While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the above Performance Standards.

The land use of the port facility and surrounds are industrial in nature, thus there are no immediate communities (PS4) subjected to the impacts of the activities. PS 5 is not applicable as the state-owned land was provided without resulting need for physical or economic displacement of people. PS 6 is not applicable given the location of the proposed project that has been designated for light industrial or port operations. PS 7 is not applicable as there are no indigenous peoples residing in the project area. PS 8 is not applicable as there are no identified impacts on cultural heritage.

The location for the proposed developments is situated adjacent to the existing port facilities in Port Umm Qasr. Aspects related to the development of the project that can have potential adverse environmental and social impacts are few in number, site-specific, largely reversible and readily addressed through mitigation measures. This is therefore an environmental category B project according to IFC’s Environmental and Social.

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. Gulftainer is a reputable ports management company, and IFC’s review of the current operations of Gulftainer’s facilities in the UAE confirmed that its facility-level procedures and practices are sound. The key issues associated with Gulftainer’s port and inland logistics facilities include corporate capacity to assess and manage the impacts and risks of its operations; labor policies and performance during construction and operation; maintenance dredging and dredge spoil disposal; liquid, solid and hazardous waste disposal; oil/hazardous materials storage and handling; handling and storage of dangerous cargoes; ship support operations, fueling services and spill response; employee health, safety and training programs; and emergency response planning and preparedness. Gulftainer’s plans for managing these environmental and social risks and impacts are summarized below.

Gulftainer is developing the proposed UQLC according to the Iraqi Ports Law No. 21/1995 and the Ports Instructions No. 1/1998; regulations related to the screening, assessment management and monitoring of environmental impacts of its facilities. The Company has signed “Management and Operation Contract of the Dry Port” according to which specific obligation of both the Port Authorities and Gulftainer were established. In addition the company is obliged to comply with the provisions of Iraqi laws, regulations and instructions, and international agreements especially the rules and regulations issued by the International Maritime Organization (IMO) relating to ports. As per the Contract, the IPA provides overall management and operation supervision of Gulftainer’s operation in UQLC.

The Company has management programs in place at its two operations in the UAE and has developed QEHS system consistent with OHSAS 18001, ISO 14001, and ISO 9001 to manage and monitor the construction and operation of its port operations. For its container and cargo terminal operations, Gulftainer demonstrated that it is able to manage port-related environmental, social, health and safety; no significant adverse social impacts have been experienced. Gulftainer is implementing as much as possible EHS procedures in the operations in Iraq. Gulftainer’s OHS officer based in Sharjah regularly visits the operation in Umm Qasr and reports back to UAE management.

During the construction phase the Gulftainer through its main contractor will ensure that the project is developed according to good industry practices and QEHS management system. This will include specific policies and procedures to assess and manage all relevant functions, including any functions that are outsourced as well as all relevant issues covered in PS2 through PS4, such as resources and waste management, accident prevention, occupational health, safety and welfare of the workforce including contract labor; and community health and safety system.

Gulftainer provides training for all employees, contractors and contract workers on these policies and procedures at the time of hiring, with mandatory annual refresher courses. A project management contractor provides oversight for subcontractors’ training to assure that the workers have the skills to perform their activities in a safe, healthy and environmentally responsible manner. All new subcontractors receive an EHS induction prior to starting work, a work-site orientation and on-the-job or formal training prior to being assigned a job. All construction and operational staff undergo OHS training as part of induction. Gulftainer’s internal auditors, established as part of ISO/OHSAS monitoring, conduct regular inspections to assess (non)compliances of their EHS management systems. According to the “Management and Operation Contract of the Dry Port” Gulftainer is obliged to introduce the latest technology to the management of the port, and provide training of a cadre from the IPA on this technology.

Gulftainer complies with all applicable host country labor laws and regulations in all of the countries in which it has operations. The Company has consolidated HR policies and practices into a comprehensive HR manual that applies to all Gulftainer operations and which is consistent with IFC PS2. The corporate HR department oversees all aspects of employee recruiting, hiring, training, evaluation, remuneration and promotion, in conformance with its corporate HR policies and practices. Labor and working conditions policies reference key PS2 principles, including establishing, maintaining and improving employee-management relations; allowing for the formation of worker’s organizations if these are desired by its employees; promoting fair treatment, non-discrimination and equal opportunity of workers; ensuring compliance with national labor and employment laws; promoting safe and healthy working conditions; protecting and promoting the health of workers; and establishing a mechanism that allows employee grievances to be articulated and addressed, as and when they may occur. Gulftainer’s practice in all of the countries in which it operates is to implement wage scales in excess of market standards for all labor categories. In addition, company policy requires that no employee below the legal employment age - or age of 18, whichever is older- may be hired.

Current staff numbers at existing Umm Qasr operations include 107 locally hired and 13 expatriate. All staff live permanently on site and have adequate housing, recreational and prayer facilities are in place, individual internet access and satellite television facilities. All accommodation and utility units are fitted with smoke detectors and emergency lighting which are tested on a monthly basis. There are fire alarm activation points to raise the alarm at strategic points that are also regularly tested. Each of the employees is trained in basic firefighting techniques.

There is some existing construction workforce engaged in completion of certain container handling activities, and more hiring is expected for construction of UQLC. Construction workers will be employed by contractors on behalf of the Gulftainer, and will be sourced primarily from nearby communities, as required by regulations of the respective Government labor departments. The HSES management system will ensure that all construction contracts and subcontracts include necessary clauses to ensure that no contractors’ employee is below the legal employment age, and that construction activities are carried out in accordance with Gulftainer’s HSES procedures.

