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
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is IFC’s first proposed investment in a project with a wild-catch fisheries component since the Performance Standards were introduced in 2006. Due to that precedent, the project has been classified as category A according to IFC’s 2012 Environmental and Social Review Procedure. Category A projects are defined as those which have business activities with potential significant adverse environmental or social risks and/or impacts that are diverse, irreversible or unprecedented.

In view of the complexity and challenges facing the Pacific tuna fisheries, the project team also developed a set of principles to guide its engagement with the Pacific Islands tuna sector where the intent is to support projects that will contribute to improving economic benefit to Pacific Island Countries and the long-term sustainability of the tuna resource. These are described further in the appended SolTuna Project – Update to Stakeholders.

The Project was assessed against the 2012 Performance Standards on Social and Environmental Sustainability (“Performance Standards” or “PSs”). Continuous assessment of potential, additional Performance Standard requirements will be part of the company’s responsibilities through PS1 and where identified, IFC must be promptly informed and appropriate mitigation agreed.The applicability of PS1-6 has been determined through the appraisal process. The population of the Solomon Islands is indigenous, with no group identifying itself in a manner which would trigger PS7 for this project. No cultural property was identified as being impacted by the project in a manner which would trigger PS8.

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.

E&S Assessment and Management System

Given the history of the plant (see Project Description), it was constructed and has been subsequently operated under a number of different management cultures. Since Tri Marine’s investment in 2010 and with it, the effective privatization of the company, SolTuna has sought to formalize its management processes in line with expectations for private sector entities. At the time of this disclosure, there are also a number of personnel changes that will impact E&S management. A summary review of key system elements is provided below, with any gaps identified captured in the appended Environmental and Social Action Plan (ESAP).



Policy

A Company Policy and Procedures Manual was introduced in September 2011, which includes an environment, health and safety policy. Revisions to the policy statement - in order to capture commitments made at the corporate (Tri Marine) level and key principles of Paragraph 6 of PS1 - including E&S performance expectations of primary suppliers - are a condition of IFC’s financing.



Identification of Risks and Impacts

While a number of operational aspects have been reviewed from an E&S perspective, there has been no comprehensive assessment as would be required, for example, by an ISO 14001 type process. The ESAP maps out a number of key risks and impacts identified during IFC’s appraisal and cross references them to actions listed under Performance Standards 1, 3, 5 and 6.



In terms of the project’s area of influence, consideration was given to whether NFD should be considered an associated facility of SolTuna. The IFC appraisal process concluded that it was not, due to the fact that NFD currently sells (frozen, whole round) fish to customers in Bangkok and SolTuna has options to purchase fish from other vendors (albeit negligible volumes in comparison to NFD purchases). NFD is therefore considered a primary supplier - further analysis is provided in the Supply Chain section of PS6.



Cumulative impacts from SolTuna’s processing operation were not considered applicable, given the plant’s location and absence of competing industries at this time. Impacts on the target fisheries are assessed under PS6 - Supply Chain and in the appended Tuna Sourcing and Sustainability Annex.



For the specific assessment of IFC’s financing of the CAPEX plan, the following components will require the submission of E&S risk and impact related documentation, specifically:



- the wharf expansion, that will extend the current damaged wharf from 5m (majority) to 18m (international jetty section) on the seaward side, with piling and backfill to reclaim behind. The reclaimed land is owned by the Solomon Islands Port Authority and the project may require the submission of a full environmental impact assessment (EIA) to the Ministry of Environment, Conservation and Meteorology. The need for, and requirements of an EIA will be determined by the Ministry in response to the initial developmen
t application. SolTuna will also ensure that the EIA scope of work will also reflect IFC Performance Standard requirements and be undertaken by a suitably experienced and qualified professional;



The same determination process by the SI government – and need to reflect IFC requirements – will also apply to:



- the bulk diesel storage facility: see PS3 for further details;



- the waste water treatment plant: see PS3 for further details;



- the new accommodation units: see PS5 for further details.

Management Programs

The ESAP requires SolTuna to formalize its E&S management programs to meet the expectations of PS1. The plant operates a HACCP program and is subject to phyto-sanitary accreditation by the European Union (for exports to) and by the Solomon Islands Competent Authority. Several of the ongoing CAPEX items being implemented related to HACCP/phyto-sanitary improvements, including address and close out of documented non-conformities. SolTuna and IFC have agreed that the plant should be certified to a recognized Global Food Safety Initiative (GFSI) system by an independent third party accreditor (in process – initial audit scheduled for April 2013).



