The Company has presented extensive information on its current policies and practices that seek to address environmental and social risks and impacts to ensure that the proposed project currently complies with or will, upon implementation of specific additional agreed measures, comply with host country laws and regulations and the IFC Performance Standards on Social and Environment Sustainability and related EHS guidelines. Findings of the IFC’s review and conclusions are summarized in the paragraphs below. Additional actions to be undertaken by the Company are listed in the attached Environmental and Social Action Plan (ESAP). The Company has developed its own extensive action plan to raise its operations to international standards.
PS1: SOCIAL AND ENVIRONMENTAL ASSESSMENT AND MANAGEMENT SYSTEMS
Assessment. An Environmental Impact Assessment (EIA) Study is required for each plant under the host country’s EIA Regulations. Currently, the Company has completed the one for the NBB site. The EIA Studies for the Ivory Coast and Senegal sites are in the process of being commissioned. The Environmental and Social Management and Monitoring Plans of these ESIA Studies as well as the Terms and Conditions of the Environmental Licenses will be compiled into an overall Action Plan.
Management Program and Organization. The Company has some elements of a management program to address environmental and social impacts. However, the Company will have to strengthen its risk management tools by developing comprehensive OHS policies and procedures coupled with a comprehensive and result-based implementation program.
As the Company is rapidly expanding, it has progressively strengthened its management team. The Company recognizes the need to further strengthen and harmonize its corporate policies, procedures and integrated management system. The NBB (Mali) and Rufisque (Senegal) sites have an environmental, health, safety and quality supervisor that reports directly to the plant manager; Treicheville plant is in the process of hiring one. The Company is keen to operate at international standards and plans to seek relevant accredited certification, such as quality management system (ISO 9001) and Hazard Analysis Critical Control Point (HACCP).
Training. GRIMAS SA has a comprehensive training program in place with regards to machinery operation. However, there is presently not a systematic OHS training program in place to raise awareness on safety procedures, including emergency preparedness and response. The NBB plant in Bamako has a fleet of 30 trucks and should also raise safety awareness amongst the drivers, enforce speed limits and schedule relevant training, such as defensive driving. The Company has identified the need to improve OHS procedures in its existing Action Plan. As such, IFC will require the Company to prioritize the implementation of OHS training programs and regular monitoring of its effectiveness.
Monitoring and Reporting. The Company monitors accidents for the purpose of reporting to Human Resources Department and, ultimately, to the Social Security System (Caisse Nationale de Securité Sociale or Institut National de Prévoyance Sociale). However, this information is not used has a risk management tool. IFC will require that the Company includes in its reporting framework an accident reporting form to track accidents (including near misses), corrective actions, and an implementation schedule for all its operations, including fleet operation.
PS2: LABOUR AND WORKING CONDITIONS
Human Resources Policy and Management. IFC’s assessment considered each operation’s documentation with respect to fair, safe and healthy working conditions. GRIMAS SA employs a total of 205 direct employees, as of February 2010, of which 9% are female employees. The plants in each country have a Human Resources Policy and Procedures which fulfill the requirements of the national law, including working hours, overtime, holidays, leave, freedom of association, collective bargaining, and a grievance process. Each employee is provided with a written contract, including a job description. Employees are paid well above the minimum wage. Temporary workers are hired on an as-needed basis without a work contract which is common practice. The Company does not hire minors; each operational unit requires that potential employees present a national identification card or birth certificate. GRIMAS SA employees benefit from additional medical insurance which covers most of their expenses.
As outlined in the attached ESAP, IFC will require the Company to formulate a comprehensive Human Resources (HR) Policy and Procedures and hire a Group’s HR manager to harmonize its HR procedures and practices, to the extent possible. The Policy will outline the recruitment process, wages, promotions, internal grievance mechanism, and terms and conditions of employment of temporary workers in line with this Performance Standard. The revised HR Policy and procedures will be communicated to all permanent employees. Written documentation of the working relationship between GRIMAS SA and temporary workers will be completed and signed prior to employment.
The plants in each country support freedom of association. However, as per the legal labor requirements, there is a minimum number of employees required to form a union. The NBB site in Mali is the only operation large enough for a union to be formed; the other existing facilities have elected workers representatives. The workers union at the NBB site sells bags/containers from sugar, colorant, PET as well as the test bottles to local small scale juice makers. The funds are used for on lending to staff; grant for personal events (wedding, funeral, baptisms). The union can also serve as a guarantor to allow members to purchase motorbikes to get to work. The employees of GRIMAS SA can express their grievances through the workers’ union, the workers representatives or the plant manager.
GRIMAS SA does not have any envisioned retrenchment plan; on the contrary, approximately 117 people are expected to be hired within the next year.
Occupational Health and Safety. GRIMAS SA provides Personal Protective Equipment (PPE) such as boots, goggles, heat resistant gloves as appropriate based on hazard assessment at each working station. However, during the site visit at the NBB site, IFC observed that not all employees were wearing PPE owing to the climatic conditions. It was also found that safety awareness needs to be improved. Employees were observed to wear PPE in the Treicheville and Rufisque plants. Based on this assessment, GRIMAS SA will put together a comprehensive OHS awareness program and procedures in place in order to effectively enforce wear of PPE. In this same vein, safety awareness and procedures should be developed for the fleet drivers.
The plants are equipped with extinguishers but the number is inadequate for the size of the plants, and, in the case of the NBB site, testing and maintenance of fire extinguishers is not done on a regular basis. The other sites are new so they are equipped with new fire extinguishers. Furthermore, facilities lacked emergency exit signage and some safety signage, such as mandatory wear of PPE for certain activities. Fire drills should be undertaken at each facility, and fire wardens should be designated to raise fire safety awareness, ensure all escape routes are cleared of obstructions and signs are not obscured, and ensure that visual checks are carried out to identify any damaged equipments. GRIMAS SA will undertake a fire and life safety audit at the NBB site and implement audit recommendations within an agreed timeframe with IFC. Terms of Reference for the life and fire safety audit at the plants in Treicheville and Rufisque are available and commission of the audits will proceed shortly.
