PS1-SOCIAL AND ENVIROMENTAL ASSESSMENT AND MANAGEMENT SYSTEMS
The Company has a well structured integrated management system for the Malting Division and all malting plants are certified under the ISO 9001; OHSAS 18001 and ISO 14000 standards. The Company also has a Corporate Sustainability Policy that covers most aspects of food quality and food safety, environmental protection, Occupational Health and Safety (OHS) and other labor aspects. The Company will implement an E&S management system in the Agriculture Division benefitting from the internal expertise from the Malting Division.
- Environmental and Social Assessment: The Company’s management system is designed mainly to achieve compliance with local regulations and the group has conducted several types of environmental assessments to meet local requirements and some specific needs of the plants. In some countries (Russia, Ukraine and Romania) the Company conducted a full Environmental Impact Assessment as well as additional studies for expansions and for the deployment of new equipments. The Company conducted a gap analysis and follow up of the compliance with local regulations. The Company also conducts a worker’s exposure assessment to hazardous agents every five years and follows up the compliance with local OHS requirements.
- Management Program: Soufflet Malting Division has formal written Environmental, Health and Safety Procedures, as well as modernization plans for the existing plants. The Company acquired old plants that were privatized after the collapse of the Soviet regime and has been taking several programs to modernize and make the plants more efficient, less demanding in natural resources (mainly water and energy) and more safe. They replaced old equipments such as conveyor belts and grain elevators and installed new dust suppression systems in the silos. The Company also has plans to modernize some of the wastewater treatment facilities and is also replacing old boilers with new ones. The Agriculture Division will take the same approach to modernize its silos and make them more efficient and safe.
- Organization: Soufflet Malting Division has one person exclusively assigned for Environmental and quality assurance as well as one person assigned for OHS at each plant. The Malting Division also has an Environmental manager and the Group Soufflet has one OHS manager and Environmental manager at a corporate level. Soufflet Agriculture Division will structure its EHS (Environmental, Health and Safety) organization capacity that will be responsible to manage E&S aspects of its operations.
- Training, Soufflet Group has a training program that encompasses an induction on EHS for new workers and an EHS training retreat week at the plants and discussing with workers main Environmental Health and Safety issues. Nonetheless, the Company will implement a job coaching program in ECA countries, in which local EHS teams will be supervised by Senior specialists from Headquarters to disseminate the existing expertise across the Company. Soufflet will also implement an EHS training briefing for all contractors that will be working inside Soufflet plants and covering Soufflet EHS policies and procedures.
- Monitoring: Soufflet Malting Division has a very well established monitoring system that monitors critical aspects of their operations such as water and energy consumption, wastes production, treatment and disposal, accidents, compliance with local requirements and corrective actions completion. Soufflet Agriculture will develop the same approach at its operations in ECA countries. In addition, Soufflet will implement a job observation program, based on frequent inspections of site operations to strengthen enforcement of its EHS policies and procedures. Soufflet does monitor the workers’ exposure to hazardous agents every five years in ECA countries and will narrow the frequency of the monitoring of workers’ exposure to noise and hazardous respirable agents to an bi-annual basis, when the workplace levels exceed the Thresholds Level Values as defined in IFC EHS Guidelines.
- Reporting: Soufflet Malting Division has a good internal reporting of its EHS performance and the Agriculture Division will develop the same approach. In addition, Soufflet annually reports to the public its Sustainability performance through its Sustainable Development Report. Report download:
http://www.soufflet.com/index.php?option=com_content&view=article&id=100&Itemid=83PS2-LABOR AND WORKING CONDITIONS
- Human Resource Policy and Management, Soufflet has a human resources (HR) policy that cover some aspects such as non discrimination, underage workers, working health and safety conditions, transparency, governance and compliance with local legal labor requirements. Soufflet follows local countries labor regulations, which are consistent with ILO standards (ECA countries have strict labor regulations inherited from the communist regime). The terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick live, maternity, vacation or holiday are established by local labor regulations. Although workers are in general familiar with the national terms of employment, the Company also informs them during the recruiting phase about the specific terms of the job position and additional benefits.
- Worker’s Organizations, Soufflet informed that they hire unionized workers and unions representatives. Based on the evidence gathered during the IFC due diligence, Soufflet does not restrict the freedom of workers to associate. Soufflet also encourage workers to establish local site committees to discuss labor aspects of their operations and promote negotiations where unions do not exist.
