While all Performance Standards are applicable to this investment, IFCs 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. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The key environmental and social issues associated with this apparel cutting and stitching operation relate to provision of safe and fair working conditions, and appropriate management of sanitary effluents generated by the large workforce employed by the Company.

Potential adverse impacts are local in nature and readily manageable through well known and commonly applied mitigation measures. This is therefore an environmental and social category B project.

The sections that follow described how Willbes Haiti does or will manage environmental and social aspects of the project in a manner compliant with the Performance Standards.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Social and Environmental Assessment

Willbes Haiti’s ongoing operations are in buildings purpose built by SONAPI to accommodate light industrial activity and especially textile stitching. Willbes Haiti’s ongoing operations have little adverse environmental or social impact, and for this reason formal environmental assessments are not required. The Project will require relatively minor refurbishment of similar adjacent buildings which have been rented by Willbes Haiti from SONAPI after the previous tenants ceased production, and formal environmental assessment similarly is not required. However Willbes has identified potential adverse impacts from its activities, such as those related to labor conditions and occupational health and safety and has established a management program to manage these impacts.



Management Program

IFC’s appraisal identified several elements of social and environmental management systems in Willbes Haiti’s operations, and at the time of IFC’s appraisal, Willbes Haiti was strengthening these provisions. In addition, Willbes supplies to several well-known branded US retailers, all of whom have and enforce well structured environmental and social compliance systems on their suppliers. Moreover, as a Haitian apparel supplier to the US market, the Company does participate in the Better Work Program a joint IFC and International Labour Organization (ILO) program that aims to improve compliance with labor standards in global supply chains. Better Work undertakes biannual audits of the Company’s facilities.



The Company has a written Environmental, Social, Health and Safety management plan, which defines objectives in each of these areas and also best practices which will support these objectives. The management structure is headed by a Haiti-based Regional Quality Assurance and Social Compliance Director and a Korea-based manager to whom the QA and Compliance manager for the Americas reports. This person oversees these aspects of Willbes’ operations in the Dominican Republic and Haiti. Separate supervisors for labor, occupational health and safety (OHS) and environmental matters in Haiti have been appointed. Development of detailed written policies and procedures governing management of labor, environmental and OHS matters was ongoing during IFC’s appraisal. In practice, many of the systems used in the Dominican Republic will be replicated in Haiti, in the case of written documents after translation from Spanish to Creole. The Company will complete the developments of these procedures, and will share them, together with key performance indicators with IFC.



One such procedure is the Willbes Self Compliance Check List which is used by Willbes to audit its own operations in the Dominican Republic and those of suppliers. The checklist is designed to ensure Willbes’ compliance with the environmental, afety and labor requirements of Willbes’ most significant customers. The checklist covers issues such as general
management issues, child labor, forced labor, working hours, wages, occupational health and safety, discrimination, harassment or abuse and documentation of all of the above. This checklist also follows-up non-compliances identified in previous audits, and includes worker interviews.

Worker Relationships

The Company does have a written Human Resources policy, in Haitian Creole, which defines the rights and responsibilities of the Company and employees. Terms of the working relationship are communicated to workers through the policy and the employment contract.



Working conditions are established in contracts which have been approved by the Haitian ministry of labor. The basic work week is 8 hours/day, 6 days/week with a 60 minute rest period. The basic salary is set at 200 Haitian Gourds (HTG) per day. Overtime is worked as needed, and is paid at 150% of the basic salary, and double time if worked on Sunday. These basic salaries are supplemented by piece-work rates. Better Work’s interpretation of the Haitian labor code is that after stabilization of work on new products 90% of the established workforce should earn 300 HTG daily. A sample review of payroll records by IFC showed that many of Willbes’ employees were earning at least 300 HTG daily, and the average daily salary paid exceeded this figure.



Willbes in summer 2013 became aware that some of its workers are members of a trades union, though it has not been formally notified of union activity in the workplace. The Company has confirmed that it would permit a formal establishment of union membership among its employees, and views such a move as a means further to improve employer / employee communication. Better Work confirmed that through their employee interviews in the early Better Work audits (around 10% of the employees at each of two audits) employees had not expressed any desire for union membership, though more recently union activity has started. Ten union members were among around 70 workers dismissed in summer 2013 following loss of an order. This dismissal was investigated by Better Work Haiti and the CTMO-HOPE Ombudsperson and the issue is considered closed. No evidence has been observed of discrimination in employment.



The Better Work auditing program, and a suggestion box system, which has written and pictorial instructions on use, form the employee grievance mechanism.



Willbes Haiti checks status of prospective employees, including age, and there is no evidence of any child labor. In 2010 Better Work did identify, in one factory unit, an incidence of compulsory overtime, in which a supervisor held employees time cards. This issue was eliminated immediately it was brought the attention of the Company’s management and the issue is considered closed.



Occupational Health and Safety

Apparel manufacture is not a high risk sector, but a number of OHS hazards requiring additional mitigation have been identified. The textile cutting operation is mechanized, and the operators usually, but do not always wear a protective chainmail glove on the “holding” hand. Sewing machines are not universally fitted with guards to protect employees from broken needles, often because the employees remove them, considering that they are burdensome.
Employees using a spot-removing spray do so without eye protection, and there are areas in which material safety data sheets (MSDSs) should be more prominently available. Willbes Haiti will enforce use of machine guarding and personal protective equipment, and will provide MSDSs as required, and train employees in their use.



Following comments by customers and Better Work Haiti, Willbes has enhanced its emergency exit arrangements for workers, and will be enhancing factory ventilation with the intent to control high summer time temperatures during early 2014.



