Globino has presented plans to address environmental and social impacts to ensure that the proposed Project will, upon implementation of the specific agreed measures included in the Environmental and Social Action Plan (the “ESAP”) attached to this summary, comply with the environmental and social requirements, host country laws and regulations, and IFC’s Policy, Performance Standards and Guidelines. The information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow.
PS1: Social and Environmental Assessment and Management Systems
Social and Environmental Assessment.
Ukrainian legislation requires all greenfield projects, new developments, reconstruction or upgrading of current facilities to carry out an environmental impact assessment (EIA) study and evaluate potential negative impacts on environmental and social conditions. Depending on impact scale and intensity, a company has to develop and implement an Environmental and Social Management Plan (ESMP) which outline mitigation measures to avoid, mitigate or compensate identified adverse impacts. Relevant Ukrainian authorities review the project documentation, including EIA for compliance with national laws and regulations and issue construction and ultimately operating permits.
To ensure strict compliance and enforcement of the national requirements, the Company will arrange a review of all new developments and facilities’ upgrades (pig farms, slaughterhouse, and dairy) to identify which are subject for ESIA studies; conduct ESIAs required for its facilities and implement ESMPs to mitigate negative environmental and social impacts and risks identified in the ESIAs. Globino will report on the progress of implementation of corrective actions identified in the ESMPs to IFC.
Environmental, Health, Social and Food Safety Management System and Organizational Capacity.
The Company has been undertaking efforts for establishing food safety and quality management systems at selected operations. Currently, the meat processing plant is developing HACCP (Hazard Analysis and Critical Control Points) management system; the dairy/creamery plant has implemented and certified food and quality management systems, in accordance with ISO 22000 and ISO 9001 respectively through which both improve the quality and safety of its products.
The environmental, health and safety (EHS) management systems of local operations address the requirements and prescriptions of local supervisory authorities, including assignment of local staff responsible for coordination of operational EHS issues and permits availability for air emissions and waste disposal. As a result, Globino’s corporate EHS system has limited internal technical capacity since it focuses on addressing specific issues arising from local operations but is rather scarce in stipulating corporate improvement management programs and key EHS performance indicators to measure overall corporate EHS performance.
The Company management is committed to strengthening its corporate EHS management system in line with national, international and IFC’s standards. Actions agreed with IFC will include the following: a) appointment of a suitably qualified EHS manager at corporate level to manage the current and future EHS issues that might arise from the rapid grow of operations; b) relevant training for top management representatives to ensure in-house expertise and knowledge in developing, implementation and auditing of the corporate EHS management system consistent with the international ISO 14001 and OHSAS 18001 standards; c) step-by-step development and implementation of the corporate EHS management system appropriate to the nature and scale of the rapid growing of operations.
Training.
Training needs for professional skills of workers are identified by line managers depending on changes taken place at operations and equipment. Specific external and internal corporate training is developed and maintained for Globino corporate management to ensure up-to-date skills for effective management. Globino also establishes long-term agreements with high schools and institutes to train relevant specialists and welcomes students for internships; these actions serve as a tool to develop students and new employees into qualified professionals.
Reporting and monitoring. The external reporting of local operations is carried out in accordance with legal EHS requirements; internal EHS reporting is provided to the management of local operations. Globino will also to report to IFC in accordance within the context of the Annual Monitoring Report.
PS2: Labor and Working Conditions
Human Resources Policy, Non-Discrimination and Equal Opportunity.
Currently, Globino has approximately 2700 employees. About 95% of workers of dairy plant are members of the trade union; neither pig farms nor the meat processing plant have trade unions or professional associations. The Company intends to increase its workforce by 30% and create approximately 800 new local jobs in the context of its expansion of the meat processing plant, the dairy and pig farms.
