maintain a written report that describes in detail the acquisition process, consultations undertaken, number of people affected, and outcomes achieved.
- Community consultation and disclosure:
In addition to IFC’s environmental category B disclosure requirements, the company will, as part of its EMS, develop and implement a community consultation and disclosure program applicable to new plants to be constructed in non-industrial or non-commerial areas and where communities are residing in the immediate vicinity of the proposed plant site.
- Management of resources including energy, water, hazardous and other materials:
There is considerable variation in the reliability of power supplies at each of the bottling plants, depending on the quality of the electric utility entity in the particular host country. All of the facilities draw from the relevant national grid, but backup diesel generators are in place. Further, boilers and CO2 generators are significant energy consumers. In conformance with its EMS, all above-ground fuel storage areas are equipped with secondary containment structure. CCS is instituting a program to convert all underground tanks to above-ground structures over the next several years. At all new facilities, the company will construct only above-ground tanks for fuel storage and will provide adequate secondary containment. The company meets part of its water requirements from groundwater withdrawals at several of its plants and has undertaken initiatives to reduce specific water consumption. CCS’s EMS contains detailed programs for sorting, reusing and recycling solid wastes. Waste paper, cardboards, glass and metal containers are all collected, sorted and recycled where possible. The company has an active community based recycling program in several countries but this is not consistently applied across all facilities. CCS is committed to create consistency with regard to recycling activities in collaboration with TCCC. The company will store, handle, transport and use hazardous materials in accordance with IFC guidelines on management of hazardous materials.
- Management of emissions and discharges including hazardous and other wastes:
The principal point sources of air emissions at CCS’s facilities are the boilers, CO2 generators and DG sets. The company will monitor air emissions from these sources and ensure that these meet Host country and WBG norms. Where required, the company will implement appropriate engineering and/or management measures to meet WBG and host country norms. CCS will ensure that the refrigerant used in chillers/air conditioning system and fire extinguishers comply with Montreal Protocol requirements; and that ambient and workplace noise levels across all of its facilities meet WBG and host country norms. Where required, the company will implement engineering and/or management measures to prevent prolonged exposure of employees and/or local community to high levels of noise. TCCQS requires CCS to install effluent treatment plants with adequate capacity where no local municipal wastewater treatment facilities exist. The company will ensure that treated effluent meets host country and WBG guidelines. The company will ensure that management of hazardous waste is in accordance with host country regulations and IFC guidelines on management of hazardous wastes.
- Hygiene in the production and bottling area:
Hygiene and product quality is accorded a high priority in all of CCS’s operations. Under its ‘anchor bottler’ agreement with Coca-Cola, CCS is required to adhere to rigorous hygiene, sterilization and quality control/quality assurance (QC/QA) protocols. All the bottling plants are equipped with laboratories –to analyze product and wastewater quality. The Beverage Quality Manual, issued by The Coca-Cola Company, specifies the design criteria for the production facilities. These comprehensive specifications detail building and equipment design requirements as well as process requirements that must be complied with to ensure that the best possible hygienic practices are followed. Regular internal Good Manufacturing Practice Audits are conducted in each facility as well as external systems and compliance audits conducted by The Coca-Cola Company annually. The company will, within a timeframe to be agreed with IFC, develop an action plan to implement a HACCP based management system across all of its facilities.
- Fire and life safety and emergency response:
CCS employees have received training in fire prevention and response, as well as proper handling and management of risk associated with hazardous substances (e.g., acids) in use at these facilities. Mock drills are conducted regularly and the results of these are analyzed to ensure that gaps or weaknesses in emergency response procedures are identified and addressed.
- Occupational health and safety during construction and operation:
The company conducts occupational health and safety programs for employees and contract labor at the existing facilities and also at the new project sites. A key part of Employees are provided with personal protective clothing and equipment in accordance with Coca-Cola’s global H&S program. The company will ensure full use of all PPE made available to employees. Further, the company will institute a program to provide relevant occupational health and safety training to MDC operators. The company will post safety signage at appropriate locations in a culturally appropriate manner and display emergency response plans across all of its facilities.
- Corporate social responsibility(CSR) efforts, including HIV/AIDS awareness:
CCS views its corporate citizenship role as a fundamental part of its operations. The company’s strategic plan includes as a specific objective being a ‘model corporate citizen'' in all the communities in which it operates, thereby demonstrating that it takes its role in the community seriously. CCS has undertaken a comprehensive internal HIV/AIDS project for its staff. CCS has a Group CSR Policy that focuses its external community project efforts primarily on health projects, education projects and environmental projects depending on local needs.
- Timely reporting on environmental and social performance to IFC:
The company will, in a format to be agreed with IFC, submit Annual Environmental and Social Monitoring Reports (AMRs) timely within 90 days of the end of its financial year. The AMR will be derived from the outcome of CCS’s annual audit program and will include:
compilation of the categories of non conformances identified in the audit in the context of host country and WBG requirements;
- summary of the remedial action proposed to be taken to address/rectify the non conformances; and
- status of implementation and outcomes of the remedial action that had been proposed in the preceding AMR (s).