Organizational Capacity and Competency

At the time of this disclosure, a new management structure is being implemented at SolTuna. A Managing Director has been appointed - a Solomon Islands national and former General Manager at NFD. His management responsibilities include high level liaison with the Solomon Islands National Workers Union (SINWU - see PS2 for further detail). A new General Manager came into post in December 2012 with responsibility for day-to-day operations (including E&S aspects) and CAPEX upgrades. SolTuna staffing also includes a Human Resources Manager (see PS2), a Health and Safety Officer (see PS2), a Community Affairs Officer (jointly with NFD - see PS4) and an Administration Manager who takes lead responsibility on securing leaseholds for the land required for new housing (see PS5).



At corporate level, Tri Marine appointed its first director for environmental policy and social responsibility in January 2013. Based in TM’s headquarters in Bellevue in Washington State, USA, objectives for the first year include the formalization of company policies at the corporate level.  In due course, these will be implemented at the operating company level.



Emergency Preparedness and Response

There is currently no formal emergency preparedness and response system in place for the SolTuna facility. The need to develop one is captured in the ESAP, which will address current risks (e.g. earthquake, tsunami, fire) and future risks (e.g. from the bulk diesel storage) as such facilities are constructed and become operational. Due to the physical continuity between the sites, the system will need to be developed in collaboration with NFD. Other relevant parties, such as local government, should also be consulted. Community safety aspects are addressed under
PS4.



Due to the high number of staff in relatively contained (processing) areas, the emergency preparedness and response system will need to ensure that adequate measures are in place to allow for rapid evacuation from such areas in the case of fire or similar situation. The lack of multi-story buildings on the SolTuna site (none exceed three stories) will assist in this process. Risk assessment, prevention and emergency preparedness and response is also required for SolTuna housing (owned and leased). See PS2 for further details.



Monitoring and Review

There is currently no formal monitoring and review procedure to assess the effectiveness of the SolTuna E&S management program. IFC has recommended to SolTuna that an E&S Review Committee is created, which takes management level oversight of E&S program design, performance of and resources assigned for (1) direct operations; (2) indirect operations (particularly through fish supply/primary suppliers) and (3); implementation of TM corporate policy requirements. The Committee should be chaired by the CEO with representation from the management of relevant departments and NFD. See the ESAP appended to this document for further details.



Stakeholder Engagement

There are no directly Affected Communities in relation to SolTuna’s processing operations, as the facility is situated at sea level with Noro town located on the hillside above it. SolTuna does own and lease housing within Noro, and given the absence of any other major employer, Noro has features of a ‘company town’, with the majority of the residents directly or indirectly employed by SolTuna (and/or NFD).



A joint SolTuna-NFD Community Affairs Officer was appointed into post in September 2012, with a mandate to maintain strong community relations and ensure community concerns and needs are pro-actively heard and where possible, addressed. SolTuna receives support from some of its key customers in this respect - for instance in relation to education programs (see Client’s Community Engagement section for more details). The Community Affairs Officer will also formalize, implement and communicate a community-focused grievance mechanism, including ongoing reporting on issues identified as a concern.



The households currently on land plots that SolTuna wishes to lease for housing developments and buffer zones (see PS5) are considered significantly adversely affected by IFC’s investment and therefore a process of Informed Participation and Consultation would be required if SolTuna’s lease requests are approved. This can be integrated into the Resettlement Action Framework/Plan development process as described in greater detail in the PS5 section.

Working Conditions and Management of Worker Relationship

Human Resource Policies and Procedures

The current Policies and Procedure Manual was implemented in September 2011 and covers the core labor and working conditions aspects outlined by Solomon Islands law and PS2. It was updated in January 2013 to strengthen commitments to management-related aspects e.g. training and development, productivity schemes/bonus mechanisms. This was undertaken by the HR Manager (who joined SolTuna in September 2011 after many years of experience in both the private and public sectors), with input from Tri Marine’s corporate VP for HR.



Workers are not automatically provided with documented copies of their rights under national labor laws and collective agreements, but at their induction they are briefed at induction through a (Power Point) presentation that describes such and copies are provided on request. The collective bargaining agreement (see below) also outlines worker rights and it is provided to all workers, whether they are union members or not.



