While all IFC’s Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that this investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

- PS1: Social and Environmental Assessment and Management Systems
- PS2: Labor and Working Conditions
- PS3: Pollution Prevention and Abatement
- PS4: Community Health, Safety and Security

Impacts related to PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainable Natural Resources Management, PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected with this investment for the following reasons: future land acquisition/lease for the expansion of SIPRA’s poultry farms from private owners and government entities will be done on a willing seller-willing buyer principle and will not involved involuntary resettlement and/or economic displacement; the project is located within existing consolidated agricultural or commercial/industrial zoning areas and no conversion of natural/critical habitats will take place; there is no presence of Indigenous Peoples or cultural artifacts.

In the event where these PSs become applicable, SIPRA will provide feedback to IFC. Screening and assessment of these issues against PS requirements will be done through SIPRA’s planned environmental and social management system (ESMS).

This proposed investment is expected to have limited environmental and social impacts which are expected to be site-specific, temporary and none are expected to be significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. This categorization is in accordance with other similar type of projects within the sector. The project is designed to avoid, minimize and manage environmental and social risks and impacts of the Company’s operations in compliance with applicable IFC’s Performance Standards and World Bank Group (WBG) General and sector-specific (Poultry production and Poultry processing) Environmental, Health and Safety (EHS) Guidelines. IFC’s Good Practice Note on Animal Welfare and its applications to SIPRA’s operations have also been assessed.

Key E&S issues applicable for this investment are: (i) operational licenses of SIPRA’s facilities; (ii) environmental, occupational health and safety (OHS), food safety and social management system, including Hazard Assessment and Critical Control Point (HACCP) and ISO 22000 certification; (iii) adherence to Ivorian labor law, working conditions, standards and OHS risk prevention and management, including SIPRA’s employees, contractors and nearby communities; (iv) Life and Fire Safety (L&FS) provisions and emergency preparedness and response; (v) use of public utilities (water supply and energy), optimization of water and energy use through project design and resource conservation measures and greenhouse gas emissions; (vi) food safety and biosecurity protocol and procedures; (vii) land acquisition and expansion planning procedures; (viii) wastewater collection and treatment, solid waste disposal, air emissions from generators and boilers, potable water quality, treatment and monitoring, hazardous material handling, management and control of pest and rodent; (ix) food and transport safety, and (x) engagement with communities on EHS, food and traffic safety and social performance.

To ensure that SIPRA will further comply with Ivory Coast’ environmental, labor and social laws and regulations, IFC Performance Standards and WBG EHS Guidelines, the Company will implement the measures summarized below, and in the attached Environmental and Social Action Plan (ESAP) which has been agreed upon by SIPRA and IFC, and which will address any compliance gaps with IFC Performance Standards requirements.

PS1: Social and Environmental Assessment and Management System
Environmental and Social Assessment/Audit. The establishment of SIPRA in 1976 and subsequent rehabilitation following privatization in 1996 is precedent to the requirements of an Environmental and Social Impact Assessment (ESIA) as defined in the Environmental Code (Loi N°96-766) adopted in October 1996. After review of this Code, Ivograin and CoqIvoire are classified as “établissement classés” and a number of provisions apply to these operations, including Article 75 on wastewater and waste discharges. As part of its licensing process, SIPRA is required to obtain its operational license (“Agrément d’exploitation”) on an annual basis. The underlying licensing process includes preparation of technical file, inspection visits by sector ministries and implementation of corrective EHS actions. Operational licenses for Ivoire Poussins, Ivograin and CoqIvoire, including slaughtering and retail outlets, are obtained from the Ministry of Animal Production. SIPRA has successfully obtained these licenses and shared copies with IFC.

Management Program. SIPRA has not yet adopted an integrated environmental, OHS, food safety and social management system, including policies, plans and procedures. However, SIPRA has taken tangible and positive steps in order to establish solid foundations for such a system. In particular, Ivoire Poussins is applying a voluntary Quality Charter for its hatchery (“Charte de qualité du Syndicat National des Accouveurs” (SNA), Juin 2003) and its production farms (breeders, egg laying hens and broiler) and a Biosecurity Protocol, which defined sanitary and hygiene management procedures for ensuring quality of inputs, working areas, staff, and the overall production process. No third-party audit has yet taken place for certification based on the above mentioned voluntary standard. Specifically, preventive vaccination programs, for among others, Newcastle, Gumboro and bronchitis for one day chick and pasteurellosis for hens, training of personnel, traceability system and independent third-party bacteriology and parasitology analysis (“Laboratoire national d’appui au developpement agricole” – LANADA) are done to ensure efficient implementation of the above mentioned standard. Structural infrastructure and budgetary constraints for transport (separate truck for transport of eggs and one-day old chick) limit, for the time being, the achievement of full achievement of the standard. With the expansion of the hatching unit under the proposed Project, SIPRA is committed to achieve HACCP and ISO 22000 certifications by 2013. On its side, Ivograin was the first feed mill production plant to obtain ISO9001-2008 certification in West Africa in January 2010, which is valid till December 2012. Ivograin has also established a laboratory for analysis and quality control. Finally, CoqIvoire has started to formalize its management procedures for environmental, OHS and food safety. In its 2012 budget, CoqIvoire intends to complete the HACCP diagnostic and successfully complete the implementation of the HACCP corrective action plan and certification. ISO22000 certification is planned by end of 2013.

Going forward, as set forth in the attached Environmental and Social Action Plan (ESAP), SIPRA’s management has agreed to further develop and integrate these Environmental, Occupational Health and Safety (EHS) and food safety management system elements – in line with ISO 14001, OHSAS 18001 and HACCP/ISO 22001 – into an Integrated Management System in compliance with IFC’s PS1 requirements and applicable WBG General and Sector-Specific Environmental, Health and Safety (EHS) Guidelines. The SEMS will encompass all SIPRA facilities and will specify operating policy requirements as well as detailed manual procedures that must be in place for quality control and compliance during operational phases. In particular, certification of ISO 22000 provides assurance that food products placed into commerce are safe and, in the event of report of adulterated food products, the Company can identify affected lot numbers and remove the products quickly. Completion of the Integrated EHS Management and certification of all SIPRA’s facilities with HACCP and ISO 22000 is expected by end of 2013.

