26716 - Fuba PC

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Environmental & Social Review Summary

Project Number

26716

Company Name

FUBA PRINTED CIRCUIT TUNISIA SA

Date ESRS Disclosed

May 13, 2008

Country

Tunisia

Region

Africa

Last Updated Date

Sep 30, 2022

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Jun 25, 2008
Signed : Jun 26, 2008
Invested : Dec 8, 2008

Sector

Computer & Electronic Products(Computers & Peripherals, Communications Equip., Elec. Watches & Similar Elec. Products. Integrated Circuits & the application of Miniturization Technologies characterize this sector.)

Industry

Manufacturing

Department

Regional Industry - MAS Africa

Project Description

Fuba Printed Circuits Tunisie S.A. (Fuba or the company) is a manufacturer of dual and multi-layered printed circuit boards (PCBs), based at Bizerte, Tunisia, with an annual production capacity of some 350,000 m2 of PCBs. IFC is considering an equity investment in Fuba to facilitate streamlining of the company’s ownership structure, strengthen the balance sheet and facilitate further growth.

Overview of IFC's Scope of Review

IFC’s review comprised site inspection visits to Fuba’s manufacturing site at Bizerte, Tunisia, review of environmental certifications awarded to Fuba, and of other documents provided by Fuba, and meetings to discuss environmental and social matters with Fuba’s Chief Operating Officer, Human Resources Manager and Chief Financial Officer to discuss Fuba’s approach to employee relations, and meetings with Fuba’s Quality, Safety and Environment manager and his staff to discuss the company’s management of environmental and occupational health and safety matters.

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.

Site based assessment has shown that impacts related to other Performance Standards are not present. Fuba’s operations have limited impact on local communities. Fuba’s site was established on an industrial estate almost 20 years ago, and retains land available within the factory boundary for expansion. For this reason, the project under review does not present any issues related to land acquisition and resettlement, biodiversity conservation or cultural property, nor are there any indigenous peoples present in the project’s area of influence.

The key social and environmental issues in this industry are social and environmental management, management of labor relations and workplace conditions, management of emissions to air and water, and solid and hazardous material management. Potential adverse effects arising from these issues are limited in scope, largely reversible and may readily be mitigated through the use of available control technologies. This is therefore an environmental Category B project.

Environmental and Social Mitigation Measures

Details of Fuba’s existing and planned mitigation of potential social and environmental impacts which may arise from the project is given in the paragraphs that follow.

- Social and Environmental Assessment and Management

Social and Environmental Assessment:

The first stage of Fuba’s development was planned from 1991, and the company’s factory has continuously grown since that time. The initial development, all subsequent expansions were subject to environmental assessment in accordance with the requirements of the Tunisian National Environmental Protection Agency.

Social and Environmental Management:

As a company which supplies extensively to the automotive industry, Fuba has well developed quality assurance and environmental management systems. Fuba’s operations are currently certified compliant with the requirements of the quality assurance standard ISO 9001:2001, the environmental management standard ISO 14001:1996 and the automotive industry standard ISO/TS 16949:2002. These certifications will be maintained upon expiry. The company is currently developing a formal occupational health and safety management system and will seek OHSAS 18001 certification of this system in 2009.

Fuba has a strong environmental and safety management team. The head of the team, the Manager for Quality and Environmental reports directly to the company’s CEO who is a major shareholder. Reporting to him are separate managers in charge of environmental management, occupational health and safety management and quality assurance. The environmental manager controls waste management and operations of the waste water treatment plant.

This team has full command of all environmental aspects of the company’s operations and of occupational health and safety risks. In both cases, audits have been undertaken to define risks and how these should be managed, there is regular monitoring and comparison with internally-generated targets which are regularly tightened to promote continuous improvement. Failure to comply with these targets gives rise to preparation of an action plan to improve performance to the necessary level.

- Labor and Working Conditions

Fuba has developed human resource policies and procedures which are fully compliant with the Tunisian labor codes covering general working conditions and the electrical sector. These practices are essentially compliance with IFC Performance Standard 2 as is described below.

Human Resources Policy:

Fuba is currently preparing a Reglement Interne which is effectively the Human Resources policy for the company. This will be a booklet in both the Arabic and French languages which sets out the rights and responsibilities of both employee and employer. On completion, a copy will be distributed to each employee. At present a two-page “welcome page” summary of the HR policy is presented on appointment to each employee.

Working Relationship:

Each employee has an individual written contract of employment, either open-ended or fixed term according to post. This contract covers issues such as working hours, place of work, remuneration, annual leave, disciplinary rules and other matters. These contracts provide for a probationary period on commencement of employment, during which time the employee is expected to demonstrate suitability for the post.