Storage methodology could be improved to optimize use of space, inventory management and reduce potential accidents; the plant managers did comment that they are revamping storage areas. For the NBB site, the plan is to separate the storage section from production area. The housekeeping at the NBB site should be improved even though the site is in expansion phase.
Noise levels appear to be at acceptable levels in most facilities. However, GRIMAS SA should undertake a noise assessment once its plants are operating at full capacity and determine (using IFC’s EHS guidelines) if ear plugs should be added to employees PPE. As previously indicated, GRIMAS SA records accidents. However, it doesn’t systematically analyze the cause of accidents. GRIMAS will, as part of its reporting framework, undertake root cause analysis of accidents at its facilities and put in place measures to prevent recurrence.
PS3: POLLUTION PREVENTION AND ABATEMENT
IFC’s assessment considered each operation’s management of raw material, source and use of water resources, liquid and solid waste and air emissions.
From a water supply standpoint, water resources are provided by wells at the NBB (Mali) and Bonoa (Ivory Coast) sites, once operational. The Company has obtained necessary authorization to extract water from boreholes. However, as a risk management measure, the Company have commissioned hydro geological study to estimate water reserves and determine which boreholes to utilize. The water at the Treicheville (Ivory Coast) and Rufisque (Senegal) sites are supplied from the municipal networks. The Company’s current total monthly water use is approximately 6,000 m³.
Electricity to all the facilities is provided from the national grid. To secure energy supply, each plant has a backup system which is supplied by diesel fuelled generators. Above–ground diesel tanks are provided with secondary containment structures (cement floors and walls) to ensure that spills or leaks do not migrate to soils, surface waters or underground waters. The Company has expressed an interest in undertaking an energy audit to look at way to optimize resources usage. IFC will work with GRIMAS to look at potential resource optimization opportunities.
Fugitive dust is an issue at the NBB site as well as at the Treicheville site. Water is sprayed on the floor to control it. The Company is considering isolating the equipments into a self contained air conditioned unit to avoid infiltration of dust.
Each facility stores small quantities of oil in 200 liters metal drums for use in the machinery. The maximum quantity stored at any time is 400 liters.
Wastewaters from Treichevilles’s and Rufisque operations (preform and cap manufacturing) are limited and are discharged into the municipal drainage system. The NBB site has recently constructed a waste water treatment plant (WTP) which has been operational in the last couple of months. More than 22.5 m³ is discharged daily to the Niger river. However, the client is looking at opportunities for water reuse. Treated effluent samples will be sent on a monthly basis to a third party laboratory for analysis of key parameters. The site also has a storm water drainage system. A WTP will also be constructed at the Bonoa site. Septic tanks are installed in the NBB and Bonoa sites. Once full, these will be discharged off-site by third party contractors at authorized site.
The facilities do not landfill or incinerate any waste. Solid waste include filters that are stored on the site; empty boxes, bag, small drums are either reused or sold to recyclers. GRIMAS is considering ways to recapture the plastic bottles it produced into the recycling chain, creating jobs, and reducing land filled plastic bottles. GRIMAS has already identified a potential purchaser of the recycled material in Dubai, and is now waiting to receive quotation on a PET crusher. The NBB site will be the test site. Once successful, this initiative could be rolled out to all other locations.
GHG emissions are mainly generated from the use of fuel for the generators and the fleet of trucks. The emissions from the operations are not significant.
PS4: COMMUNITY HEALTH SAFETY AND SECURITY
IFC’s assessment considered GRIMAS SA impacts on the health, safety, and security of and the surrounding community. GRIMAS SA’s operations currently meet the required noise level in terms of impact to community as the noise is adequate within the plant (outside the factory area). The various operations are located in industrial, commercial or agricultural area with some residential properties in the surroundings.
Prior to installing its WTP at NBB, GRIMAS SA used to dispose its waste water into the agricultural fields. This led to farmers complaining that GRIMAS was contaminating their wells. GRIMAS addressed the situation by building the WTP which discharges treated effluent into the Niger river. Furthermore, GRIMAS connected, at each side of the NBB site, two faucets to its own boreholes enabling farmers’ access to clean water.
GRIMAS mineral water is purified through injection of ozone, microfiltration and several other micron filters which are biodegradable. GRIMAS has received certificates of conformity from the “Agence Nationale pour la Sécurité Sanitaire et Alimentaire” (ANSSA) for their mineral water and carbonated drinks.
GRIMAS uses private security forces to guard its premises. The sites in Treicheville and Rufisque have armed security guards, although the one in Rufisque uses blank bullets. GRIMAS uses reputable companies, or army reserve to source security staff. GRIMAS is required to review its contract with these companies and to incorporate the requirements of the IFC Performance Standards. GRIMAS is committed to investigate any credible allegation of unlawful and/or abusive acts of security providers, take action or urge appropriate parties to take action.
PS5: LAND ACQUISITION AND INVOLUNTARY RESETTLEMENT
The project involves the land acquisition of the Bonoa site in Ivory Coast which already has existing infrastructure from a previous IFC investment. No economic or physical displacement was required as part of this land acquisition process. The land is a customary land and was acquired through the municipality with the blessing of the village leaders who were consulted in a culturally appropriate manner. GRIMAS SA has obtained a lease for 99 years on the property.
As part of its community support, GRIMAS financed the implementation of a drainage system following recent flooding in the area; and it is committed to hire from the local community where there is a person job fit or where occasionally unskilled laborers are required.