Organization. SIPRA has not yet assigned an EHS officer and/or established a stand-alone corporate E&S unit with managerial responsibilities, responsible to senior management, and with assigned responsibilities to supervisors in all SIPRA facilities. For the time being, SIPRA’s President, Managing Director and Operational Directors of Ivoire Poussins, Ivograin and CoqIvoire, assisted by quality officers are jointly contributing to EHS responsibilities but corporate coordination and accountabilities are deficient. As part of its expansion plan, and as spelt out in the ESAP, SIPRA will establish a corporate E&S unit and strengthen its EHS compliance through the recruitment of a full-time and qualified E&S officer whose key responsibilities will encompass the coordination of the preparation and implementation of the Integrated EHS management systems, including ISO 14001, OHSAS18000 and HACCP/ISO22000 standards certification, and supportive procedures manual. This officer will ensure the preparation of the technical file for obtaining the annual operational license at all facilities, including retail outlets, implementation of related corrective actions plans, continuous training of SIPRA employees on EHS issues, coordination of technical and financial proposals for required cleaner production measures at all plants (e.g. wastewater treatment plant in CoqIvoire), support the coordination of the SIPRA’s Occupational Health and Safety Committee (“Comité d’Hygiène de Sécurité et des Conditions de Travail” - CHSCT), and ensure the monitoring and reporting on resource efficiency, through EHS key performance indicators (KPI)s for continuous improvement of E&S performance. This EHS officer will report to SIPRA’s Managing Director and will closely coordinate his/her works with SIPRA’s operational directors and quality officers.

Training. SIPRA adopted a detailed corporate training procedure in 2008 to ensure continuous training, in European and Ivorian institutions, to staff at all levels in all SIPRA’s business entities in order to improve operational efficiencies. As it relates specifically to EHS issues, specialized training has been provided over the last two years for CoqIvoire’s staff, including training courses in 2010 on good hygiene practices and food safety, including independent review of current cleaning practices and deficiencies while awareness training on good hygiene measures in agri-business unit was delivered in 2009. In 2012, the main focus of the staff training in Ivoire Poussins and CoqIvoire will be concentrated on HACCP and ISO 22000 requirements in the context of SIPRA’s commitment to achieve certification in 2013. In addition, Ivoire Poussins is planning to train its employees on L&FS, including 1st and 2nd level intervention and first aid. The objectives of this training are to ensure the efficient prevention of fire hazard and to learn how to control fire event. As set forth in the ESAP, as part of the Integrated EHS management system, the HR Director and the EHS officer will undertake a comprehensive training need assessment of SIPRA’s employees at main job positions to consolidate this training program. SIPRA already recognizes the importance of strengthening the technical capacities of its employees in order to improve regulatory compliance and E&S performance and, ultimately, increase career mobility. The HR Director will be responsible to coordinate the effective delivery of the training plan.

Monitoring and reporting. SIPRA is not presently monitoring or reporting on its EHS performance. This being said, each technical director responsible for SIPRA operations, assisted by quality officers, and the Director of Human Resources for OHS issues, is maintaining statistics on key EHS indicators (resource consumption, OHS incidents, etc.). These are not centrally compiled or used to their fullest in order to inform license renewal process, investment strategy and/or the above mentioned training program. As part of the operational license process, technical inspectors from sector departments are investigating EHS performance of SIPRA’s operations and provide corrective action plan. In addition, commercial customers are also undertaking their own independent assessment of SIPRA’s operations and products. These audits recognize the continuous and positive improvement of SIPRA management in its production process. Key recommendations proposed by the customers’ audits, namely presence of Quality/HACCP manual, key performance indicators on quality and hygiene and traceability system are already addressed by the Operations and HR Directors. The Ivorian Social Security (“Caisse National de Prévoyance Sociale” – CNPS) also undertakes annual legal OHS inspection, including the functionality of SIPRA’s OHS Committee (CHSCT). Full implementation of recommendations is expected within a 6 month period. Going forward, as set forth in the ESAP, SIPRA’s EHS officer will define an integrated EHS report format to report on key EHS performance indicators, including food safety, energy and water consumption and efficiency; air emissions (NOx, SOx, particulates), including GHG emissions, noise, solid and hazardous waste management and disposal, effluent discharges from WWT unit, compliance with OHS mitigation measures from CHSCT and CNPS and on accident rates (lost-time accidents); customers complaints, supplier performance and community engagement activities. SIPRA will report annually to Ivoirian authorities and IFC as part of the Annual Monitoring Report (AMR).

Community engagement. Ivoire Poussins facilities are, for biosafety reasons, isolated from communities, in rural areas. This being said, Ivograin is located in an industrial area and CoqIvoire facility is surrounded by commercial and residential areas. Main E&S concerns from surrounding communities include traffic, solid waste management and disposal, odor, noise and air emissions. SIPRA will define a Stakeholder Engagement Plan, as indicated in the attached ESAP, to strengthen its consultation and communication processes with concerned communities on the E&S risks of its operations.


PS2: Labor and Working Conditions
Human Resources (HR) Policy and Management. As of December 2011, SIPRA reports a total of 520 permanent employees. In addition, 217 temporary workers are recruited through local human resources firms (RMO Sous-traitance). Of the 520 employees, more than 390 are assigned to production, technical support, processing and logistical activities while the remainder is dedicated to administrative functions (e.g. managerial, commercial, marketing, transit, procurement). With the proposed expansion of the poultry production and the retail outlets, it is estimated that 200 jobs will be added to the payroll. More than 12% of SIPRA’s employees are women. During high season, SIPRA also recruit occasional workers who are paid on a daily fee. There is limited staff turnover (1.35% in December 2011 and 9% on an annual basis) explained by the seriousness of SIPRA’s management in fully respecting the provisions of its Internal Regulations and by interesting Company’s salary scale and benefits.