To address the issue, the Company has introduced a human resource policy to develop a corporate culture based on loyalty, self-motivation and share the company’s values. Going forward, Globino will enhance corporate HR Policy by focusing it on the management commitments to employees’ rights for labor protection, including right /freedom for professional associations, trade unions; non-discrimination principles based on gender, race, age, ethnic and religious association, or nationality in employment; HR organizational structure and responsibilities; corporate approaches to workforce hiring; reduction of staff turnover; professional training; internal communications. The policy will be applicable to all businesses of Globino Group of companies, including its construction companies.
Working conditions and terms of employment.
Globino has collective bargaining agreements with workers’ representatives at local operations where trade unions function. Working conditions at Globino’s operations comply with national labour laws and IFC’s performance standard. Employment of children below the age of 16 years is prohibited; children below 18 years are not employed in dangerous, night or overtime work; forced labor is not employed. The company’s internal regulations supplement local labour laws and set up essential terms of employment including hours of work, wages, and leave for illness, vacation or holiday.
The Company hires personnel after preliminary medical examination addressing specific working conditions of pig breeding, meat processing and dairy operations, and then repeats the health exams regularly. The Company provides, and requires the use of proper hygienic conditions including shower cabins, working cloths and shoes, disinfection, and controls that these requirements are observed. Employees are given mandatory medical insurance that covers general medical services.
Globino maintains social projects and initiatives and offers to employees a social package, including onetime payment in specific circumstances; financial aid and social benefits. Also Globino has been constructing houses and apartments to rent for employees coming from other Ukrainian regions and neighbouring countries.
Grievance mechanism.
The Company actively encourages employees to openly discuss and resolve internal conflicts and managers to implement an “open-door policy”. Although the meat processing plant successfully implements gathering of workers’ concerns through mailboxes available at public premises; there are no corporate formal mechanism at this time. Globino will therefore create and implement a corporate grievance process which allows grievances to be presented without the risk of oppression consistent with IFC’s Performance Standard 2. The grievance procedure will be made available to all employees.
Occupational health and safety.
The Company carries out medical examination of employees at the time of entry on job and, after that, repeats the health examinations on a regular basis scheduled according to specific working conditions. Also, there is an on-site first aid medical point in the premises of the meat processing plant.
Pig farming / raising has limited occupational health and safety (OHS) risks; while employees at the slaughterhouse, the meat processing plant and the creamery unit are exposed to specific OHS risks associated with these operations. As mentioned above, the meat processing plant is developing food safety management system (HACCP and ISO 22000), including amendment of General Hygiene Practices (GHPs) that contributes to the OHS improvement. Also, the Company has mandatory fire safety, occupational health and safety training for its employees. In addition the Company arranges job specific training.
Reportedly, pig farming business does not have accidents during the last three years. Meat processing plant’s accident frequency ranges from 0.7 LDA/MMH (Lost-Day-Accident/Million-Man-Hours) in 2007 to 0.42 in 2009; dairy mill had the one incident in 2009; that is equivalent to 1.9 LDA/MMH. MMH is based on 2000 man-hours per year. Therefore, Globino demonstrates good performance.
PS3: Pollution Prevention and Abatement
Pollution prevention, resource conservation and energy efficiency.
Globino undertakes feasible efforts to have pollution prevention and energy efficiency systems in place. The Company has been implementing and purchasing advanced technologies and energy saving equipment at the new and upgraded pig farms, slaughterhouse and dairy farm. Also, Globino has been installing equipment for processing of manure to granulated fuel to be burnt at a pilot biofuel-fired boiler being constructed at the one of the new pig farm. However, there are a number of challenges to improve water and energy use; wastewater and waste management; greenhouse gas emissions that are discussed below.
Power and water supply.
Pig farming, meat and food processing generally required significant water and energy consuming operations. To optimize this, Globino is installing energy saving equipment of recognized international manufacturers at the new and upgraded facilities. Power for local operations is sourced from public grid. To provide local operations with heating, hot water and steam supply gas-fired boilers are installed. Water is supplied either from own water wells or from mains of the nearest settlements.
Air emissions.
