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
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

Key environmental and social (E&S) issues associated with this Project include: development and implementation of EHS management systems, health and safety; assurance of fair, safe and healthy working conditions in compliance with local regulatory requirements and relevant Performance Standards during construction and operation ; resource efficiency of the operations (water and energy efficiency); monitoring and management of air emissions, wastewater treatment and discharge, solid waste disposal; life and fire safety management including emergency preparedness and response; and the supply chain of knitted fabric.

The Project activities will be undertaken within DBL’s existing industrial complex (Mymun Complex). No new land acquisition is envisaged for any of the activities in the Project. Thus PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. Similarly, the type of impacts envisaged in PS6 (Biodiversity Conservation and Sustainable Natural Resource Management) do not apply; and this also applies to PS7 (Indigenous Peoples), and PS8 (Cultural Heritage).

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.

IFC’s assessment considered DBL’s management of its EHS performance in the establishment and operation of its already operating fabric dyeing and printing facilities in the Mymun Complex (Hamza, Mymun and DB Tex) and compliance with national and local permit requirements. The discussions in below sections focus on the policies, procedures and infrastructure in the Mymun complex as the same will be extended to the Color City operations.



Environmental & Social Impact Assessment (ESIA): As per the requirements of the Bangladesh Environment Conservation Rules 1997 (ECR 1997), DBL is in the process of obtaining the Environmental Clearance Certificate (ECC) for the Project from the Department of Environment (DoE). DBL had submitted the preliminary Environmental Management Plan (EMP) to the DoE in January 2010. DoE inspected the Project in March 2010 and asked DBL to apply for ECC once the machine installation is complete and ETP is installed. Both these activities are expected to be complete before October 2013 and DBL will apply for ECC for Color City thereafter.



Policy and Management Systems: DBL has a Group Environmental Policy as well as Occupational Health and Safety Policy. It has implemented an environmental management system (EMS) certified as per ISO 14001:2004 in the Mymun complex covering Mymun, Hamza and DB Tex. The EMS will be extended to Color City and it will be included in the certification.



DBL''s procedures and systems are also reviewed as per the standards of various global retailers who are DBL''s buyers. As part of these reviews, all facilities undergo independent assessments required by DBL’s buyers (Walmart, H&M, G-star, Puma, etc.) against their code of conduct compliance requirements on fire safety, occupational health and safety, labor and working conditions. In addition, currently DBL is undergoing independent buyer-mandated structural and electrical safety (including fire safety) assessments. Based on these assessments, DBL will agree on a time bound action plan with its buyers.



The Color City buildings comprise a manufacturing unit and a low rise office block. DBL’s key buyers require independent fire, electrical, and structural safety evaluations of this facility. As part of the agreed ESAP, DBL will provide the results of these independent assessments and agree on a time bound corrective action plan (with the Buyers and IFC) based on any gaps defined in the assessments.



Organization: Responsibilities and authorities for managing the EHS issues and risks are clearly defined and communicated within DBL. The Group has a dedicated E&S compliance team headed by GM - Corporate and Deputy GM - E&S Compliance. Under the Deputy GM, there are separate teams of assistant managers and executives for environmental compliance and social compliance. The responsibility of the group compliance team is to monitor and review E&S compliance across all facilities and report to the board of directors. DBL also has a Director –
Sustainability who is responsible for reduction of environmental impacts of DBL operations with a focus on energy efficiency, water efficiency, carbon emissions and waste reduction as well as implementing the Group’s Corporate Social Responsibility (CSR) program.



Mymun complex (where the Project is located) has a dedicated person with the responsibility of implementation of the EMS who is also the safety in-charge for the complex. Additionally, there are utilities/maintenance, waste management, ETP operation and safety teams who have E&S responsibilities.



Fire safety and emergency response: The fire safety system at the Mymun complex is based on a fire hydrant system and portable fire extinguishers. Fire alarm call points have been provided at many locations. The locations of fire extinguishers, fire hose boxes and alarm call points are clearly marked. The fire safety equipment was noted to be inspected regularly and well maintained.



DBL has a Group Fire Safety Incharge (who is also the Administration head for the complex) and a fire safety team. Additionally, in each of DBL facilities including the Mymun complex, a number of workers have been trained in fire safety and operation of fire safety equipment. Refresher courses on fire fighting are run as part of the monthly training calendar.