The Human Resource Department comprises its Director and two assistants. In 2012, it is planned to add two HR assistants in CoqIvoire and Ivoire Poussins. This Department is responsible for the development and implementation of a standard set of procedures, the Internal Labor Regulation (“Règlement Intérieur”) that must be followed during human resource management cycle, including recruitment and selection; admissions process and documentation; planning and approval of holidays and time off; attendance and working hours; payment processing, including health insurance and benefits; performance evaluation; training; access to grievance mechanism; disciplinary measures and cessation of employment. The Internal Regulation, the Code of Good Conduct and the Vision and Value of SIPRA are communicated to all new employees during the induction process and a signed acknowledgement of receipt from each employee is requested. The Internal Regulation will be reviewed and updated in order to meet all the necessary requirements as spelled out in IFC’s Performance Standard 2, especially at it relates to formalizing the training plan, including OHS provision based on job risk assessment, freedom of association, and the grievance mechanism. The Internal Regulation is in compliance with Cote d’Ivoire’s Labor Code (“Code du Travail”), including non-discrimination and equal opportunity, and is disclosed in public areas in SIPRA’s facilities. No work is carried in SIPRA facilities by child and/or forced labor while SIPRA is not directly sourcing from primary corn suppliers where child labor is likely to be present. This being said, as set forth in the ESAP, SIPRA will introduce pertinent sections in contracts, in order to ensure that all contractors and sub-contractors are in compliance with payment of workers’ legal benefits; timely payment of wages; OHS regulations, including personal protective equipment (PPE) and ILO Conventions 138 on Minimum Age. SIPRA will contractually ensure and monitor the compliance of service providers to minimum age employment requirements. SIPRA will develop and provide contracting firms with an OHS manual reflecting its own OHS requirements and will include reference to such requirements in contract documents.

In addition to the salary payment (22days/month and depending which regime applies, 40 or 48hours/week), other benefits are provided, including: health coverage, seniority, risk premium, extra hours payment, transport, performance and sale bonuses. Payment to the Social Security is deducted from the workers’ monthly pay to a level of 4.8% for the employees’ retirement plan. In addition, SIPRA has to pay 7.2% of workers’ monthly salary to the CNPS. In addition, there is a 3% for the workplace accidents and 5.75% for family allocations, including pregnancy. The minimum monthly salary in Ivory Coast is presently 18,000 FCFA/month and 36,607 FCFA/month for agriculture and industrial activities respectively. SIPRA’s salary scale is significantly above this threshold. In fact, average minimum monthly salary for SIPRA’s employees is estimated at 57,000 FCFA (excluding bonuses). There are presently 2 shifts of 8 hours at CoqIvoire plant while 3 shift at Ivograin. Changing rooms, toilets and showers facilities are available for workers and respect gender sensitivities. Rehabilitation of these will take place at Ivograin and CoqIvoire based on recommendations of CNPS.
SIPRA pro-actively conducts annual social dialogue with its entire employee to further assess worker satisfaction, working conditions and grievances. This consultation is translated into a report with a time-bound action plan. An informal process also exists for workers’ complaints through either calling, visiting or sending a letter to the HR Director. As set forth in the ESAP, SIPRA will develop and implement a structured grievance procedure for its workers, in accordance with PS2 requirements, including steps to be taken for workers to manifest any concern, engage in a mediation process, contact responsible persons at each facility, and provide feedback. Employees’ awareness raising on grievance mechanism procedure will take place during the worker’s induction session.

Workers’ Organization. SIPRA’s labor, including hiring practices, is conducted in accordance with the Ivorian labor law (Loi N°95-15 of January 12, 1995). The recruiting process at SIPRA involves a background check of diploma, professional experience and a medical test (to be operationalized in 2012 through the recruitment of 3 part-time doctors). In accordance with the Ivoirian Labor Law, the minimum age for recruitment of employees is 18 years which is validated though a birth certificate and national identification card. A Union Agreement (“Convention Collective”), adopted on July 20, 1977 and applicable for indeterminate period applies to all SIPRA employees. A renewed Labor Code is presently under negotiation and should be soon validated. The main unions existing in Ivory Coast are “Union Générale des Travailleurs de la Côte d’Ivoire”, Dignité and FESACI. The affiliation of SIPRA’s workers to these unions is through personnel delegates. SIPRA supports the freedom of association of its workers.

