This project will comply with local and IFC’s environmental and social requirements upon implementation of the specific agreed measures. The information about how these potential impacts will be addressed by Agrotec is summarized in the paragraphs that follow and in the attached Environmental and Social Action Plan (ESAP).
Social and Environmental Assessment and Management System
-Social and Environmental Assessment: Agrotec has identified the main social and environmental impacts of its operations, and addresses the issues in full compliance with Paraguayan law. The company has presented to the local authorities the Environmental Control Plans (Plan de Control Ambiental) for all the facilities and activities and has obtained the respective licenses. The Environmental Control Plans identify the main risks and impacts of the distribution centers and the transportation of products, the plans also describe the proposed control measures. Agrotec renews the licenses as required by law. The environmental control plans have been disclosed locally through newspapers in compliance with local regulations.
Products distributed by Agrotec are approved by local authorities (e.g. SENAVE - Servicio Nacional de Calidad y Sanidad Vegetal y de Semillas). Agrotec has a department dedicated to process and obtain the local registration for all the products the company distributes. In order to acquire the authorizations, Agrotec submits toxicological studies by approved laboratories, physicochemical analysis and other required assessments. In addition, the company will ensure compliance with the Food and Agriculture Organization’s International Code of Conduct on the Distribution and Use of Pesticides or other good international industry practice.
-Social and Environmental Management Program: Agrotec has developed basic environmental and human resources manuals and policies that are communicated to the employees through memorandums. The company has developed manuals for safe transportation of materials, use of personal protective equipment, and fire prevention. However, those documents are not necessarily addressing specific environmental impacts and risks identified in the Environmental Control Plans. Agrotec will review the existing manuals to guarantee they target the specific hazards and impacts of the company.
-Organizational Capacity: The company has appointed a qualified Environmental Engineer to handle the environmental and occupational health elements of the company. There is a Human Resources Manager who coordinates the HR programs. Environmental and Social responsibilities are shared with the local managers of each distribution center, this model has proven to be effective for the company and there is evidence of empowerment and responsiveness towards environmental and social issues throughout the company.
-Training: Employees receive proper training based on the assigned tasks; the majority of the employees have received training on handling and transportation of hazardous materials, use of personal protection equipment, and use of extinguishers. Personnel with specific responsibilities in the transportation of materials are further trained and licensed by the local authorities to transport agrochemicals. The company demonstrated that there has been trainings on other topics such as Cardiopulmonary Resuscitation (CRP); first aid; and confined spaces.
-Monitoring and Reporting: The company has identified the need of monitoring programs in the Environmental Control Plans and does monitor some of the environmental impacts and risks of the operations. A comprehensive and coordinated monitoring system is not in place at the moment. Agrotec will develop a structured monitoring and reporting system, in order to assess and control its environmental impacts and occupational risks. Agrotec will define the relevant parameters to monitor, the periodicity of the reporting, and the management of records. During the implementation phase of the monitoring program the company will collect data on the relevant parameters and will apply the corrective measures as needed. The monitoring will include, but not be limited to (i) life and fire safety prevention measures (e.g. fire drills, extinguisher inspections); (ii) energy, fuel and water consumption; (iii) OHS events, including accidents and occupational disease; (iv) hazardous material safety, and (v) training.
Labor and working conditions
-Human Resource Policy and Management: Agrotec has a strong focus on the development of its employees. Customer service (technical assistance) is one of the core principles of the company; therefore, there is a strong effort to guarantee that the employees are qualified, retained and well compensated. Agrotec does not have currently a formal written HR policy; however, the company has generated a series of memorandums where decisions, benefits and rules are presented and shared with the employees. The company will define a formal Human Resource Policy that sets out its approach to managing employees. The policy will be consistent with the requirements of Performance Standard 2 (PS2) and contain information on the employees’ rights under local law. Such policy will be communicated to all the employees.
-Working Conditions, Terms of Employment and Protection of the Workforce: Agrotec has two types of contracts with its employees (i) services contracts and (ii) direct contracts. Compensation and benefits differ between the contracts: services contracts are used for the management team and most of the sale representatives. Direct contracts are usually for operational staff and entitle contribution to the Paraguayan Social Security in addition to Agrotec’s benefits. Employees under services contracts are responsible for their health plan, which is in compliance with local legislation.
