The Company has presented information on its policies, plans and procedures that seek to address environmental and social risks and impacts which are summarized in the findings below along with specific additional agreed measures to be implemented by the Company in order to comply with host country laws and regulations, IFC Performance Standards on Social and Environment Sustainability and applicable World Bank Group (WBG) general and specific (Food and Beverage Processing) Environmental, Health and Safety (EHS) guidelines. These additional measures to be undertaken by the Company are listed in the attached Environmental and Social Action Plan (“ESAP”).
PS 1: Social and Environmental Assessment and Management Systems – IFC’s review considered the Company’s assessment of potential social, environmental, occupational health and safety, and food safety impacts and risks from its operations and programs in place to mitigate and manage these risks on an ongoing basis through its management system which includes the elements listed below. The Company engagement with local communities regarding environmental, health and safety performance is discussed in the community engagement section of this document.
Environmental and Social Assessment
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 and implementing an integrated corporate environmental and social management system (ESMS) for environmental and social affairs, food quality and safety, and occupational health and safety management. The ESMS will address environmental, labor, and occupational health and safety issues associated with the overall Company operations and proposed new facilities, including construction phase. Patisen will design the ESMS to comply with IFC Performance Standard 1 requirements and related PS1 Guidance Note. The ESMS will incorporate a supply chain component.
The Company is rapidly expanding and space availability is an ongoing issue. All existing facilities are in industrial areas. The Company doesn’t have a systematic process in place to fully identify, evaluate and assess its environmental and social impacts. This will need to be addressed in the Company’s environmental and social management system. The Company will ensure that as per the requirement of the “Département de l’Environnement et des Etablissements Classés” an environmental and social impact assessment is conducted for each new location prior to obtaining operating permit. The terms of reference of the ESIA will be provided to IFC for comment to ensure compliance with national law and IFC PS. The Company is currently engaging with the Hazard Analysis Critical Control Point (HACCP) compliance bureau, and the FONDEF program of ONUDI as the Company is keen to operate at international standards and plans to seek ISO 2200 certification (quality management system and HACCP).
Organizational Capacity and Management Programs
The Company has a quality assurance (QA) professional who is responsible for the implementation of quality assurance procedures as well as occupational health, safety and hygiene. The quality assurance professional is supported by production unit heads to implement the QA programs. As set forth in the ESAP, the Company will hire an experienced Environment, Health and Safety (EHS) manager that will report directly to the Company manager and provide him/her with adequate resources to put in place relevant management programs to strengthen the Company’s environmental, OHS, food safety and social management ensuring compliance with the requirements of host country laws, IFC’s Performance Standards and WBG’s EHS Guidelines. In addition, the Company will establish Corporate Environmental Managerial Responsibilities and an Organogram. The Company will also assign environmental and social managerial duties at each operation, and undertake the activities required to implement environmental and social policy at all levels of operations.
Training
The Company 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. There is no defined training program for employees for this fiscal year. The Company will identify training needs for the staff responsible for implementing the management programs. Furthermore, the EHS manager will ensure proper annual training of workers, raise awareness on occupational health and safety, have joint meetings on OHS with contractors and subcontractors, and jointly investigate any incidents/accidents on the site; regularly conduct occupational health and hygiene inspection at various facilities; and build in-house capacity to collect accurate E&S information on suppliers at origin and reliably input data into the supply chain component of the ESMS.
Monitoring and Reporting
The Company will establish an E&S monitoring and reporting program for both construction and operation phases of the Project. The Company will implement a process for periodic reporting and monitoring of environmental and social information to senior management, to allow monitoring of progress. Patisen will proactively seek opportunities to foster mainstreaming of E&S best practices in its supply chain over time.
PS 2: Labor and Working Conditions
IFC’s review considered Patisen practices with regards to fair, safe and healthy working conditions in its operations.
The Company has 200 full time employees, and at any given month can hire up to 270 temporary workers and 1,600 daily workers. The Company has a human resource manager who is in the process of putting in place HR policies and procedures. Each employee has a contract which has to be registered at “Inspection Régionale du Travail et de la Sécurité Sociale de Dakar” (social security). The Company is in compliance with the local labor code, and it is governed by “La Convention du Commerce – Activités de Negoce” which defines the various labor categories, employee’s benefits, as well as minimum salary to be paid for each category. All employees are over 18 years old and are paid above minimum wage. The Company contributes to social security; and both Company and full time employees contribute to IPM (medical insurance for employees and his/her family) as well as IPRES (pension). In addition, there is an optional private medical insurance that employees can subscribe to which is 50% subsidized by the Company. The Company is an equal opportunity employer and has performance evaluation and promotion systems based on set objectives and performance outcome.