Occupational Health and Safety. SIPRA adopted a general policy on OHS in February 2007 and established, in accordance with Ivorian legal requirements, an internal OHS Committee (CHSCT) which is chaired by its HR Director and composed of the operational directors of Ivoire Poussins, Ivograin and CoqIvoire, a doctor, quality officers and personnel delegates. A plant-level CHSCT at all facilities also exists. A diagnostic of key OHS risk areas was done in 2007. Due to the civil unrest, operational efficiency of this Committee has been limited and, most importantly, necessary mitigation measures have not yet been fully implemented. From September 2011, SIPRA’s President provided new impetus to the CHSCT and monthly site visits to high risk areas are now systematically taken place by CHSCT. The ratio of total lost man-hours due to accident to total man hours worked from 2008 to 2009 has decreased from 0.19% to 0.05%. To date, no fatality has been reported at SIPRA’s facilities. However, as demonstrated by the latest CHSCT’s monthly reports and CNPS’s annual reports, despite continuous and overall improvement of SIPRA’s OHS performance, significant work place safety issues at numerous operations sites still require further attention and will be addressed in the ESAP. Namely, in order to improve OHS performance in all existing SIPRA facilities, SIPRA will: (i) conduct a gap analysis of its OHS policy and procedures against applicable WBG EHS General and Industry-specific Guidelines and present a detailed Corrective Action Plan detailing activities, timetable for implementation and budget; (ii) ensure provision of adequate Personnel Protective Equipment (PPE) to its employees and its sub-contractors; (iii) present a safety plan and chronogram of implementation for safety measures for employee working in high risk areas as stipulated in its 2007 diagnostic; (iv) this safety risk plan will guide the specific general and specific training needs at all facilities. SIPRA will conduct timely implementation of corrective measures to address gaps identified during the review. The Company will present to IFC for review and approval satisfactory evidence that a management system procedure has been implemented to manage OHS, including employee training and PPE, to comply with WBG General and Sector-specific EHS Guidelines. Finally, first aid dispensaries are found at each production site and doctors are available two hours a day. Through the on-going recruitment of part-time doctors at different SIPRA’s operations, SIPRA intends to systematize free pre-employment examinations for all employees and increased health monitoring of its workers at its facilities, as requested by the customers of its products.

Biosafety and avian influenza preparedness and response. Ivory Coast was subject to cases of avian influenza in April 2006 in traditional rearing facilities. No case has been registered in modern livestock facilities. A preventive vaccination program has been enforced. Since 2009, Ivory Coast has been considered free of the disease. This being said, as part of its operational procedures in Ivoire Poussins, a bio-safety protocol has been adopted which includes strict measures to (i) improve and monitor poultry hygiene and health according to the risk and occurrence of diseases during the production process, (ii) establish a traceability system, (iii) ensure poultry products quality for customers. Standardized sanitation and disinfection procedures exist and their use is systematically enforced at all SIPRA’s own poultry rearing units, and at associated poultry producers. Bio-safety procedures include limited controlled site access and suitable infrastructures (e.g. high concrete fences); entrance gate with vehicle disinfection area, cleaning and disinfection procedures for visitors, materials and tools (e.g. foot disinfection at the entrance to sites/houses), control of pathogen vectors (rodents, insects), and organic waste management. Workers’ clothes are kept clean, shoes are scrubbed with disinfectant, and hands are washed. As part of its bio-safety procedures, any sick or dead bird is removed and reported to the veterinarian. Given the potential magnitude and unprecedented nature of the threat posed by avian influenza and to protect its workforce, SIPRA will develop and implement a management system procedure for the avian influenza preparedness and response, including a training plan to ensure that employees are knowledgeable of the preparedness plan for avian influenza and emergency contingency plans. The plan will include: (i) preparedness and prevention, (ii) outbreak response, and (iii) recovery.

Life and Fire Safety. During its OHS risk assessment process in 2007, SIPRA identified numerous operations with fire and explosion risks, including diesel containers in all operations, a potentially explosive environment in Ivograin silos due to dust accumulation, etc. In order to prevent such risks, in addition to the continuous monitoring and recommendations from the CHSCT and CNPS, SIPRA has established contractual agreement with a certified service provider (Sicli Intelec Protection) for fire prevention and control, and regular inspection. Fire alarms and extinguishers are available and properly maintained at semestrial intervals. Fire extinguisher use training is progressively provided to all workers during regular trainings, including the one mentioned above for Ivoire Poussins. Recognizing these continuous improvements, external review from the Ministry of Industry (“Direction des Infrastructures et des Instruments de Developpement Industriel”) in 2008 and 2010, identified some weaknesses, especially the absence of an Internal Operational Plan (IOP) for fire prevention and control, absence of a fire hose and hydrant at Ivograin, deficiency in the electrical boxes, lack of an assigned fire safety officer, etc. A certain number of these deficiencies are in the process of correction by SIPRA, including the preparation of an IOP by 3rd Quarter of 2012, installation of fire hose and hydrant (contract allocated to a service provider), etc. The site visit has identified additional areas where some aspects of the fire protection are deficient (e.g. visible means of egress, emergency lighting and exit signs, fire detection and alarm systems). Coordination with the local fire authorities also takes place. In order to consolidate its life and fire prevention performance, as indicated in the ESAP, SIPRA will develop and implement a management system procedure, in compliance with WBG EHS requirements, to improve implementation of the recommendations at all facilities from its CHSCT and the CNPS, fire safety response procedures, including training on emergency evacuation, use of fire equipment, signalization, and undertakes annual fire drills in all operating facilities.

PS3: Pollution Prevention and Abatement
As part of the development and implementation of its integrated EHS management system and program under PS1, SIPRA will prepare plans and procedures for the management of energy, potable water, liquid and solid waste, greenhouse gases (GHG) emissions and any other key environmental aspects. The plans will include production’s reduction targets for resource use to be monitored annually, based on a proposed resource efficiency assessment which is planned to be conducted by IFC’s Advisory Services and proposed recommendations (e.g. installment of water meters, re-use of chicken litter as boiler fuel, generation of methane by anaerobic bio-digesters from slaughtering wastes, etc.).

Hatchery facility (IvoirePoussin). This facility, situated in Bingerville, include a combination of incubator and hatchery equipment, with a capacity to hatch 18,000,000 eggs per annum. It is equipped with fully digitalized climate control systems to ensure correct process temperatures never exceeding 99.5°F (37.5°C). All chambers have continuous air exchange and operate under strict pathogen free conditions. Water is sourced from a well and annual use is monitored. No water analysis and/or treatment have been done since 2009 due to civil unrest. It is planned to re-establish water analysis and consumption monitoring, at all SIPRA’s farms in 2012. Average total incubation and hatch period for chicken is 21 days. Temperature regulation is the most critical factor for a successful hatch. Variations of more than 1°C (1.8°F) from the optimum temperature will reduce hatch rates. Humidity is also important because the rate at which eggs lose water by evaporation depends on the ambient relative humidity. Once hatched, one-day old chick are vaccinated against Newcastle and Marek disease and sent to the poultry rearing facilities in temperature regulated transport. Wastes from hatchery include broken eggs, chick embryo and eggs shell. These are stored in specific container and transported to Abidjan landfill. In its 2012 investment plan, Ivoire Poussin is planning to buy its own truck for waste disposal from its hatchery and rearing farms.