Working Conditions and Terms of Employment

SolTuna management signed the first collective agreement with the Solomon Islands National Union of Workers (SINUW) in April 11, 2012. The agreement addresses twenty areas covering core working conditions and terms of employment.



Due to a degree of unpredictability in SolTuna’s staffing needs (as production is dependent on adequate fish supply) the collective agreement outlines procedures for ‘Interruptions to Work’. This specifies that staff will be paid if they arrive for roll call but for circumstances outside SolTuna’s control, no work is available. If, however, SolTuna provides prior notice (24 hour notice) of no work being scheduled, no pay is due. The latter provision has not been used extensively to date but was agreed with the union as a necessary provision in order to manage SolTuna wage costs (and therefore long term viability of operation). Redundancy is also covered, based on national requirements (Employment Act of 1981).



Appendix III specifies wage structure and benefits. Three classes of worker are recognized: unskilled, semi-skilled and skilled and 8 grades of competency.



All SolTuna hires are permanent, direct employees, with set salary and benefits and a three-month probation period. The current HR policy specifies that all fixed term contracts (one year duration) will be converted into permanent contracts (process recently completed). 40 hours/week are the expected hours, with overtime permitted per week up to the 12 hours maximum specified by SI law.



Allowances and benefits detailed in Collective Agreement include:

- Housing/accommodation (including utilities subsidy); (if SolTuna does not provide accommodation, then 20% of base salary is provided as a subsidy)

- Paid annual leave;

- Paid sick leave;

- Maternity leave;

- Compassionate leave;

- Redundancy;

- Education allowance;

- Daily transport;

- Annu
al leave travel;

- Meal during working hours;

- Healthcare services from Company clinic.



Migrant workers are defined by the Company as those not from Western Province and currently stand at 30%. This is a reverse from the situation prior to 2011, when a concerted effort was made to increase local recruitment (as part of a broader community development initiative for Western Province).

No distinction is made between non-migrant and migrant workers (although the latter receive higher repatriation benefits e.g. annual leave travel costs).



Worker accommodation

SolTuna currently has 134 housing units for workers and their families, comprising:

- family units in ‘Okinawa houses’ (former fishermans’ houses) with up to six families per unit and 6 family members (i.e. 4 children). These will be converted into single person units once new family accommodation is built. The units are old (constructed in late 1980s) and therefore their overall condition relatively poor;

- family units in provincial housing. These are rented from Western Province government and are newer than the Okinawa units. SolTuna provides some of the basic site services e.g. refuse collection;



- hostel for women only. 240 bed capacity (6 per room) on a self-catering basis within a communal dining room. The unit is well maintained (cleanliness/hygiene) but some infrastructure repair required (e.g. replacement of wooden steps). SolTuna covers all costs except food. No water in showers (but very clean). Replace steps/some maintenance needed. Up to six per room but at present more like three;



Accommodation is provided free of charge to workers – with the Company also paying utilities. If SolTuna does not provide accommodation, the employee receives 20% of base salary as subsidy toward housing. Housing/Accommodation is specifically addressed in the Collective Agreement.



As part of the CAPEX that IFC proposes to finance, 20 staff houses and 2 management houses will be added to the housing inventory.



Assignment/selection criteria for accommodation will be captured in a formal procedure, which will also address issues of non-discrimination and equal opportunity. A review of existing housing stock to inspect and where necessary rectify unsafe conditions (e.g. electrical wiring) will also be undertaken by the Company, together with a reiteration to tenants of their obligations to maintain accommodation and report any malfunctioning services or unsafe conditions. See ESAP for further details.



Workers Organizations

Approximately 50% of the SolTuna workforce are registered members of the Solomon Islands National Union of Workers (SINUW), based in Honiara. As described previously, the collective agreement in place with the Union is applied to the entire workforce, however, as its content aligns strongly with SolTuna’s HR policies and procedures.



A SolTuna Workers'' Committee has been established but given the unionization of the workforce is relat
ively recent (the Recognition Agreement was signed in September, 2011), it remains in ‘start up’ phase. In addition, the composition of the Committee was affected by the wildcat strike action that took place in September 2012, which focused on a backdated pay dispute. The strike resulted in a direct loss of production but part-processed tuna was also lost, resulting in consequential drop of the volume to tuna ready to process once the strike was resolved. As part of the review of the incident, SolTuna undertook a number of workforce measures, including disciplinary action; performance review; job function review and redundancy. SINUW collaborated on aspects of the review and agreed to jointly run an education/awareness program for workers on the procedures to follow for legal strike action. This is captured in the ESAP. The new Managing Director of SolTuna also has been assigned management oversight for SolTuna-Union-worker relations, with the goal of open, effective working relationships.