The Company works with an employment agency to source temporary workers. This agency has a contract with each potential worker and registers the contract with social security. With regards to daily direct workers the Company contributes to social security to cover work accidents.
As per local labor laws and regulations, the employees have the right to freedom of association. However, none of the employees are unionized nor are there workers’ representatives for the time being. Employees grievances are handled by direct supervisors, followed my manager then director. If the matter is not resolved, it gets escalated to HR. The Company will organize election of workers’ representatives for each production unit to be the liaison between the employees, HR and the Company. These workers representatives will be provided with terms of reference and training on national labor rights.
Patisen will modify existing procedures to fully comply with the requirements of IFC’s Performance Standard 2 Labor and Working Conditions. It will include reference to child labor, non-discrimination, freedom of association and collective bargaining.
Approximately 10% of the client revenues are attributes to sales of chocolate based products such as chocolate, peanut butter spread and cocoa powder. The Company utilizes about 1,500 tons of cocoa per annum and it currently sources it from a company in Spain. Based on this sourcing procedure, Patisen does not have the leverage to influence any potential E&S issues in the cocoa’s supply chain. Sugar is sourced in Brazil, flour in Germany, and mono sodium glutamate (MSG) in France. As part of the supply chain component of the ESMS, Patisen will upgrade its purchase policy to promote sustainable purchasing practices. The Policy will support these objectives, promoting compliance with national environmental legislation and IFC Performance Standards, including among others, avoidance of child labor and forced labor. As part of its E&S monitoring, Patisen will develop procedures for monitoring of key environmental and social information on its supply chain at the local level and track information in a database.
In order to minimize OHS incidents, the Company provides Personal Protective Equipments (PPE) such as gloves, hair caps and, in some cases, ear plugs. During the site visit at the various Patisen’s processing facilities, IFC observed that not all employees were wearing adequate PPE and several employees in contact with food were not wearing gloves or masks. Non compliance with PPE was more prominent with subcontractors, temporary and daily workers. As part of its ESMS, the Company will plan, fund and staff an OHS management system including employee training; capabilities for job hazard analysis; training and placement of health and safety coordinators in each operation; emergency response and contingency planning; data collection and analysis. The Company will update its OHS policy for its processing and warehouse facilities in accordance to WBG’s EHS guidelines and present an Action Plan detailing activities and budget.
By the same token, safety awareness and procedures should be developed for fleet drivers; enforce speed limits and schedule relevant training, such as defensive driving. Furthermore, the Company should develop an operational safety plan for site infrastructure as field visit indicated deficiencies in the display of signals and emergency warning devices to allow clear identification of evacuation routes and ensure safety of the workforce. This plan should include pavement markings, wall signals, and warning signs and devices, according to international standards, to indicate evacuation routes and alternate means of escape, for workers and visitors to gather and to ensure that everyone has left the danger zone.
The Company records accidents for the purpose of reporting to the social security services but not as a risk management tool. In compliance with E&S performance monitoring requirements in PS1, the Company will track, investigate, analyze, and report on incidents and accident and use lessons learned as part of the training program.
PS 3: Pollution Prevention and Abatement
IFC’s review considered the Company’s management of water resource and energy use, raw material storage and handling, solid and liquid waste disposal, effluent discharge, air emissions and noise in the surrounding human and natural environment of its operations.
The Company’s relies on the municipal networks for water supply and consumes 28,666 liters per year. Limited water is used in the production; the rest is used for cleaning equipments, general housekeeping, and sanitary purpose. As part of its E&S performance evaluation, the Company will track and assess its water consumption, benchmark it against best industry practices and identify opportunity to reduce water use.
Energy is sourced from the national grid, diesel based generators as back up, and a heavy fuel oil based boiler in the margarine plant. Furthermore, consumption of fuel is accrued by the fleet of Patisen cars in Senegal and some of the distributors’ delivery vehicles provided by Patisen as part of its distribution strategy. The total annual fuel consumption is approximately 500,000 liters of diesel. Annual power consumption is estimated at 9,940 MW and annual green house gas emissions will be approximately 8,500 tons annually of CO2 equivalent.
As the Company is planning to consolidate its operation on 100 hectares site located in the outskirts of Dakar, IFC will work with the Company to promote green building design and other energy efficiency opportunities. The Company also plans to use half of the site to grow peanuts (which are used in the production of chocolate spread) with the technical assistance from the US’s association of peanuts to produce high grade peanuts which are not readily available in the Senegalese market place. The Company will observe best practice in pesticide selection, use and field production practices.