Poultry parent-stock farms (Ivoire Poussin). These facilities are as isolated as possible for bio-security reasons. E&S impacts from these facilities are minor. SIPRA has developed SOPs, including standard production and bio-security measures, to avoid or mitigate adverse impacts. Technology package dissemination is under the supervision of Dr. Faye, veterinarian, and is supported by a zoo-technician engineer, farm managers and workers. SIPRA poultry production is performed by well-trained staff, with practical knowledge to maintain poultry health and minimize distress. Housing systems allow animals to engage in natural behaviors. Poultry rearing practices comply with IFC’s Good Practice Note (GPN) on Animal Welfare. Well-maintained bedding, feed and water availability, disease control, adequate temperature, ventilation, and humidity are key parameters which are closely monitored. Broiler chickens are controlled against diseases (ref. influenza by PCR method) and vaccines are applied according to an agreed upon prophylaxis plan. For broiler, no antibiotic is provided after the 25th day in order to avoid drug residues in poultry products. No hormones are in use by SIPRA. Only European certified providers and approved antibiotics are applied if a disease outbreak takes place. Overall annual mortality rates at the broiler rearing houses are less than 6%, which is considered excellent. Broiler chickens of 35-42 days are transported to CoqIvoire under a distressed-free environment in compliance with IFC’s GPN on Animal Welfare. Water analysis and consumption from wells is not monitored at associated farm level. As set forth in the ESAP, SIPRA will conduct a full chemical, physical and microbiological assessment of groundwater in all wells and establish quality and consumption baseline for on-going monitoring purposes. If annual assessment indicates deterioration, SIPRA will take mitigation action.

Feed mill facility (Ivograin). The feed mill plant has a capacity of 17 tons/hour (100,000 tons/year). Corn reception silo and cleaning and dryer processing are also found in Yamoussoukro. Key processes include storage silos, conveyors and elevators, screening, sorting, batching machines, milling machines, mixer, dryers and packaging machine. SIPRA is in the process to install safety measures to mitigate explosive (dust) environment, fire, flammable liquid or gas leak, structural and power failure. Annual water consumption is 4,234 m³ and sourced from the municipal adduction system. As mentioned under the OHS section, numerous OHS corrective measures have been identified at Ivograin by the internal CHSCT and the CNPS and will be addressed in the ESAP.

Poultry processing plant (CoqIvoire). Processing operations at CoqIvoire are conducted within good OHS and food safety practices, respecting animal welfare. The plant, established in 1977, has been rehabilitated in order to improve production (through optimization of processing lines design) and bio-safety measures (installation of sanitation barriers upon entries and exists with non-contact hand washing, sanitizing equipments in all processing rooms, and improved refrigeration equipment). There is no rendering plant at CoqIvoire facility. In addition to the training provided in 2009/10 on good hygiene and disinfection/cleansing practices, in the context of its commitment to achieve HACCP and ISO 22000 by end of 2013, further training will be provided to employees on food safety and quality management practices. All equipment is automated, except for few manually assisted operations, such as evisceration, packing and storing. CoqIvoire’s processing capacity is 2,000 chicken/hour. Water consumption is sourced from the municipal distribution system (3,500 m3 in 2010) and an authorized well (2,400 m3 in 2010). Microbiological analysis, by an independent laboratory, is done and corrective action taken, as appropriate. Processing wastewater is presently not treated before discharge to open drains outside of the plant. Based on laboratory data of April 2010, there are significant exceedances of BOD, COD, total nitrogen against Ivoirian and WBG wastewater effluents parameters. In addition, drainage deficiency on the diesel tanks has been noticed. Numerous cleaner production opportunities, especially related to blood collection in the slaughtering area and water use in the cleaning section, have been observed. For the latter, through limited drainage measures, volume of process wastewater to be treated could be significantly reduced.

SIPRA will commission appropriately qualified advice to study opportunities to reduce effluent loading through cleaner production techniques, and also to minimize water consumption and hence discharge. Effluent volume and contamination will be minimized. SIPRA will recruit an expert consultancy firm for an engineering design study for the construction and operation of a wastewater treatment plant whose performance shall meet all effluents parameters found in Table 1 of the WBG EHS Guidelines for poultry processing. As indicated in the ESAP, this study is required to be completed within 12 months of commitment while the commissioning of the WWT plant within 30 months. Sanitary wastewater are presently collected and conveyed in septic tanks which are being emptied on a regular basis by licensed operators.

Energy use and green house emissions. Provision of energy to SIPRA’s operations and administrative offices is secured from the “Compagnie Ivoirienne d’Electricité” (CIE). In the context of the civil unrest in 2010/11, SIPRA has also been using emergency back-up generators used only in case of power shortage. Total annual electricity consumption from the national grid in 2011 is 2,556,000 kWh at IvoirePoussin, 1,200,000 kWh at CoqIvoire, and 1,200,000 kWh while total annual diesel consumption in 2011 is 53,400l at IvoirePoussin, 237,600l at Ivograin and 147,800l at CoqIvoire (7,800l for processing plant and 140,000l for distribution fleet). This energy consumption is expected to increase significantly due to the proposed expansion Project. Given this business scenario, as set forth in the ESAP, SIPRA will implement an energy management plan to improve use efficiency, through data collection, energy consumption/management reports and reduction targets.