DBL has documented an emergency response plan for the complex. The roles and responsibilities for various teams responsible for evacuation, rescue, fire fighting, first-aid etc. are defined and are displayed at various locations in the factories in the complex. The assembly points are identified and marked. Emergency exits and evacuation routes are clearly marked and have a provision of emergency lighting. Regular mock drills are conducted to assess the preparation of the teams. Fire safety and emergency response systems of DBL are also reviewed as part of various code of conduct compliance audits by DBL’s buyers (e.g., H&M, Walmart, Puma, G-star etc.) and the Mymun complex factories are approved as per these buyers’ requirements.



No major accidents or fatalities are reported by any of the facilities in the past few years.

DBL employs about 15000 workers in its group companies, most of them in the stitching operations. All the workers in DBL are employed on company rolls and there are no third party workers. For Color City, DBL will employ around 1500 workers (660 for Phase-I and 848 for Phase-II). The Phase-II workforce will include 700 workers and 165 technical and managerial staff members. Like all the other dyeing units in the Mymun complex, Color City will operate in three shifts.



Human Resource Policies and Procedures: DBL has a Group HR Manual which describes policies and procedures applicable to staff and workers. Many of these policies and procedures (e.g., Health & hygiene policy, leave policy, grievance procedure, prevention of child labor policy, disciplinary procedure etc.) are displayed on a Policy Board in the operating factories in the complex. The policies and procedures were noted to be meeting the IFC PS2 requirements.



Working conditions and terms of employment: DBL signs a contract with the worker at the time of employment. The contract describes the working conditions and terms of employment. In addition, each worker is provided with an employee handbook explaining the provisions of Bangladesh Labor Act, working conditions and benefits provided at DBL including probation period, wage calculation, festival bonus, leaves etc. and some basics on occupational health & safety. DBL also provides an induction training for new workers which includes awareness on working hours, calculation of wages, leave policy and disciplinary procedure. The same is repeated in the refresher sessions as part of the monthly training calendar.



The working conditions and terms of employment were noted to be meeting the legal requirements.



In addition to the statutory benefits, DBL has made a provision of a Fair Price Shop where workers can buy food grains, cooking oil and other household items (toiletries, housekeeping etc.). Also, a Fair Price Pharmacy has been provided where DBL workers and their relatives can buy medicines. Both these shops are located in the Jinnat complex located within 1 km of the Mymun complex.



Non-discrimination and Equal Opportunity: DBL has a documented policy on non-discrimination and equal opportunity as part of its recruitment policy. No instances of discrimination were noted.



Freedom of Association: Though DBL management does not restrict its workers to become member of trade unions, currently there is no workers'' union at the operating factories in the complex. The factories in the Mymun complex have a workers’ participation committee with about 20 members. The committee meets on a regular basis to discuss issues related to workplace and improvement of facilities.



Child Labor and Forced Labor: To prevent use of child labor, DBL collects age proof documentation (e.g., National Identity Card) at the time of recruitment of the worker. In absence of age proof documentation, age of the worker is verified through a doctor
’s examination. Regarding forced and bonded labor, no such practices were noted. There is no provision for workers to obtain a loan from the factory.



DBL has included child labor, forced labor and non-discrimination in its induction training for new workers.



Grievance mechanism: DBL has a documented grievance procedure. The same is also displayed at various locations of the factory and DBL also provides regular trainings for workers on the grievance mechanism. Under the procedure, there are multiple means for workers to raise their grievances, including; (a) through the welfare officer of the unit; (b) by submitting them in writing in one of the grievance/suggestion boxes kept in the factory; (c) through the immediate supervisor/admin officers/HR department/compliance team members. The mechanism describes the process of documentation and resolving the grievances. The procedure, however, does not cover the aspects of raising the grievances anonymously and preventing retribution to the workers. DBL will therefore revise the procedure to align it with PS2 requirements.



Occupational Health and Safety (OHS): DBL has identified machine specific safety risks in the factories in Mymun complex. Based on this risk assessment, the safety instructions are displayed on the respective machines. Training is provided to workers on usage of personal protective equipment (PPE) both as part of the induction as well as through monthly refresher sessions. Usage of PPE was noted to be adequate. The visit did not indicate any unmitigated safety hazards.



DBL is also planning to implement OHSAS 18001 for its dyeing factories. As part of this process, DBL will complete a formal OHS risk assessment and review its safety provisions as part of the new management programs.



The DBL facilities document and investigate accidents/incidents/injuries. No major accidents or fatalities are reported by any of the facilities in the past few years.