Working Conditions and Terms of Employment:

These are defined in the individual contract. For manual staff, normal weekly working hours are 40, worked over five days in a shift pattern. Overtime is paid when worked by manual staff, but is rare in this continuously-operating factory expect for work during public holidays. Salary levels are set above rates paid in the nearest comparable Tunisian industry. Annual leave is provided according to the Tunisian norms, three weeks/year for manual staff and four weeks/year for management grades. Non-salary benefits include health insurance, a subsidized staff canteen, free transportation to work and an emergency lending program for particularly needy staff. Fuba also has a bonus system for staff based upon their meeting performance objectives.

Fuba undertakes an annual employee survey, which last year had a 64% participation rate. Results indicate considerable employee support for the company and its goals.

Workers’ Organizations:

Fuba has representation by two trades unions, one a national body and the other established within Fuba for employees of the electrical/electronics sector.

Workers’ views are represented and rights protected through an employee representative council. This is a body currently of six persons (1% of the workforce), and has representatives from company management and the employees and is a requirement of Tunisian labor law. By law, such workers’ groups must meet at least twice annually; Fuba’s group typically meets every two months, meetings are minuted and minutes circulated to workers on notice boards, and also sent to the national labor inspectorate. Council members are elected from among all employees, with elections being held every four years.

Non-Discrimination and Equal Opportunity:

Fuba has a policy of non-discrimination in employment and advancement, incompliance with Tunisian law, and recruits and promotes solely on merit. It is unusual in Tunisia for women to work a night shift, so to compensate, priority is given to recruitment of women for 2-shift posts and for less physically demanding positions.

Fuba has recently established detailed competency frameworks for every post within the company. This is used to define the most suitable candidates at the time of recruitment, and to manage performance and advancement in employment. A process of detailed performance evaluation by competencies has started; this is used in defining employee training needs and thereby to improve performance.

Retrenchment:

Fuba is expanding and expects to continue to do so. Retrenchment is not expected.

Grievance Mechanism:

Fuba has three employee grievances mechanisms. Firstly, the General Manager is known to maintain an open door policy and will receive any employee. Secondly, a complaints/suggestion box is placed in the factory, and submissions are reviewed regularly by the Human Resources department, and lastly the employee representative council is able to represent employee grievances should this be necessary.

Protecting the Workforce:

Fuba requires relatively highly skilled staff in its operations. Therefore its workforce has typically received technical training after leaving school not before the age of 15 before joining Fuba. Fuba’s youngest employee is 20 years old.

Fuba does not employ or benefit from forced or harmful child labor.

Occupational Health and Safety (OHS):

Fuba is in the process of developing its OHS management system as was described earlier.

Accidents and lost work days are regularly monitored. In 2007, Fuba employees suffered 4 accidents causing loss of three or more workdays, and 7 accidents causing loss of up to three workdays. This is not an excessive rate of accidents in a company of this size, but does give room for improvement. There is a well-established trend of reduced accident incidence however. Since 2003, the number of recorded accidents has fallen by 20% and the number of lost work days halved, but in the same time the number of employees has increased by almost 50%.

Most production machinery is fully enclosed, with local ventilation systems preventing worker exposure to chemicals, or to dust arising from machining operations. Workplace concentrations of VOCs have been measured and found to be very low. Noise levels have been monitored; a few places, particularly the board cutting and edging areas have high noise levels and in these areas employees use ear protectors. Machinery is very well guarded, and the company has a permit-to-work system covering potentially hazardous operations such as hot-work.

Prospective employees undergo health checks on taking up employment. Thereafter, annual medical checks are provided for all employees. Confidentiality of results is maintained between the physician and patient. However, there is no indication of any occupational illness or injury (such as hearing loss) in the workforce, one third of which has been with the company since it started operations.

Annual training in civil protection/fire safety and fire aid is provided to staff. Around 10% of staff are trained to provide first aid and emergency response, and the security guards are trained in emergency rescue. In the event of illness at work, the company has arrangements to provide medical care in the nearby town of Bizerte.

- Pollution Prevention and Abatement

Emissions to Air:

Fuba has emissions to air arising from process vents and three boilers used for process heating.

The boilers are fueled by LPG and are not sufficiently large to require regular emissions monitoring.

Potential process emissions to air are of volatile organic compounds (VOCs), and acid mists arising from etching, plating and cleaning operations, and emissions of particulate matter arising from machining or printed circuit boards.

Fuba has measured its VOC emissions arising from processes using VOCs and measurement shows that emissions are well below IFC guideline values and Tunisian regulatory limits. Similarly lead emissions arising from a leaded solder-coating operation have been measured and are below local regulatory limits.

Fuba has a number of vents from processes which use acids. Monitoring data for these vents is not available; however vents from five processes are equipped with water scrubbers to limit acid mist emissions, while another scrubber will be installed during 2008. Acid mists arising from the other process vents will be measured, and vents equipped with scrubbing systems if emissions are found to be significant.

Dust emissions arise from PCB cutting, edging, drilling and routing operations. Drilling and routing operations are undertaken in closed, hooded machinery with dedicated extraction systems. Extraction is also provided at the cutting and edging machines; all dust arising from these machining operations is extracted at source, to a bag house. The collected dust is bagged and disposed of in an approved sanitary landfill.