Air emissions monitoring. The main source of air emissions are from the two boilers at Ivograin and CoqIvoire and large gensets at Ivoire Poussin (500kVA), Ivograin (800 kVA) and CoqIvoire (500 kVA) that burn diesel to produce electricity, heat and hot water. Both boilers and generators undergo trimestrial maintenance inspection to optimize efficiency. SIPRA do not presently monitor its generators and boilers’ air emissions to ensure consistency with WBG EHS guidelines for point source emissions to air (PM10: 50mg/Nm³; NOx: 460mg/Nm³; SO2: 2,000 mg/Nm³). As set forth in the ESAP, SIPRA will monitor the air emissions and will report them in the IFC Annual Monitoring Report.

Management of solid & hazardous waste. Waste characterization of SIPRA’s operations are composed of the following: 1) Ivoire Poussins - 85% of broken eggs, chicken embryo and egg shell which are disposed at Abidjan’s landfill site; deep bedding materials at rearing facilities composed of wood chips, rice husks, saw dust and chicken droppings which are either given or sold as fertilizer in horticulture and banana and hevea plantations. Dead chicken carcass are daily buried at site in a covered earth pit between two coats of quicklime; 2) Ivograin has limited process waste. More than 300 tons per year of waste (paper, cardboard, on-site food services and maintenance waste) disposed at Abidjan landfill site; 3) CoqIvoire: waste characterized by birds intestines/feather and dead birds or rotten meats. For the former, a licensed service provider comes twice a day for collection and disposal. Rotten meats are sent to a licensed incinerator. Hazardous materials present in SIPRA’s facilities are limited and include cleaning/disinfection products, veterinarian products for prevention and control of poultry disease. SIPRA’s facilities have large diesel tanks (from 10,000 - 20,000l). As set forth in the ESAP, SIPRA will develop a management system procedure to ensure that all solid and hazardous wastes are collected and disposed in accordance with Ivorian and WBG waste management guidelines.

Cooling agents. SIPRA uses HCFC 134a in its refrigeration systems. Annual maintenance of the refrigeration system is done at all SIPRA’s operations, especially IvoirePoussin and CoqIvoire.

Pest management and control. A legally registered company conducts rodent control in all SIPRA’s operations, including poultry rearing units (own and associated), feed mill plant and slaughtering plant. Activities include inspection and maintenance; and rodent and pest are controlled and monitored constantly. Products for rodent control used are listed under WHO Class 1a and 1b chemical formulations. SIPRA will prepare a management system procedure to implement pest and rodent management. The procedure will aim to eliminate the use of WHO Class 1a and 1b chemical formulations in their premises. SIPRA will modify service contracts to require contractors and suppliers for mandatory training to workers and ensure provision of adequate PPE based upon MSDS and/or ICSCs for the materials used. This consideration will be added in employee’s OHS training programs


PS4: Community Health, Safety and Security
Community Health and Safety. Aside from Ivoire Poussins and rearing farms which are isolated from human settlements, there is an obvious growing urbanization process around CoqIvoire (not applicable for Ivograin as being situated in an industrial area). Transport traffic (50/day) does not represent a significant risk for the local population as the road is in poor condition which results in slowing down the speed of the trucks. Given their location within dense urban areas, there is nevertheless significant interaction between SIPRA’s operations and surrounding urban communities. Aside from the potential negative health impact from the wastewater’s effluents and odors at CoqIvoire and the numerous trucks waiting around Ivograin plant, no significant EHS impacts on the surrounding communities have been identified. Transport sub-contractors are requested to produce a validated driver license. CoqIvoire has recruited a logistic officer in 2012 that will develop and implement a driver and transport safety vehicle safety program consistent with the requirements of the WBG’s General EHS Guidelines, as indicated in the ESAP. SIPRA will also conduct studies to confirm that drug residues in poultry products meet the maximum residue limits (MRLs) recommended by WHO and FAO.

Emergency Preparedness and Response. SIPRA has not yet adopted for all its facilities an emergency preparedness and response protocols, procedures and plans. The emergency plans respond to the needs of life and fire safety. SIPRA will submit its consolidated plan for all its production and retail outlets to IFC in order to ensure compliance with WBG EHS requirements. It will develop and implement emergency preparedness and response plans for all its facilities. Emergency plans will respond to the needs of life and fire safety requirements and include training on emergency evacuation, use of fire equipment, and other applicable aspects identified by experienced emergency planning specialists in the planning process. It will implement a training plan to ensure that all employees are knowledgeable of existing emergency procedures and emergency contingency plans, including evacuation routes. It will perform fire drills in all operating facilities.

Community Grievance Mechanism. SIPRA has not adopted a formal Community Grievance Mechanism. Some complaints have been received due to the odors at the CoqIvoire slaughtering plant. As set forth in the ESAP, such a mechanism will be formalized in order to receive and to address any issues and/or complaints raised by surrounding stakeholders and customers, resulting from odor, transport activities, consumption of finished products.

Security Personnel. Security personnel at SIPRA’s operations are being sourced through a licensed service provider. Staffs assigned to security purposes are trained for defensive measures and are not armed.

SIPRA has not yet established a structured Corporate Social Responsibility program. This being said, SIPRA is financing numerous social initiatives, including financial support for village’s infrastructure and/or social-economic and health activities with local schools (e.g. bed nets against malaria); support to funeral services of village members, etc. Socio-economic (employment) and overall developmental impacts of SIPRA (food security and linkage with local farmers), especially where Ivoire Poussins rearing and associated farms are situated, are important.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. SIPRA will be requested to place an advertisement in a local newspaper to inform the public that results from IFC’s environmental and social review and ESAP is available for access on its corporate website or provide a web- link to IFC’s disclosed ESRS and ESAP.