- Non-Discrimination and Equal Opportunity, Soufflet’s Code of Conduct makes explicit reference to non-discrimination on the basis of sex, race, national origin, religion, age or other bias. No evidences of discrimination were identified during the appraisal.
- Retrenchment, The Company informed that they have no plans to reduce the size of the workforce in their sites in ECA countries. They also informed that when they had to do it in the past, after they had acquired the plants, they had to follow the strict local labor regulations and workers had to be compensated on a progressive basis related to the number of years they had been working to the Company. Additional benefits were negotiated with workers and they were also encouraged to form companies to provide services to Soufflet group.
- Protecting the Work Force, In its existing facilities, the Company employs approximately 450 permanent staff, 35% of which are women. The Company respects the employee’s collective bargaining agreements and the Company minimum wages are consistent with local national standards. The minimum workers age is 18 years. The Company pays the social security and provides a personal insurance. The Company also provides transport to workers and food during the working periods. The costs of the food are shared with workers and the Company pays for 50%. The administrative workers have a weekly working period of 40 hours (eight hours per day) and for operational workers, work and rest periods are organized this way: twelve hours of work and eight hours of rest; than twelve hours of work and forty eight hours of rest.
- Occupational Health and Safety: The Malting Division has conducted an assessment of the OHS risks at its plants and undertaken improvements to promote safer working place. They have replaced old silos’ machinery, electrical equipments and connections, and dust suppression systems to reduce the risk of explosions due to dust concentration in the atmosphere. They have fall protection guard rails, the moving parts and conveyor belts are enclosed and they monitor workers exposure to hazardous agents such as noise and dust. They have formal procedures to assess and manage the OHS risks, procedure for contractors working inside the Company, procedure to work at confined spaces, procedure to work with electrical components; procedure to permit-required works and procedure for accident investigation. The Company will identify with warning signs all confined spaces and improve the risk communication in the plants and consistent with IFC EHS guidelines. Soufflet Agriculture Division has recently acquired four silos in ECA countries and will conduct a risk assessment and a corrective action plan for each one. The Agriculture Division is structuring its OHS teams and programs. They have improved its seeds treatment plants with new equipments to reduce the workers exposure to pesticides and are defining the proper use of PPEs. The Agriculture Division has some pesticides storage areas and they are deploying the necessary improvements to be in compliance with local requirements and EU standards, over time. They are also starting to work on the prevention plans and formal procedures for working in confined spaces, procedure to work with electrical components; procedure to permit-required works and procedure for accident investigation. The Company will develop a job observation program with routinely site inspections to improve the enforcement of the use of the PPEs and implementation of its policies and procedures.
PS3-POLLUTION PREVENTION AND ABATEMENT
- Pollution Prevention, Resource Conservation, Energy Efficiency: The Malting Division has a very well established program of water and energy conservation. They have changed the equipments in the old plants that had promoted significant changes in the energy consumption and water conservation. The Company has specific targets to reduce consumption of both resources and good monitoring. The goal is to achieve an average of water consumption of 5m3/ton and reduce the energy consumption in 2% an year.
The Company is decommissioning some areas of the old plants that contain old oil and coal storage facilities. Soufflet will develop formal written decommissioning plans consistent with IFC EHS Guidelines, section 4, requirements, or an equivalent international standard.
- Wastes:
Solid Wastes: the main process’ solid wastes are the dust collected in the cyclones or filters from the dust suppression system, and the mud of the wastewater treatment station. The mud is used as a fertilizer and dust is used the feed cattle. The office’s wastes are collected and disposed by the local public system.
Wastewater. The average monthly wastewater production ranges from 40.000 m3 to 60.000 m3 per site. From the total 5 existing malting plants in ECA two have wastewater treatment facilities, in which the wastewater is directly discharged to local rivers. In The other three plants wastewater is delivered to local public sewage systems without treatment. Soufflet complies with local regulations requirements before discharging wastewater to the rivers. Soufflet will deploy wastewater pre-treatment, if necessary, at all plants that they deliver wastewater to the public sewage systems to achieve compliance with IFC General EHS Guidelines requirements as defined at table 1.3.1
Air emissions Soufflet has small boilers at the malting plants to produce heat that will be used in the kilning process. Their thermal power capacity ranges from 3 to 6 MW and are considered small combustion facilities as defined in IFC EHS Guidelines. All the boilers, with one exemption, are fed with natural gas and only in Kazakhstan the Boilers are fed with heavy Oil. The Company will monitor NOx emissions from the Boilers fed with natural gas and will deploy the necessary adjustments to achieve compliance with IFC General EHS Guidelines requirements as defined at table 1.1.2. The Company will also monitor emissions rates of Particulate Meter, SO2 and NOX from its Boiler in Kazakhstan and will deploy the necessary adjustments to achieve compliance with IFC General EHS Guidelines requirements as defined at table 1.1.2. The Company will also consider alternative options to replace oil consumption in Kazakhstan to natural gas or Biomass.