Mymun complex has a medical center which has a doctor in the day and a male nurse is available 24 hours. There is also an ambulance for medical emergencies. DBL’s knitting and stitching complex (Jinnat Complex) located within 1 km of the Mymun complex has a bigger medical center with a mini operation theater, pathology laboratory and observation room (with 6 beds).



Supply Chain: DBL sources raw (or griegh) knitted fabric from the knitting facilities within the group as well as those outside the group. Post implementation of Color City, 55% of the fabric will be sourced from within the group and the rest will be sourced from knitting factories outside the group.



For the group facilities, as discussed above, these facilities undergo independent assessments required by DBL’s buyers against their code of conduct compliance requirements on fire safety, occupational, health & safety, labor and working conditions.



Regarding the facilities outside the group, DBL has a process of supplier evaluation under which the supp
lier facilities are audited by the compliance team through a checklist covering health & safety (including fire safety), environment, HR management (including child labor), and management systems. DBL will review and strengthen the supplier evaluation program by documenting DBL’s expectations from suppliers (both at the time of start of business as well during the relationship), including additional aspects like prevention of forced labor, structural safety etc. and improving the monitoring and follow-up procedures to ensure adequate improvements on these issues.

Resource Efficiency: DBL’s factory Hamza (located in the same complex as Color City) was one of the first set of 18 pilot factories to engage in IFC’s Cleaner Production (“CP”) program over 2010-11. Hamza implemented the 14 out of the 17 recommendations and reduced gas consumption by 4% and energy consumption by 14% in the period 2010-2011.



DBL is also one of IFC’s key CP and resource efficiency partners under the Dutch funded ''Partnership for Clean Textile'' (PACT) project. As part of this, a joint on-site audit and in-depth study has been performed to establish the water and energy consumption mass balance. Based on this, various improvement options will be proposed to improve water and energy efficiency including better effluent treatment enabling water reuse. Also, as part of ''community engagement and outreach'' component of PACT, DBL will work in the local communities of the “Konabari” area to increase awareness on water efficiency.



DBL closely monitors resource consumption i.e., process water, gas, electricity, dyes and chemicals. The data provided for 2010-2012 for Mymun complex shows improvement in all areas. The process water consumption is reported to be 66 liters/kg of fabric which is below the water consumption benchmark for knitted fabric finishing (70-120 liters/kg) as per the World Bank Group (WBG) EHS Guidelines for Textiles Manufacturing. Similarly, electricity consumption is reported to be 0.71 kwh/kg of fabric which is below the benchmark of 1-6 kwh/kg as per the guidelines. As the fabric processing technology in the Color City is similar to Hamza, similar levels of resource consumption are expected.



To increase water efficiency further, DBL will evaluate options for reuse of effluents for gardening and/or toilet flushing in the new office block. Also, as per the requirements of Environmental Clearance (issued to already operating dyeing and finishing facilities in the complex), DBL will complete the feasibility assessment of salt recovery or any other suitable effluent recycling technology and submit a plan to DoE.



Air Emissions: The main source of air emissions for Color City will be the gas based power generators (total capacity of 8 MW)and gas based boilers (capacity of 50 tons). DBL monitors stack emissions and ambient air quality on a yearly basis. The monitoring reports indicate compliance with the legal requirements.



Water and wastewater (including Stormwater): The main source of water is the on-site borewell. The water is treated in the Water Treatment Plant (WTP) with iron removal, multi-grade mediafiltration followed by ion exchange (IX) softening and pHcorrection. For Color City, a new WTP will be installed with similar treatment process.



The industrial effluent generated in the facilities in Mymun complex is treated in the existing ETP with a treatment capacity of 4000 m3/day. The ETP is based on secondary treatment in a conventional activated sludge process (ASP). For additional wastewater
that would be generated from Color City operations, a new ETP has been constructed with a treatment capacity of 7500 m3/day with same treatment methodology. The civil structure work of the complete and the installation of treatment equipment will be completed by October 2013. Like the existing ETP, the treated effluent will be discharged in the River Turag.



The effluent is tested in the internal laboratory on a weekly basis and through DOE on a quarterly basis for limited parameters and externally on a yearly basis for a detailed list of parameters. The reports indicate compliance with the legal limits as well as the limits specified in the WBG EHS Guidelines for Textiles Manufacturing.



Sewage is disposed of in the septic tank and then into the public sewage drain.