Name/Address

M. Jean-Marie Ackah, Président
La Société Ivoirienne de Productions Animales (SIPRA)
04 B.P. 1664 Abidjan 04, Cote d’Ivoire
Tel: +225 23 53 00 53; Fax: +225 23 46 63 87
E-mail: mailto:jma@sipra.ci; Website: http://www.sipra.ci

SIPRA CI(31422) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
Environmental and Social Management System (ESMS) for Ivograin and Coqivoire. SIPRA shall fully develop and incorporate a Performance Standard 1-compliant Environmental and Social Management System (ESMS) within Ivograin’s ISO 9001 quality management system and extend it to CoqIvoire and to IvoirePoussin operations. The ESMS shall fully incorporate the nine (9) mandatory elements of an ESMS defined in Performance Standard 1. SIPRA shall prepare Standard Operating Procedures for implementation and institutionalization of the ESMS. These procedures shall define the activities required to implement the nine (9) mandatory elements of PS1. The procedures shall designate the organization chart positions (titles) of the individual staff, supervisors and managers, who will be responsible for ensuring that the activities described in the procedures are carried out. SIPRA’s Human Resources (HR) manager shall revise employee job descriptions to incorporate assigned responsibilities defined in ESMS procedures. Furthermore SIPRA’s HR manager shall ensure that periodic employee performance reviews include an evaluation of employee adherence to allocated responsibilities defined in the ESMS procedures.	31-Dec-2017	Completed	Completed	3/1/2018
Environmental and Social Management System (ESMS) for IvoirePoussins. SIPRA shall fully develop and incorporate a Performance Standard 1-compliant Environmental and Social Management System (ESMS) within Ivograin’s ISO 9001 quality management system and extend it to CoqIvoire and to IvoirePoussin operations. The ESMS shall fully incorporate the nine (9) mandatory elements of an ESMS defined in Performance Standard 1. SIPRA shall prepare Standard Operating Procedures for implementation and institutionalization of the ESMS. These procedures shall define the activities required to implement the nine (9) mandatory elements of PS1. The procedures shall designate the organization chart positions (titles) of the individual staff, supervisors and managers, who will be responsible for ensuring that the activities described in the procedures are carried out. SIPRA’s Human Resources (HR) manager shall revise employee job descriptions to incorporate assigned responsibilities defined in ESMS procedures. Furthermore SIPRA’s HR manager shall ensure that periodic employee performance reviews include an evaluation of employee adherence to allocated responsibilities defined in the ESMS procedures.	31-Dec-2018	Completed	Completed	3/1/2018
Environmental and Social Management System (ESMS) Orientation and Training Program. SIPRA shall prepare and implement an ongoing ESMS training program for casual/daily workers, new employees, existing staff, and service contractors. The casual or daily workers training program shall be delivered daily to inform casual or daily workers of their duties, obligations and rights when working on SIPRA property. Casual or daily worker training shall be brief and designed to deliver prior to commencement of shift work. New employee orientation shall be a more detailed training program delivered in separate classes during the employees’ first month to ensure in-depth learning about the ESMS as well as specific duties, obligations and rights when working on SIPRA property. Training programs for existing staff shall be a more detailed training program delivered in separate classes over a month to ensure in-depth learning about ESMS-defined duties, obligations and rights when working on SIPRA property. Training programs for contractors and service providers shall communicate performance and behavior obligations and prohibitions incorporated into the covenants of service contracts. SIPRA management, the SIPRA HR Manager, and the SIPRA Procurement (purchasing) function shall require that all employees and contractors understand that performance and adherence to ESMS procedure obligations and prohibitions shall be considered for conversion of casual or daily employment, permanent employee merit increases and promotions, and renewal of service contracts.	30-Jun-2016	Completed	Completed	3/1/2018
Hazard Analysis and Critical Control Point (HACCP) Food Safety Certification for CoqIvoire. CoqIvoire shall obtain HACCP certification for CoqIvoire poultry slaughterhouse in Abidjan	31-Dec-2016	Completed	Completed	3/1/2018
Human Resources Policy and Procedures. SIPRA shall revise its Human Resources (HR) Policy to incorporate the requirements of Performance Standard 2 Labor and Working and Conditions. SIPRA shall revise its HR Policy to clearly state that equal opportunity and fair treatment of employees is the guiding principle of the HR Policy. The HR Policy shall incorporate all rights and obligations of workers as defined in PS2. SIPRA’s HR Policy shall clearly state that SIPRA shall not make employment decisions on the basis of personal characteristics unrelated to inherent job requirements. SIPRA’s HR Policy shall incorporate guidance and procedures for potential employee retrenchment and these shall be based upon conducting an analysis of alternatives. For any retrenchment SIPRA shall comply with all legal and contractual requirements including notification of public authorities, and provision of information and consultation with employees and their representatives. A complete set of procedures required to implement the revised HR Policy shall be prepared, implemented and institutionalized. For example, SIPRA shall provide all workers (daily, temporary and permanent) with documented information that is clear and understandable regarding their rights under national labor and employment law and applicable collective agreements. This information shall include employees’ rights related to hours of work, wages, overtime, compensation, and benefits upon beginning the working relationship and when any material change occurs.	31-Dec-2014	Completed	Completed	3/1/2018
Employee Grievance Mechanism. As part of the HR Policy and implementing procedures revision, SIPRA shall develop and implement a corporate Employee Grievance Mechanism to raise workplace concerns that complies with the requirements of Performance Standard 2. SIPRA shall inform all employees of the grievance mechanism at the time of recruitment and orientation of daily and temporary workers. SIPRA shall make the grievance mechanism available to all workers. Voiced concerns shall be addressed promptly; and shall employ an understandable and transparent process that provides timely feedback to concerned employees without any retribution. The mechanism shall also allow for anonymous complaints to be voiced and addressed.	31-Jul-2016	Completed	Completed	3/1/2018