Non-Discrimination and Equal Opportunity

SolTuna reached a peak of 1,515 employees in August 2012, with 800 engaged in processing. Under the proposed capacity expansion, it is projected that the workforce could reach 2,000.



October 2012 data indicates 1,473 employees, of which 912 (63%) are women, reflecting the weighting of women in processing tasks. Women are currently less well-represented in supervisor and management roles in the Company. A career incentive plan for women workers, with the strategic goal of increasing female representation at supervisor and management levels, is captured in the ESAP.



Pre-employment medical checks include a medical screen. There are no limitations other than standard fit-to-work criteria (e.g. adequate eyesight to undertake the task safely). Literacy is not a condition for employment. The HR Manager is currently assessing the employment opportunities that could be promoted to the disabled community.



Retrenchment

Retrenchment is not currently covered within SolTuna’s P&P Manual, but is covered (in part) in the Collective Agreement. The need for a policy is captured in the ESAP.



A retrenchment was initiated in November 2012, for the reasons described under Workers’ Organizations. A total of 70 staff were affected (55 positions were made redundant and 15 employees retired). To identify workers to consider for redundancy, the criteria are sent to department managers and include an assessment of job need; past performance/work quality and length of service. As the retrenchment occurred concurrently with some dismissals (for breach of employment contract conditions), the risk of confusion between the two processes was elevated. The ESAP requirement to develop a formal retrenchment policy should reduce this risk going forward.



Grievance Mechanism

There is a Grievance Procedure specified as part of the Disciplinary Measures section of SolTuna’s P&P Manual and a clear articulation in Section 17 o
f the Collective Agreement. It defines a four stage process, including engagement of the Workers’ Committee if it cannot be resolved with immediate supervisors. The collective agreement allows for dismissal without notice in extreme circumstances, with an appendix laying out the working rules, including offenses that lead to disciplinary procedures. There is currently no mechanism in place for the submission of anonymous complaints.



As part of induction training, the HR Manager is looking to build up communication/awareness about employment terms and grievance options available to them. The need to formalize and effectively communicate grievance mechanisms will also be addressed as a condition of IFC’s financing.



Protecting the Workforce

Child Labor

The minimum age for employment at SolTuna is 18. A prior policy to permit employment at 16, providing one of the parents was also working in the plant has been discontinued. The goal was to provide the family with sufficient income to allow a return of the minor to full-time school, but was only sanctioned on three occasions. SolTuna employs no forced labor.



Occupational Health and Safety

SolTuna employs a Safety Officer (commenced January 1, 2012) and has established a Safety Audit Committee. A 2013 work plan for OHS has been developed, with a focus on the implementation of an effective incident reporting system (including near misses), more consistent (and correct) usage of Personal Protective Equipment (PPE), introduction of a workplace risk assessment process and improvements to fire prevention and fire response (equipment and training).



At present, SolTuna only keeps records for reportable Lost Time Accidents under SI law (LTA > three days). In 2012, there were no fatalities and 13 LTAs, comprising slips, crush injuries, cuts and steam burns. This was an increase on the 2011 LTA total of 11 but the more systematic approach being promoted by the Safety Officer should reduce workplace risks and the corresponding numbers of LTAs.



Workers Engaged by Third Parties

SolTuna employs no contract workers in core operations – all are direct employees. See Working Conditions and Terms of Employment section above.



The improvements IFC will be financing and the broader CAPEX program will entail contractors being on site (e.g for the wharf extension, housing development and waste water treatment plant construction). Inclusion of SolTuna’s environmental, health and safety (and for housing development specifically, social) expectations will be included in job specifications/work orders.



For parts of the site and/or facilities shared with NFD or where NFD employees take primary responsibility for operational management and maintenance, SolTuna will also communicate such expectations.



Supply Chain

SolTuna’s primary supplier is NFD (see PS1 and PS6 for further details). The minimum age for employment for NFD is 18. All boat based crew (approximately 220) undertake I
MO Basic Seaman training, which includes basic occupational health and safety aspects.