- Hazardous Materials: The malting plants uses different types of refrigerating gas in its cooling systems that can be Ammonia, HCFC-R22 or Glycol oil. Where the Company uses Ammonia or HCFC R22, they will deploy the refrigerating facilities with alarm systems to identify leaks and proper warning signs in the area. Malting Division has been replacing the Ammonia and R22 to Glycol oil, which is safer for the workers. HCFC-R22 was banned by the Montreal protocol and the Company will replace it to other types of refrigerating gas, preferably Glycol oil. Gas cylinders (oxygen and acetylene) are properly stored in areas specifically assigned for it. The Company has two storage tanks for heavy oil in Kazakhstan and underground pipes from the transport unload facility. Soufflet will conduct a gap analysis and will deploy all adjustments to achieve compliance with WBG/IFC General EHS Guidelines requirements as defined in section 1.5 and 3.3.
- Emergency Preparedness: The Malting Division has a formal written procedure for emergency response and preparedness, fire fighting brigades and equipments, trainings and drills. The Agriculture Division will develop the same approach at its plants.
- Greenhouse Gas Emissions: The main significant emissions from Soufflet activities are related to energy consumption from the grid and from fossil fuel consumption from the boilers. The Company is conducting an inventory of its GHG emissions, and already has in place an energy efficiency programs to reduce GHG emissions. Soufflet Group examines all potential solutions for energy conservation, for instance, replacing old compressors to new ones equipped with an energy recovery system, deploying low energy consumption motors or installing “green” kilns. Every Malting plant has an energy consumption reduction target of 2% an year.
- Pesticide Use and Management. The Agriculture Division stores and sells Pesticides to farmers. Soufflet own warehouses in France, Czech Republic, Kazakhstan and Poland and lease ones in Russia, Ukraine and Romania. The Company will conduct an assessment and gap analysis of its existing warehouses consistent with EU safety requirements for small pesticides warehouses. Soufflet will develop and implement a corrective action plan to bring warehouses to compliance, over time. Soufflet Agriculture Division will also develop a safety procedure for Pesticides transport, storage and distribution with provisions for risk communication (warning signs and Material Safety Data Sheet), use of Personal Protective Equipment – PPE, emergency equipments and procedures, training, product segregation and handling. Soufflet will develop and implement a pesticide selection procedure and will phase out any pesticide that follows under World Health Organization (WHO) Class Ia or Ib, over time.
PS4-COMMUNITY HEALTH, SAFETY AND SECURITY
- Community Health, Safety and Security. Most of the Malting plants are located within or close to small towns and urban or semi urban area. The main expected impacts of their operations are related to wastewater releases, air emissions and trucks traffic. There is also the risk of explosion due to dust explosive atmosphere formation. Where the Company releases wastewater directly to local rivers, they already monitor and are seeking to comply with local standards of water quality. Soufflet will also deploy if necessary wastewater pretreatment facility before delivering it to local public sewage treatment facilities to ensure to achieve minimum wastewater quality standards. Soufflet will also monitor its air emissions to achieve compliance with international best practices standards and avoid degradation of air quality. Soufflet will also improve the safety of the silos in the Agriculture Division, as well as they have already done in the Malting plants, to avoid creation of dusty explosive atmospheres and heat in the silos.
- Emergency Preparedness and Response, As described in PS2 section
- Security Personnel Requirements Soufflet may use armed security personal in some of their operations and security guards are hired through a local contractor. No incidents involving security guards have been reported from any of the operations.
Soufflet will develop a corporate Security Personnel policy covering the assessment of risk, hiring, training, rules of conduct, equipment and monitoring as well as a grievance mechanisms for local communities to express concerns and in accordance with local laws to ensure the requirements of PS4 on Security Personnel are met throughout the Group.
