25896 - Groupe AMI

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Environmental & Social Review Summary

Project Number

25896

Company Name

GRANDS MOULINS DU MALI SA

Date ESRS Disclosed

May 15, 2008

Country

Mali

Region

Africa

Last Updated Date

Jun 11, 2022

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Jun 25, 2008
Signed : Oct 31, 2008
Invested : Dec 8, 2009

Sector

Grain Processing (Milling, Starch, Flour, Malt)

Industry

Agribusiness and Forestry

Department

Regional Industry - MAS Africa

Project Description

Grands Moulins du Mali (GMM or the Borrower), a wheat flour and rice milling company, and Société des Eaux Minérales du Mali (EMM), a mineral water bottling company, are part of Groupe Achcar Mali Industries (AMI or the Group). The Group also comprises Grande Confiserie du Mali, in confectionary and pasta production, Groupe Achcar Mali Transit, in customs clearing and logistics, and Compagnie Malienne pour le Développement du Blé (CMDB), a subsidiary of GMM involved in wheat growing.

GMM and EMM have initiated an investment program over 2007-09 to:

- diversify into animal feed production with a capacity of 75,000 tons/year,
- increase rice milling capacity to 18,000 tons/year,
- start a bakery training center to secure the loyalty of its flour clients,
- build two silos in the port of Dakar, Senegal to strengthen its supply chain,
- double EMM’s mineral water production capacity, and
- raise additional working capital.

Total project cost is estimated at €17.5 million. The Borrower has requested IFC to provide an A Loan of up to €8 million to GMM and EMM.

Overview of IFC's Scope of Review

IFC’s social and environmental review of this project consisted of site inspection by an environmental specialist to the flour grinding mill and interviews with the management at that site. The client has additionally provided responses to written question submitted by the IFC.

E & S Project Categorization and Applicable Standard

While all Performance Standards (PS) are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

- PS1: Social and Environmental Assessment and Management Systems,
- PS2: Labor and Working Conditions,
- PS3: Pollution Prevention and Abatement, and
- PS4: Community Health, Safety and Security.

The project does not involve the acquisition of land. CMDB has leased 500 ha of land from the Office du Niger for growing wheat, but this land is not part of the project and did not involve involuntary resettlement. The animal feed plant is located on the existing wheat milling site and the silos will be in the industrial zone associated with the Port of Dakar. PS5 does not, therefore, apply. There are no natural habitats, indigenous peoples (as defined for the purposes of PS7), or physical cultural properties within the project sites, all of which are existing industrial or plant sites. Thus, PS 6, PS7, and PS8 do not apply.

The following potential environment, health and safety and social aspect of the project were analyzed:

- social, and health and safety management systems;
- labor and working conditions, particularly occupational health and safety associated with workplace dust; and
- transportation safety.

GMM operates low impact flour and rice mills using predominantly imported wheat and rice in modern mills that incorporate collected dust into product. Flour milling operations are low impact operations with few if any environmental issues; similarly distribution of bulk goods is a low impact operation provided that vehicle operations and maintenance are conducted in compliance with good international industry practice. 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 environmental and social requirements. Thus, this is a category B project under IFC’s Environment and Social Review Procedure.

Environmental and Social Mitigation Measures

The following potential environment, health and safety and social aspect of the project were analyzed:

- environmental, health and safety assessment and management;
- food safety and quality control; labor practices;
- worker health and safety, particularly related to workplace dust;
- air emissions from boilers;
- refrigerants;
- water demand and waste water treatment;
- solid waste management;
- life and fire safety associated with milling dust; and
- transport safety for raw materials between Conakry/Dakar and Bamako, and for finished products into new markets

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 environmental and social requirements:

- the host country laws and regulations;
- the IFC social and environmental Performance Standards; and
- IFC’s environmental, health and safety (EHS) guidelines.

The information about how these potential impacts will be addressed in the Project is summarized in the paragraphs that follow. Further information is provided in the attached documentation.

- PS1: Social and Environmental Assessment and Management Systems

Activities that may have a direct or indirect impact on the environment must prepare an environmental impact assessment (EIA) or obtain approval from the Ministry of Environment and Sanitation to proceed with construction and operations in the absence of an EIA. GMM and EMM will provide documentation demonstrating that environmental assessment requirements have been met or waived as required by government authorities in accordance with the attached Environmental and Social Action Plan (ESAP).

GMM is in the process of obtaining a certified, quality management certification (ISO 9001) for the flour milling operations. Following completion of this certification, the Company will also seek certification for the food safety standard, ISO 22000. This latter system provides assurance that food products placed into commerce are safe and, in the event of a report of adulterated food products in the market place the company can identify affected lot numbers and remove the products quickly. The system also facilitates the company’s ability to determine where the problem occurred.