Direct air emissions are not a key environmental issue upon operation of facilities under standard conditions. The company holds or is developing documentation for getting permits for air emissions issued by relevant authorities for local operations. Compliance of point source air emissions with national limits are monitored by authorities. Reportedly, the company did not have any complaints related to odor or noise from its facilities.
Animal welfare and biosecurity.
Globino’s practices to protect against the spread of diseases include control of new animals; accurate cleaning and disinfection measures after each cycle of animal breeding; observation and maintaining of proper hygienic conditions by personnel, including the use of shower cabins, working cloths and shoes, shore disinfection barriers; etc. Biosecurity measures for vehicles going to farms include special disinfection barriers at entry check points; limiting movement to special areas within farms; spraying of tires, etc.
Wastewater management.
Wastewater discharges generated by pig farming, slaughterhouse and dairy operations constitute the main environmental issue of this project. Pig farms typically generate significant quantities of animal waste with high concentrations of organics. This waste is usually collected in closed drainage systems and discharged to sedimentation ponds. After a period of settling (natural biological aeration), it is used as field fertilizer. At the visited pig farm being upgraded, an on-site wastewater treatment plant (WTP) has been installed for mechanical separation of solid faeces from liquid effluent, and then the solid residue is either temporary stockpiled on the special on-site area or used as organic fertilizer depending on seasonal conditions, while an odorless wastewater is discharged to the sludge ponds. The company intends to install such wastewater treatment facilities at all new pig farms. To ensure protection of surface and ground waters from potential contamination from sludge ponds and disposal areas Globino will monitor conditions of these facilities and undertake adequate measures to prevent leakage or run off.
The primary sources of contamination of the wastewater from the slaughterhouse are blood and faeces, with smaller quantities of animal fat, skin, bone and hair, and cleaning detergents. The slaughterhouse has an isolated drainage system. Processing effluents are delivered to the onsite WTP being upgraded to increase its capacity and improve water quality after treatment. It will include mechanical, biological and chemical treatment processes. The treated wastewater is thereafter discharged to receiving ponds.
Wastewater generated by the dairy mill is collected through a drainage system at the on-site WTP where grease and floatable solids are separated from main effluents; then lactoserum and wastewater treatment residuals are pumped to a specialized truck and transported to the disposal fields, according to the agreement for disposal. Effluents are delivered to the aeration tanks for biological treatment and then are discharged to a river. Relevant local authorities monitor the quality of effluents discharged by dairy mill. Currently, WTP is upgraded to improve quality of effluents after treatment and increase capacity in view of the planned growth of cheese and butter production.
The Company has agreed to undertake the following actions to ensure that water quality, after WTPs of the meat processing plant and the dairy mill, meet national and the World Bank/ IFC guidelines: a) provide adequate evidences confirming that WTPs being installed at the slaughterhouse and the dairy mill have sufficient capacity to treat effluents generated by facilities after expansion and will provide water quality acceptable for discharge to land and surface water; b) regular monitoring of liquid effluents quality after both WTPs; and update IFC with progress of this issue.
Waste management.
Globino has permits for disposal of wastes generated by the facilities and relevant agreements for waste disposal, including disposal of carcasses by specialized contractors. Going towards improvement of waste management appropriate for significant expansion of operations, the Company is committed to implement a comprehensive waste management system consistent with IFC’s EHS Guidelines. To achieve this, the Company will develop Waste Management Plans for pig farming, meat processing and dairy operations that, except of inventory of waste sources and types, will include proper methods for collection and temporary on-site storage of biological wastes prior to appropriate disposal; management responsibilities and proper staff training programs.
Hazardous Materials.
Implementation of asbestos containing materials (ACMs) is not prohibited locally, and ACM are used widely as asbestos-cement corrugated roofing. Globino also operates old transformers and capacitors that may contain polychlorinated biphenyls (PCBs) classified as a persistent organic pollutants. Going towards good practices related to minimization the health and environmental risks associated with ACMs and PCBs, the Company has agreed to undertake measures for avoiding their further use in new construction and renovation. Also Globino will inventory ACMs, PCBs being used for new facilities and develop a long-term plan for stepwise replacement of ACMs and PCBs.