Conditions of employment, including compensation are defined in the contracts with each employee. The minimum salary paid in Agrotec is above the legal minimum salary in Paraguay. Working conditions comply with local regulations, no employees under18 years are contracted as required by local Law. There is no evidence of child labor or forced labor in Agrotec’s clients or suppliers.
-Workers’ Organizations: The employees of Agrotec do not belong to workers’ organizations or unions, and there has not been such request among the employees. The management team of Agrotec confirmed that they would not prevent employees to organize or participate in workers’ organizations. There has never been labor complains against Agrotec. Due to the relative small size of the teams, communication is quite direct and employees can raise concerns directly to Human Resources or to the Management team.
-Retrenchment: The company is planning to increase its sales with the same workforce they currently have. There are no plans for opening new distribution centers. Therefore the workforce is expected to have a very small growth, mainly on the administrative side and retrenchment is not expected from this project.
-Non-Discrimination and Equal Opportunity: Agrotec applies the principles of Non-Discrimination and Equal Opportunity. There is no evidence of discrimination based on personal characteristics or gender. Fair treatment is observed in the company, including processes of hiring, promotion and termination of employment. Agrotec has an annual performance assessment with 360 degree evaluations, the system is considered fair and positive among the employees.
-Occupational Health and Safety: OHS elements in Agrotec have been oriented to the safe handling, storage and transportation of the products. The distribution centers are well designed with functional eye and body washers, containment kits, and natural and forced ventilation systems; in addition employees were observed using personal protective equipment. The seeds’ plant, although at the time of the visit was not operational, was observed with proper housekeeping and OHS controls. The company presented evidence of training on elements such as emergency response, confined spaces, and safe transportation. The company will reinforce its OHS procedures, in particular those related with work permits, transportation of materials, confined spaces and recordkeeping.
Pollution Prevention and Abatement
-Resource Conservation and Energy Efficiency: Agrotec operations do not require intense use of resources. The distribution centers use natural illumination and do not require water use other than for sanitary purposes. Therefore no industrial liquid effluents are generated by Agrotec. The use of energy in the seeds’ plant Pedro Juan Caballero is limited to the production season that is four to five months per year.
-Air Emissions: Agrotec emissions are associated with the distribution fleet and vehicles used for sales purposes. All the automobiles are less than four years old and periodic maintenance is provided. In the seeds’ plant Pedro Juan Caballero, emissions are limited to the use of agricultural equipment for the cultivation and harvest of the seeds. During the processing of the seeds and storage of grain, dryers are used; the fuel employed is GLP and natural wood. The company is buying wood from a plantation that is authorized by the local authorities. The annual consumption of wood is around 60,000 m3.
-Hazardous materials: Agrotec distributes among other products fertilizers and agrochemicals. The company stores and transports the materials according to local and international regulations. Measures observed during appraisal include the existence of MSDS, transportation documents, training, and full compliance with registration and permits required to import and distribute the products. In addition, Agrotec provide technical assistance to its clients on how to apply the products, including the use of PPE.
Distribution of agrochemicals represents approximately a forth of the business of Agrotec. Near 80% of agrochemicals sales of Agrotec correspond to products containing active ingredients that are unlikely to present acute hazard in normal use (Class U) or are slightly hazardous (Class III); based on the classification of active pesticide ingredients from the World Health Organization. The company only distributes products authorized by the local authorities (e.g. SENAVE) and follows the local requirements for its distribution. Currently, the company has in its portfolio only one agrochemical Class Ib, which will be phased out. Agrotec will eliminate stocks and distribution of any products containing WHO class Ia or Ib ingredients. In addition for those products in class II, Agrotec will review the technical and economic feasibility to replace them with less hazardous materials; considering alternatives such as cultural practices, biological, genetic, and as last resort chemical means. In case replacement is not feasible, Agrotec will provide proper training to its clients on topics such as: facilities to handle and store the products, equipment and conditions of application, and disposal of residuals.
Products classified in the red zone, under Paraguayan law, require the prescription by an accredited agronomist, without that prescription Agrotec does not sell the product. For an agronomist to prescribe the application of one of these products, the agronomist will assess the need of the product and ensure that it is critical for the crop.