The Company has one diesel underground storage tank for generators, and for pumping stations. USTs are stored in concrete secondary containment. The Company’ ESMS include an audit program for the integrity of USTs.
Solid wastes mostly consist of domestic waste and containers such as drum, tanks, plastic, and cardboard from raw material storage; these are either reused or sold to recyclers. Limited hazardous materials are found in the company’s operations. Used oil from the maintenance of vehicles are collected and sold to other recyclers.
Sanitary waste and waste water discharges are channeled through the municipal waste water treatment system. Drainage systems are equipped with oil and water separators but the Company does not analyze the quality of wastewater prior to discharge. As part of its ESMS, the Company will conduct analysis of effluent for key parameters, such as PH, oil and grease, biological oxygen demand and total suspended solids. Should the Company not be compliant with WBG General EHS Guidelines, the Company will put in place a wastewater treatment system to ensure compliance with such guidelines.
Air emissions mostly emanates from peanut grilling activities, boilers, generators, and aerosol from the manual dry spice mixing facility. Boilers should be equipped with filters or bag houses, air emissions monitoring will be required as part of the annual monitoring requirement. Proper ventilation of equipments and regular maintenance schedule, as well as dust minimization techniques, such as water mist spray should be implemented. Indoor air quality was not observed as an issue by IFC with exception to the dry spice mixing facilities where all workers wore heavy duty protective mask due to strong nature of spices.
As part of the hazard assessment, noise level within the plant will be measure to determine if additional PPE will be required.
As the plant uses ammonia in its refrigeration process it should ensure that its handling and storage practices are in keeping with best industry practice, as espoused by bodies such as the International Institute of Ammonia Refrigeration (www.iiar.org). This will be addressed as part of the Company’s ESMS.
The Company will put in place an emergency response system to handle any potential spills or fire and involve onsite fire wardens and the local fire department. Furthermore, the system will be tested through a mock drill to confirm effectiveness of the system or rectify any identified oversight.
The QA team has procedures for use of pesticide, including rodenticides. The Company will ensure that contractors applying these products have adequate PPE based on the material safety data sheet (MSDS) and/or international chemical safety cards (ICSC) for materials used. Patisen will ensure the non use of WHO Class 1a and 1b chemical formulations in their premises. The Company’s ESMS will include integrated pest management (IPM) procedures.
PS 4: Community Health, Safety and Security
IFC’s review considered the Company’s impacts on the health, safety, resource use and security of surrounding communities both for current facilities as well anticipated relocation site.
The Company’s facilities are located in industrial areas with limit impact on air emissions, and water resources, however, the Company has a fleet of 150 vehicles that deliver products to distributors. As previously indicated the Company will develop safety awareness and procedures for fleet drivers.
Patisen produced products, such as bouillon, margarine, chocolate spread, and cocoa powder, are all consumables. The Company has quality assurance procedures to ensure food safety in order to assess potential quality failure in the raw materials or during the production process. The Company has product quality specification standard for each raw material; and, laboratory control plan for products and raw material which are tested in the in-house lab. This quality assurance procedure was able to identify contamination of a product batch which was subsequently sequestered. This process will be improved through ongoing HACCP certification process.
The potential relocation of the Company in the outskirts of Dakar will also have potential community, health and safety impacts during construction, such as ambient air quality, noise, increased traffic, construction waste management, sanitary and domestic waste disposal, accident management, roadside accident response system. Should workers’ accommodation be built during construction phase, the Company will ensure that health and hygiene inspection at the construction site are conducted to ensure compliance with medical and health rules and regulations. The Company will also refer to IFC/EBRD guidelines on workers’ accommodation. The Company and the selected construction contractor will develop, based on the ESIA Study, environmental management plans and procedures to minimize health, safety and security impacts to surrounding communities from construction and operation phases.
The planned agricultural activity in addition to the production operation may have impacts on water resources for the community and pesticide use. The Company will ensure that the ESIA Study and related Environmental Management Plan ensure the avoidance and/or mitigation of such impacts.
The Company will put in place an emergency preparedness and response system that will be tested for its integrity as described in PS3 above.
The Company contracts unarmed security personnel to protect its staff, equipments, raw material and stock. The Company will ensure that security personnel have undertaken necessary screening and training in accordance with good industry practices. The Company will put in place a system to investigate any credible allegations of unlawful or abusive acts of security personnel, take action (or urge appropriate parties to take action) to prevent recurrence, and report unlawful and abusive acts to public authorities when appropriate.
A community grievance mechanism will be put in place to allow community to lodge their grievances. A free telephone hot line should be created and be included on the label of all Patisen consumer products. The Company will maintain a register of complaints during construction and operation phases including actions taken to address complaints.