GMM and EMM will conduct a food safety review of equipment and appurtenances required for expansions and obtain management system certification for these expanded manufacturing activities in accordance with the attached ESAP. GMM and EMM will further develop community engagement programs to ensure that host communities are aware of the nature of operations, associated risks and afforded the opportunity to express concerns about each operation.

- PS2: Labor and Working Conditions

Groupe AMI has a Human Resources Department and an HR policy. The HR policy incorporates a grievance mechanism for expressing concerns about employment and working conditions. There is a collective labor agreement with a local work organization and both employees and Groupe AMI are guided by this agreement. The HR manager is responsible for all compliance with Malian laws and regulations affecting food production labor and occupational health and safety.

Groupe AMI provides fire prevention and response training to all employees at induction, as well as refresher courses annually. Fire drills are carried out twice a year. GMM mills are designated non smoking facilities and operations areas are clearly posted with no smoking signs.

Groupe AMI will formalize corporate occupational health and safety training activities for milling, transport, warehousing and other food manufacturing activities to include expanded training programs; job hazard analyses; orientation to chemical compounds and employee training using material safety data sheets (MSDS) or International Chemical Safety Cards (ICSCs); for chemicals employed in pest control; and collection of accident and near miss statistics and analysis of these statistics to modify work places and working conditions to reduce the number of lost time accidents observed.

- P3: Pollution Prevention and Abatement

Dust control and good housekeeping in the flour mill are important to preventing explosions and protecting worker health. The mill has sufficient air extractors to address these risks. There is no process effluent in flour milling operations as all water used in operations is consumed in the flour mills mill for wheat conditioning. Potable water for operations and sanitary purposes is provided by the municipality. Wastewater from employee changing rooms, bathrooms, laboratories and other operations is piped to a septic tank and connected to a subsurface disposal system.

Potable water is also used in mineral water production and bottling as well as in equipment cleaning and disinfection. Adequate provisions will be made to ensure the potability of water used in food manufacturing and cleaning. Similarly, wastewater disposal will be planned and implemented in accordance with the Ministry of Environment and Sanitation requirements and the attached ESAP. No hazardous materials are utilized in milling or food storage and distribution operations with the possible exception of compounds that the subcontractor uses for pest management. Small scale fueling operations for company transport vehicles, which will be expanded, are segregated from milling and storage operations. Pest control materials are consistent with those allowed for food preparation operations.

Groupe AMI’s transport vehicle maintenance facility produces waste hydrocarbons and scrap that are collected and sold for recycling. Diesel fuel for vehicles is stored in above ground containers with no secondary containment. Waste hydrocarbons in storm water from the property are collected in an oil water separator and removed prior to discharge to the public sewerage.

GMM and EMM’s greenhouse gas emissions resulting from consumption of electric power do not exceed IFC’s threshold of 100,000 tons/year of CO2 equivalents.

Pest management is provided by a third party service company licensed by local government. In general the service is not utilized unless an infestation is noticed. Groupe AMI will obtain technical information on the chemicals in use and include information about these compounds and associated hazards in employee occupational health and safety training programs. Bird intrusion is a common problem and control measures include trapping and releasing.

- PS4: Community Health, Safety and Security:

Groupe AMI contracts external security services and will prepare a contract specification for these services to include guidance for the contractor firmly based upon the principles of proportionality and by good international industry practice in hiring, rules of conduct, training, equipping and monitoring these services. Groupe AMI will also make appropriate enquiries into past performance of the security contractor and make an effort to unearth any evidence of past abuses.

Groupe AMI will develop and implement a driver and transport vehicle safety program consistent with the requirements of the IFC General EHS guideline. In addition, Groupe AMI will plan and implement a Vehicle Operator Safety Training Program affecting all operators of moving equipment on public roads and other infrastructure.

Stakeholder Engagement

The technical content of the ESRS and the ESAP will be translated into local languages with no reference to IFC and utilized to convey assessment and remedial measures to the local community as part of stakeholder engagement programs. Translation of the ESRS and ESAP and publication in local news organs and placement in town council offices in the districts where GMM and EMM operate will be carried out as part of community engagement. In meetings held in affected communities, Groupe AMI will explain its expansion program to local community representatives and describe potential impacts and how these will be mitigated through project design. And, local leaders and individuals will be given the opportunity to ask questions and to voice concerns about company operations and the elements of the expansion project.

Further information about GMM and EMM’s projects, the companies and other considerations may be obtained from:

Mr. Christian Viale
Directeur Financier
Telephone : +223 221 3664
Fax : +223 221 5874

Client Documentation

File Name	Actions
Groupe AMI EAP final.pdf

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

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