Technical service is provided by qualified and authorized professionals, Agrotec has in place controls to ensure quality in the service and retention of its clients, which includes a proper guidance in the use and application of the products. In addition the clients usually have its own agronomists to advise him/her in the use of products. There was no evidence that Agrotec is overselling its products by suggesting additional application.
-Solid Waste Management: Waste generated from the operations is basically domestic waste. Direct use of agrochemicals products is limited to the farms for seed production and the demonstrative parcels, in which cases containers are tripled washed and punctured. Organic material from the seeds’ farms and the demonstrative parcels are reincorporated into the soil to increase soil fertility. Reuse of bags and cardboard is done by the company.
Regarding the distributed agrochemicals, Agrotec recommends and promotes the triple wash and puncture of containers to reduce the risk of using the containers for storage purposes. Agrotec will be developing and implementing proper training and guidance to its client regarding the proper management procedures for container disposal.
-Greenhouse Gas Emissions: Greenhouse emissions of the operations are associated with electricity consumption, the use of combustible for the dryers in the seeds’ plant, and the fuel for the distribution and sales fleet. The Greenhouse emissions of the current operations have been estimated to be less than 25,000 tons of CO2, 100% of which is derived from fuel use; electricity contribution is minimal, due to its hydroelectric source.
-Pesticide Use and Management: Direct application of pesticides is limited to the seeds’ production farms and demonstrative parcels. The company applies pesticides based on technical criteria and application is done following safety procedures such as use of Personal Protective Equipment and consideration of wind direction.
The company has in place several controls during the distribution of pesticides as described under the hazardous materials section of this document. Elements such as registration, labeling, packaging, information exchange, and storage were observed in accordance to international codes. The company will ensure compliance with the Food and Agriculture organization’s International Code of Conduct on the distribution and Use of Pesticides or other good international industry practice.
Community health, safety and security
-Hazardous Materials Safety: Agrotec exercise proper care to minimize the exposure of its employees, clients and communities to the products the company distribute. Storage of products is minimized by coordinating the purchase with the direct delivery to clients. The distribution centers have controls such as independent drainages with collection tanks, eye and body washers, and fire suppression equipment. Measures to protect the employees are described as well in the OHS section. Protection to clients is provided through the proper technical assistance, adequate labeling of the products, availability of MSDS, and additional written instruction for the application of controlled materials. By Paraguayan law only accredited agronomist are allowed to prescribe products classified in the red zone. Agrotec has implemented controls to guarantee proper transportation and response in case of spills, such procedures and training will be reinforced and targeted to the specific circumstances of Agrotec.
-Emergency Preparedness and Response: Agrotec has trained its employees and contracted drivers to prevent and react in case of accidental spills. All the distribution centers have emergency contact numbers available and elements to control spills such as sand and containment tanks. The company reported that fire drills are performed; some photographic evidence was presented. Agrotec will document emergency response plans and according to the Annual Monitoring Report required by IFC, Agrotec will have periodic fire drills and will include hazardous materials safety within the emergency drills.
-Security Personnel: Agrotec contracts security guards for the distribution centers and the seeds’ plant. The guards are contracted through a recognized security company and are armed. The security company has ethical manuals and trains the employees to guarantee adequate use of the arms and follow up of the procedures. There has not been complains or reports regarding abusive behavior or improper use of the arms.
Biodiversity Conservation and Sustainable Natural Resource Management
Agrotec cultivates directly near 1300 has for seeds, those farms are located in areas authorized for crop production. The areas used for seed production have the environmental licenses required by Paraguayan law and have the required protected buffer area around water streams. The project does not include expansion of the cultivated area and under no circumstance will the company clear natural forest. The majority of the direct clients of Agrotec are farmers with areas greater than 200 ha, which by Paraguayan law are required to have environmental licenses and the supervision of an accredited Agronomist. Therefore , it is unlikely that the clients of Agrotec would clear forest to set up crops.
Agrotec follows Paraguayan legislation regarding registration of all the new seeds, including those imported. All the products distributed by Agrotec have the SENAVE approval. The company will exercise care in case of introduction of alien species and will continue to follow the local legislation.