Emissions to Water:

Fuba’s processes include PCB coating, etching of developed film, electroplating and other coating operations, chemical removal of metals (principally copper and tin) from plates, and multiple washing operations. These give rise to liquid effluents which have high concentrations of metals.

Fuba practices in-process chemical recovery; etched copper is collected in the etching solution which when spent is returned to the supplier and credit given for the additional copper present.

Effluents remaining after this pre-treatment are treated in Fuba’s waste water treatment system. This has chemical coagulation of metal ions, sedimentation and aeration stages; during this treatment the majority of the metal concentration is removed: following treatment, effluents are discharged from site where they mix with effluents from the nearby village. An action plan has been developed by FUBA and submitted to ANPE for approval. When implemented FUBA will fully comply with the legal requirements.

Resource Efficiency:

Fuba’s washing processes make extensive use of counter current rinsing in order to conserve water.

An energy efficiency audit was undertaken during 2007 and Fuba is currently implementing recommendations arising from that audit.

Greenhouse gas emissions arising from Fuba’s energy use are in the order of 20,000 tonnes/year of CO2 equivalent. Fuba does not use PFCs.

Wastes:

Wastes arising from Fuba’s operations are used chemical containers, dust arising from PCB machining, trimmings of copper, tin and aluminum foil, spent etching solution and cake arising from pressing WWTP sludge.

Drums and bagged dust are stored on an impervious base at the rear of Fuba’s factory. Drums are sent for recycling. Dust is disposed of off site in a sanitary landfill. Metal foils are sold for recycling.

Spent etching solution is stored in pallet-sized plastic containers, also on an impervious base at the rear of the factory. It is returned from time to time to the solution supplier. The storage area is provided with spill containment systems (sand buckets) in the even of a spill. The containment area is not drained.

WWTP sludge is considered hazardous material because of the metal content. At present facilities to accept this waste do not exist in Tunisia. The waste (amounting to some 170 m3 from Fuba’s history) is stored on an impervious base at the rear of Fuba’s factory. Storm water arising from this area is captured and sent to the WWTP for treatment. Fuba does expect a hazardous material landfill to be constructed within Tunisia within two years, at which time this waste will be sent there for permanent disposal.

Hazardous Materials:

A number of the chemicals used by Fuba are hazardous. Fuba has a material safety data sheet (MSDS) for every material used. Precautions advised on the MSDS are incorporated into operating instructions which are provided in written format at the point of use of that chemical.

Chemicals in general are stored in the dedicated storage warehouse, and only brought to the point of use in small quantities which are stored on grids over containment wells. This discipline will be enforced in a few areas.

Fuba has a dedicated chemicals materials storage warehouse to which access is restricted to authorized personnel only. All chemicals in the warehouse have been assessed for mutual reactivity and are stored such that chemicals that react with each other should not come into contact. The whole warehouse has an impervious sloping floor and dedicated drain which direct spills to the WWTP. In this warehouse concentrated sulfuric acid is stored on high racks; storage will be reviewed such that chemicals which would be particularly hazardous if spilt will be stored at low level.

The store does have an emergency shower, but no emergency eye irrigation system which will be added. Possible need for these systems will be reviewed in areas where hazardous chemicals are used. A non-functioning eye irrigation system near the nickel-gold plating line will be replaced.

Fire Protection:

Fuba provided fire protection through a combination of hydrants and hose-reels and hand-held extinguishers. These systems are checked regularly by an authorized contractor. Fire pumps, which operate manually, are supported by a diesel engine-driven pump. Expert advice will be sought on converting these to start automatically in the event of loss of system pressure.

Stakeholder Engagement

Fuba’s factory is located on an industrial estate on the outskirts of the town of Bizerte. It is bounded on one side by the main road to Tunis, on another by another industrial enterprise and otherwise by fields. There is a village of some 1200 people approximately 500m from Fuba across fields, but this area is closer to the other factory than it is to Fuba.

Fuba has no formal community engagement process at present. However, around 500 local villagers work in Fuba and the neighboring factory, and through this employment are familiar with the company and its operations.

Fuba enjoys good relations with its neighbors, due to low impact and the employment created by Fuba. Should there be a grievance this would be expressed either directly to the company or through local government officials.

Disclosure of this ESRS constitutes Fuba’s first formal community engagement.

This ESRS and associated action plan will be made available in French languages and may be viewed at a noticeboard to be erected outside the main factory gate, at the address shown below.

For further information about the project please contact:

Mrs. Sabeh Boussarsar, Chief Financial Officer,
Fuba Printed Circuits Tunisie,
El Azib,
Délégation Menzil Djemil
Km 9 – 7026 Bizerte, Tunisia

Telephone: + 216 72 45 11 44
Fax: +216 72 45 13 33
E-mail: s.boussarsar@fuba.com.tn

Client Documentation

File Name	Actions
ESAP Fuba PC Tunisie.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.

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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:

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