Willbes Haiti does not presently have a formal accident investigation system, but one will be developed as part of the social and environmental management program.



Willbes Haiti’s premises have fewer toilets and a smaller staff eating area than indicated by the number of employees. The Company will use its best efforts in negotiating with SONAPI, its landlord, in seeking upgrades.



Non-employee workers

Willbes Haiti uses its Self Compliance Checklist, as described earlier, to verify working conditions of its subcontract suppliers on a monthly basis. It follows up with its suppliers in the same manner as its own customers adopt in dealings with the Company. Suppliers are rated green, yellow, orange and red, and three successive failing grades result in termination of the contractual relationship.

Emissions to Air

These are limited to combustion products arising standby diesel generators and a small synthetic waste burning packaged steam boiler, used to generate steam for ironing newly made clothes. All combustion equipment is small, and emissions data are not available. However, observation showed that exhausts from the generators visible smoke. Willbes will service this equipment, adjusting the boiler burners, and the engines’ air filters and diesel injector pumps in order to mitigate these emissions.



Liquid Effluents

The Company’s manufacturing processes are dry, and process effluents are not produced. Sanitary waste water arising from the industrial buildings’ toilet blocks is directed to septic tanks for initial treatment, with the liquid stream existing via a gravel tanks and bacterial bed, to drains serving the entire SONAPI park, and thereafter to the sea. No effluent discharge data are available. Septic tanks are serviced by SONAPI. The Company will ensure that service frequency is sufficient to prevent the overflow observed.



Solid Wastes

Most solid waste is formed of cotton scraps which result from cutting cloth profiles from woven raw material. Layout patterns are developed to minimize such waste. This waste is burnt in the boiler described above. Other waste is collected by a contractor for SONAPI and taken to an authorized disposal site.



Hazardous Materials

Chemicals used for fabric treatment are generally safely stored in segregated areas with adequate containment.



Observation showed that used engine oil and oil filters had been dumped over the factory fence, causing a small degree of oil contamination of ground. The Company will suspend this practice, and identify a company to disposes properly of these materials, and clean the contaminated ground.



Greenhouse Gas Emissions

Annual greenhouse gas emissions from the ultimate development of the project are estimated at 5,500 tonnes per annum CO2 equivalent. Much of this represents generator fuel: major uses of electricity are many very small sewing machine motors, and factory lighting. Willbes Haiti will seek to use high efficiency fluorescent or LED lighting aligned with work stations when the new factory buildings are established.



Emergency Response Procedures

The most significant expected emergency is fire. Buildings have steel and concrete frames and withstood the 2010 earthquake. Emergency evacuation is planned, exit routes are marked, and evacuation drills are held.

Willbes Haiti’s operations are located within a purpose built industrial zone near Port au Prince airport, and so the Company has no direct neighbors, other than other industrial enterprises. However, the company does have constructive ongoing engagement with its workforce, including through staff interviews as part of the internal checklist described above and by Better Work, through routine line management and through a suggestion box which forms part of the employee grievance procedure.

A copy of this summary, translated to Haitian creole will be placed outside the gate of each of Willbes Haiti’s operating factories in SONAPI. The addresses of these factories are:

Buildings #34, # 41 and #42,
Parc Industriel SONAPI
Rte de l’Aeroport,Port au Prince

Attention: Mr H C (Antonio) Yang, General Manager
Telephone: (509) 2250 6732/6733
Email: mailto:hcyang@willbes.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
The Company will further develop and detail the plans for occupational health and safety and environmental management. These plans will include, as a minimum:Occupational Health and Safety: (i) Provision and enforcement of use of engineering guards and personal protective equipment; (ii) Procedures for safe storage, handling and application of chemicals within the Company’s premises, including by contractors; (iii) Workplace ergonomics and avoidance of RSI; (iv) Measurement of lost time incident frequency; (v) Lost time incident investigation. Environmental Management: (i) Hazardous materials management; (ii) Solid waste management; (iii) Septic tank monitoring and servicing	2/28/2014	In Progress	In Progress
The Company will further develop and detail the plans for occupational health and safety and environmental management. These plans will include, as a minimum	5/31/2014	In Progress	In Progress
Willbes Haiti shall develop and present to IFC time bound training plans for the nominated supervisors for social compliance, occupational health and safety and environmental management matter.	02/28/2014 12:00:00 AM	Completed	Completed	04/23/2014 12:00:00 AM
The company will present a time-bound Action Plan, responsive to the most recent Better Work Compliance Assessment Report available at the time of disbursement which will have the objective of eliminating all non-compliances identified in those audit reports within six months of the date of disbursement which the Company is able through its own efforts to correct.	02/28/2014 12:00:00 AM	Completed	Completed	04/15/2015 12:00:00 AM
The company will report to IFC its discussions and negotiations with SONAPI requesting that SONAPI enhances, or allows Willbes Haiti to enhance social areas of the factory buildings, where non-compliances have been identified by Better Work audits.	5/31/2014	In Progress	In Progress
Willbes Haiti will service its diesel generators and boilers so as to eliminate smoky combustion conditions	08/31/2014 12:00:00 AM	Completed	Completed	04/23/2014 12:00:00 AM
Willbes Haiti will arrange service pump out of all septic tanks and disposal of contents by a licensed contractor in approved manner.	08/31/2014 12:00:00 AM	Completed	Completed	04/23/2014 12:00:00 AM
Willbes Haiti will remediate the ground contaminated by disposal of oil and filters, and will thereafter contract with a licensed company for appropriate disposal of these hazardous wastes.	08/31/2014 12:00:00 AM	Completed	Completed	04/23/2014 12:00:00 AM