Stormwater is currently drained off-site through stormwater drains into the river. DBL is planning to implement rain water harvesting in the complex to recharge groundwater.



Waste Management: The main waste streams generated at the complex include packaging wastes (e.g., cartons, paper, polyethylene), empty containers of hazardous and non-hazardous chemicals, waste fabric, used tubelights, used batteries and ETP sludge.



The packaging wastes, empty containers (after washing) and waste fabric are sold to external agencies who sell it further for recycling.



As there are no hazardous waste landfills in Bangladesh, the ETP sludge is dewatered using a filter press and stored in bags in an earmarked room. After 6 months of drying, the sludge is disposed of on-site in a reinforced cement concrete (RCC) pit. Currently DBL is working with Deutsche Gesellschaft für Internationale Zusammenarrbeit (GIZ) GmbH on an initiative to use ETP sludge as an alternative raw material for cement clinker production. This pilot project aims to set an example for an environmentally friendly sludge disposal option for the textile industry.



The used tube lights and batteries are given back to the respective manufacturers.



Greenhouse Gas (GHG) Emissions: The GHG emissions for the project are from consumption of fuels – gas and diesel. The estimated GHG emissions from Color City operations are estimated to be 35,000 tons CO2/annum.

The Project is being implemented in within DBL’s existing industrial complex with three operating dyeing and printing facilities, hence no significant additional impacts on local community are expected except additional traffic which may be generated due to Color City operations.DBL signs contracts with its transporters and ensuring safety during traffic is a clause in the contract.



The facility has its own security workers who are unarmed. Regular training program are conducted by the security in-charge for the guards on the standard operating procedures for their job.

DBL has been operating the factories in Mymun complex since 2002. The spinning, knitting and stitching factories of the group are also located within 2 km of the Mymun complex in the same area (Kashimpur). Under its CSR program, DBL has supported the local community by building the local prayer house, providing financial or infrastructure support to the schools and colleges and repairing the roads. Also, DBL has provided financial assistance to hospitals (Dhaka Medical College, Birdem, Mitford, Ahsania Mission Cancer). DBL has received a CSR Award in 2008 and Standard Chartered-Financial Express CSR Award in 2010-11.

It was mentioned that the local community members regularly engage with the management directly or through DBL’s many staff members and workers who stay in the area. However, the engagement is informal and there is no documented process. Therefore, DBL will develop and implement a documented process of community engagement and grievance mechanism.

DBL will locally disclose this ESRS at its website: http://www.dbl-group.com, as well as locally at the following addresses:
DBL Group
Mymun Textiles Limited/Hamza Textiles Limited/DB Tex Limited
Nayapura
Kashimpur, Gazipur
Tel : +880 2 7790060-67

Any queries and/or comments about the project may be directed to:

Mr. Abdul Matin
DBL Group, BGMEA Complex,
23/1, Panthapath Link Road,
Kawran Bazar, Dhaka-1215
Tel : +880 2 8140207
Email: mailto:matin@ho.dbl-group.com

Broad Community Support is not applicable for this project

DBL Color City 2(31357) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Structrual & Electrical Safety: Conduct structural and electrical safety assessments against recognized standards for Color City as well as its knitting and stitching facilities through independent competent professionals. Share the results of these assessments with IFC and agree on a time bound corrective action plan, in case required.	01-Jan-2013	Completed	Completed	12/10/2015
Review and revise the grievance procedure to align it with PS2 requirements including the aspects of raising the grievances anonymously and preventing retribution to the workers.	31-Dec-2013	Completed	Completed	12/10/2015
Review and strengthen the supplier evaluation program to document the expectations from suppliers (both at the time of start of business as well during the relationship), including additional aspects like prevention of forced labor, structural safety etc. and improving the monitoring and follow-up procedures.	31-Dec-2013	Completed	Completed
Evaluate feasibility of reuse of effluents for certain purposes on-site e.g. gardening and toilet flushing in the new office block.	31-Dec-2013	Completed	Completed
As per the requirements of Environmental Clearance (issued to already operating dyeing & finishing facilities in the complex), complete the feasibility assessment of salt recovery or any other suitable effluent recycling technology and submit a plan to DoE.	31-Mar-2014	Completed	Completed
Develop a documented community engagement and grievance mechanism including a method of receiving, handling public grievances and providing feedback on them. The information to be communicated to the local community through appropriate means.	31-Dec-2013	Completed	Completed