Occupational Health and Safety Program Implementation. SIPRA shall provide safe and healthy workplaces at all of its installations. SIPRA shall prepare ESMS procedures to fully implement a robust OHS program that is informed by Performance Standard 2 and the General EHS Guidelines, Section 2, Occupational Health and Safety. SIPRA shall routinely conduct OHS Risk and Impact Identification audits to identify inherent risks in all workplaces (job hazard analysis) comprising specific classes of hazards in work areas including physical, chemical, biological, radiological, ergonomics and specific threats to women. To eliminate identified hazards, SIPRA shall prepare and implement Action Plans describing identified hazards, the required corrective action(s), the SIPRA staff and manager responsible for eliminating the hazard and complying with the mandatory completion date. SIPRA shall take all necessary steps to prevent accidents, injuries and disease arising from, associated with or occurring in the course of work by eliminating or minimizing the causes of hazards. SIPRA’s ESMS procedures implementing OHS shall address (i) Identification of potential hazards to workers; (ii) Provision of preventive and protective measures, including modification, substitution, or elimination of hazardous conditions or substances; (iii) Training of workers; (iv) Documenting and reporting of occupational accidents, diseases, and incidents (near misses); and, (v) Emergency prevention, preparedness, and response arrangements. SIPRA shall train and require that all employees and contractors understand ESMS OHS procedure as well as assigned responsibilities, obligations and prohibitions described in ESMS OHS procedures.	31-Jul-2016	Completed	Completed	3/1/2018
Management of Industrial Effluent from CoqIvoire Poultry Slaughter House. CoqIvoire shall implement a cleaner production program in the poultry slaughterhouse. The immediate needs are to reduce water demand and use, modify solid waste management and to reduce wet cleaning to once/shift. All solid waste on floors and in work areas shall be removed and stored in waste containers. Between shifts cleaning efforts using water to wash wastes into the floor drains shall cease immediately. CoqIvoire discharges its effluents into the City of Abidjan’s municipal sewerage. At present the effluent exceeds allowable limits on various parameters. Implementing the cleaner production/solid waste management program described above and limiting wet cleaning to once/shift may resolve the current suspended solids exceedance. If physical cleaning, water reduction and waste management practices do not achieve effluent compliance with City of Abidjan’s discharge limits, SIPRA shall engage professional assistance to further modify the effluent generation and management system to reduce restricted parameters to comply with permitted levels. SIPRA shall then implement required measures. This cycle of remedial actions and sampling shall be repeated until CoqIvoire effluent complies with municipal requirements.	31-Jul-2016	In progress	Under discussion with IFC Client
Fuel and Liquid Raw Materials Storage Tanks. In order to prevent fuel discharges to public sewerage, storm water and soils, SIPRA shall build secondary containment structures to collect leaks and spills from storage tanks. SIPRA’s impermeable secondary containment shall be constructed to contain 110% of the total volume of Storage Tanks. Structures shall be fitted with roofs or allow for the removal of uncontaminated rain water. The absence of leakages from underground storage tanks has to be verified regularly (at least every two years) using methods such as inventory reconciliation or integrity testing. Underground storage tanks with leakages must be replaced. An integrity testing was done in March 2015 for the diesel underground storage tank in CoqIvoire, which verified the absence of leakages.	31-Mar-2017	Completed	Completed	3/1/2018
Air Emissions Monitoring. SIPRA shall prepare and submit an inventory of all small combustion plants (e.g. electric power generators, boilers, etc.) with 3 to 50 MWTh (megawatts thermal input) and the number of hours of operation/year. For all small combustion plants with 3 to 50 MWTh (megawatts thermal input) and are operated more than 500 hours per year, SIPRA shall conduct air emissions monitoring. The results shall be compared to the allowable emissions considering fuel type defined in IFC’s General EHS Guidelines, Table 1.1.2 Small Combustion Facilities Emissions Guidelines (3MWth – 50MWth). SIPRA shall submit a report of all small combustion plants with the requested data. For any plant with 3 to 50 MWTh, operated more than 500 hours/year, and that exceeds IFC air emission limits, SIPRA shall prepare and implement a corrective action program to bring emissions into compliance with IFC limits and a schedule for implementation of required control measures.	30-Sep-2015	In progress	Under discussion with IFC Client
Integrated Pest Management. SIPRA shall develop an integrated pest management program incorporated into the ESMS procedures. For all observed pest infestations, SIPRA shall identify the pest, its impact and appropriate non chemical means to control. Chemical control methodologies shall be the last recourse for infestation control. SIPRA shall employ all non-chemical means available to reduce the infestation such as total removal of harborage and wastes that attract rodents. Pest Management procedures shall prohibit the use of WHO Class 1a and 1b chemical formulations (respectively extremely and highly hazardous) in its operations. SIPRA shall modify service contracts to require pest management service providers to train its workers and to provide appropriate personal protective equipment (PPE) based upon technical data contained in material safety data sheets (MSDS) and/or International Chemical Safety Cards (ICSCs) for the materials used. Copies of these documents shall be provided to SIPRA. SIPRA’s contractors shall inform SIPRA of intended application activities, associated risks and precautions required to protect employees and food products.	31-Jul-2016	Completed	Completed	3/1/2018
Vehicle Operator Safety Training Program. SIPRA shall develop and implement a vehicle Operator Safety Program for staff and service providers operating vehicles on SIPRA’s premises. SIPRA shall adopt best transport safety practices across all aspects of project operations with the goal of preventing traffic accidents and minimizing injuries suffered by project personnel and the public. Measures should include: Emphasizing safety aspects among drivers; Improving driving skills and requiring licensing of drivers; Adopting limits for trip duration and arranging driver rosters to avoid overtiredness; Avoiding dangerous routes and times of day to reduce the risk of accidents; Use of speed control devices (governors) on trucks; and remote monitoring of driver actions; and mandatory regular maintenance of vehicles and use of manufacturer approved replacement parts to minimize potentially serious accidents.	28-Feb-2016	Completed	Completed	3/1/2018