Construction safety management is the responsibility of the project management contractor who has to ensure that each subcontractor submits, at the tender stage, proof of its good OHS practices in order to be shortlisted for the work. Subcontractors are required to prepare a work method statement for all activities in advance of the relevant activities (e.g., demolition, excavation, electrical work, welding), specifying how to reduce or eliminate potential risks.
All construction and operational staff undergo OHS training as part of induction. The small expat workforce is supported by locally recruited labor who after a safety induction, are trained in their discipline thoroughly prior to being allowed to operate solo on equipment.
Safety induction meetings will be regularly conducted, and incident statistics maintained during both construction and operation. Health and safety advisors will be appointed on the construction site during working hours. The HSE team will hold weekly project progress meetings, including a review of HSE performance. HSE manuals will be translated into Arabic and/or Kurdish as appropriate and made available to all construction workers. Gulftainer will ensure that training is provided for all on-site workers, including truck drivers, and that construction contractors provide all requisite PPE to their workers. These activities have to be conducted in compliance with relevant laws and best practice according to the IFC PS2.

During construction one of the most important safety risks is associated with the presence of unexploded ordnance (UXO) and land mines owing to the historical use of the land during the Iraq war. In order to clear the land Gulftainer commissioned a local licensed de-mining contractor to remove these materials. The contractor provided a certification that the land is free of any war time residuals and cleared for further construction work. Notwithstanding, Gulftainer and its construction contractors will pay special attention in conducting ground breaking works, i.e. work on foundations, reverse rotary drilling method for pile boring if needed.

The main sources of air emissions during construction will be airborne dust pollution from equipment operating on site. Specific measures will be designed for contractor management, with specific focus on excavation activities, truck fleet maintenance, driving behavior and training. Gulftainer will ensure that its contractors use water tankers to control dust if needed.

Storm water and sanitary wastewater generated by UQLC operations will be pretreated and discharged to municipal sewerage system. Storm water will be collected and subsequently pretreated with sedimentation basins and oil/grease separators. Screens will be installed in the sand traps/sedimentation basins to prevent clogging of the system by bulky debris. Gulftainer also intends to install a sanitary waste water recycling facility to obtain water for irrigation of 4000 trees to be planted on site.

Solid waste is generated during the construction and operations, and this may include road litter, illegally dumped waste, or general solid waste from rest areas; and sediment and sludge from storm drainage system maintenance (including sand sediment traps and oil/water separation systems). General waste will be recycled, where possible, sold to vendors or disposed of in designated landfills; septic waste will be sent to a lagoon treatment area. These are both the municipally approved areas for the disposal of such waste.
Management of the waste including oily waste from oil separators will be disposed by the maintenance contractor “Basra Offshore Services" Utility, which is authorized for collection and final disposal of waste. Gulftainer will store containers in accordance with International Maritime Organization (IMO) conventions to prevent potentially dangerous combinations of goods coming into contact with one another.

As it does at its port operations in the UAE and elsewhere, Gulftainer will coordinate with IPA in responding to incidents that occur on the terminal property. The Company will provide an on-site emergency response team that will coordinate its own efforts with IPA authorities, including carrying out jointly-sponsored and staffed fire and emergency response training and drills. Gulftainer will apply its own emergency plans and procedures and the necessary equipment for preventing and containing oil and chemical spills, fires and major accidents during normal operations. The Company’s emergency response program includes appropriate personnel training in emergency response for all employees, quarterly fire drills, and joint exercises with local fire brigades. Customer-identified IMO dangerous and hazardous containers will be transferred to and stored in designated container sheds separated from Gulftainer''s main container storage yard.

As part of its HSES management program, Gulftainer will monitor electricity consumption, in order to identify energy efficiency opportunities. Greenhouse Gas Emissions (GHG) is minimal and limited to fuel used for construction activities and annual maintenance of the UQLC.

Owing to the fact that there are no communities in the immediate area, consultations have been limited to those involving national and local authorities. The Minister of Transportation and relevant stakeholders were consulted and contacted as part of the concession awarding process, and this process was concluded in December 2010. Going forward, Gulftainer will establish a procedure for receiving external communications from the public to account for necessary grievance redress during construction and operation of the Logistics Center.

Gulftainer has an established corporate social responsibility (CSR) program at its UAE operations, including an annual charity golf tournament, the Sharjah Classic, which raises money for charities including the World Food Programme and, in 2010, Haiti earthquake relief fund efforts. Gulftainer intends to implement similar CSR efforts in Iraq, and has begun identifying local non-governmental organizations (NGOs) with whom it can partner to provide support to local schools, orphanages, mosques, and programs for communities impacted by the war. Gulftainer provided the population is the nearest town of Umm Qasr with Water Treatment Kits so as to assist in the supply of safe and decontaminated water supply. Gulftainer also sponsors the local Port football team.

Stephen Ogden,
Group Operations Manager
tel: + 97165724201/2
mob: + 971506265189
PO Box 225, Sharjah, UAE
http://www.gulftainer.com

Mr. Peter Smith
Terminal Manager
Gulftainer Co. Ltd. Office
C/o. South Oasis Co. Ltd.
Next to Minawi Basha Hotel
Basrah, IRAQ
(t): +964 (0) 7703227749

Broad Community Support is not applicable for this project

Current client performance is aligned with applicable Performance Standards and EHS Guideline requirements. No ESAP is required.