The company uses pesticides, chemicals and materials certified and permitted by relevant local authorities. Handling, storage and use of PPE for pesticides comply with national regulations. The company is committed to develop a formal documented Pesticide Management Plan which will cover the areas of pesticide selection and handling, application and storage, staff training, safety requirements, and disposal, consistent IFC and WHO guidance.
Application, implementation and storage of chemicals, for instance, sodium nitrite and hydrochloric acid used in meat processing plant; acids and alkali used in dairy plant for equipment washing are maintained in accordance with national regulations and controlled by operational personnel and supervisory authorities.
Refrigerants used by the diary mill include ammonia; refrigeration equipment of the meat processing plant use R404 and R134. For personnel potentially affected by ammonia, use of personal protective equipment (PPE) is mandatory. The ammonia unit is equipped with safety features required to comply with national regulations for working with ammonia as well as emergency response actions and emergency contact numbers. The facility has an emergency response plan and a trained emergency response unit for ammonia emergencies. Going towards safety of employees and surrounding communities the Company has agreed to upgrade existing ammonia refrigeration unit of the dairy mill to comply with internationally recognized norms, such as those recommended by the International Institute of Ammonia Refrigeration or European Union or similar international standards.
Emergency Preparedness and Response.
Visited facilities are equipped with primary life and fire safety means appropriate for the most probable events and risks. They include fire extinguishers; fire hydrants; detached fire water tanks; fire alarm systems; a meat processing mill has a fire-fighting vehicle. Potentially dangerous facilities have emergency response plans as required by national regulations; its availability is checked by supervisory authorities.
Greenhouse Gas Emissions (GHG).
Estimated carbon dioxide emissions from fuel and electricity consumption, livestock wastewater discharges of facilities under Globino’s operation and control average about 105,000 tons annually. To reduce greenhouse gas (GHG) emissions, the Company will consider feasible actions and develop a program for reduction of GHG emissions by improving energy and water use and liquid effluent reduction and will report annually on the progress to IFC.
PS4: Community Health, Safety and Security
Operation of Globino’s facilities in normal conditions is not associated with risks to community health and safety. Environmental and occupational safety and health mitigation measures discussed above reduce potential risks to the community. The dairy and meat processing plant are located in industrial zones of the town of Globino. Pig farms are surrounded by small villages/settlements. Sanitary distances and buffer zones of Globino facilities comply with national laws and regulations. Emergency response plans are developed in accordance with national laws.
The state supervisory authorities regularly review and assess the health of the stock, food safety and employees’ training. Additionally, to control systematically risks to community health and safety from ingestion of drug (such as growth hormones) and pesticide residues, the Company will conduct studies to confirm that drug and pesticide residues in milk and pig tissue meet maximum residue limits (MRLs) for veterinary drugs and pesticide recommended by the World Health Organization (WHO) and Food and Agriculture Organization of the United Nations (FAO) and will undertake corrective actions, if needed to comply with MRLs.
Also, with the assistance of the veterinary service, Globino will develop a Veterinary Health Plan that will cover disease prevention strategies, parasite controls, antibiotics application, etc. based on the FAO/WHO recommendations and implement corrective actions, if needed, including staff training.
Security to Globino’s facilities is provided by its own guards licensed and trained according to the relevant national legal requirements. Staff does not wear fire arms.
PS5: Land Acquisition and Involuntary Resettlement
Globino’s land plots have been acquired through willing seller/willing buyer purchases or leased on long term contracts with property owners, private or municipal. Reportedly lands already acquired or being acquired /leased were idle or abandoned during long time. Neither involuntary resettlement nor economic displacement has been associated with any of Globino''s land acquisition/leasing.
The company is committed to acquire/ lease lands for future expansion undertaken with IFC’s support in compliance with national legislation and IFC’s PS5 and update IFC with progress in annual monitoring reports.