NFD’s accident reporting mechanisms are detailed for its vessels (part of the captain’s logbook) but informal for shore/wharf based operations, including unloading when often casual labor is employed (often up to 30 persons). A fatality was recorded in 2010 when a casual worker suffocated while cleaning out a fish well on board a purse seine vessel. There is no formalized review of accident data/LTAs and SolTuna, through the management influence it holds, will request NFD to undertake such going forward.



In 2012, NFD also was allocated 50 licenses for long line vessels (LLVs). PS6 provides further details of this arrangement but given that NFD is the license holder, child labor, forced labor and health and safety aspects of NFD-licensed LLVs is a valid supply chain issue under PS2. The majority of the current NFD licensed LLVs are Taiwanese-registered, typically with Taiwanese captains and Indonesian crew. The need for primary suppliers – including LLVs licensed to NFD - to verify the absence of child and forced labor and to demonstrate health and safety management is addressed in the ESAP.



With the increasing number of LLVs entering Noro to offload, SolTuna and NFD have initiated a sexually transmitted disease education program for crew, shore-based workers and Noro residents.

Resource Efficiency

The Noro facility was initially developed in 1971, and together with neighboring NFD operations, the site infrastructure has grown opportunistically to respond to market and operational needs. It has also been subject to physical damage through earthquake and tsunami. IFC’s proposed investment centers on helping the Company upgrade a number of key facilities, as part of a broader infrastructure improvement plan that commenced in 2011. These upgrades include measures to address the expectations of PS3.



Greenhouse Gases

In 2012, the Noro plant consumed 4,659,828kW(h) of electricity, generated from 3 generators rated at 800 kW(h) each that comprise the on-site diesel-powered captive power plant. The plant also supplies power to the entire Noro community under an agreement with the Solomon Islands Electricity Authority.



Energy consumption corresponds to 1,388 MJ/mt of raw fish processed, which is above the 350 MJ/mt target for contact freezer type processing specified in the relevant IFC EHS guideline, although a direct comparison is not truly valid as SolTuna processing comprises a number of different options (canning, frozen loins and in the future, fresh and blast frozen), each with differing energy performance metrics. A cleaner production audit, focusing on energy and water use, is part of the ESAP for this Project.



Total GHG emissions from existing SolTuna operations are estimated at approximately 7,000mtpa. As such, the proposed expansion will still see emissions below the 25,000 mtpa CO2e threshold that triggers direct emissions quantification under this Performance Standard.



Water Consumption

Fresh water is sourced from the mains/municipal supply and from a number of boreholes on the hillside above the northern end of the plant. The abstracted groundwater is hard (i.e. high mineral content) and therefore used primarily for cleaning purposes. In order to create a buffer zone around the boreholes, SolTuna has asked the Western Province government to lease to them the relevant land parcel. Refer to PS5 and ESAP for further details of the significance of the land parcel/proposed buffer zone.



Based on purchased water, SolTuna currently uses 4.6 m3/mt, which is below the 5-11m3/mt target in the IFC EHS guideline for fish processing. This however excludes (unmetered) borehole water, so the m3/mt will be higher when this is included. A cleaner production audit, focusing on energy and water use, is part of the ESAP.





Pollution Prevention

The key pollutants generated from SolTuna operations are air emissions from the captive power plant and wastewater from processing operations. All organic solid waste (i.e. fish offcuts, bones and other unused parts) provide the raw material for the fishmeal plant and as such, there is minimal solid waste produced.



The captive power plant is comprised of 3 diesel burning units, served by a stack of 11 m in height. No air emissions monitoring has been unde
rtaken to date and the performance guarantees of the equipment supplier are unknown at this time. One boiler was recently replaced and a recovery blow down heat exchanger and a stack economizer installed.



As the only significant industry in Noro, coastally located in a remote, marine archipelago, it is highly unlikely emissions from the power plant have any adverse effect on airshed quality, nor are there sensitive environmental or social receptors in the immediate vicinity that could be directly impacted. SolTuna will however undertake air emissions monitoring and submit the results to IFC as part of its first annual monitoring report.



There is no current operational waste water treatment plant (WWTP) serving the Noro facility. A former unit (providing basic primary treatment) was damaged beyond repair in the 2007 tsunami.



Part of IFC’s proposed financing will be directed toward the construction and operation of a new WWTP. At the time of this disclosure, it remains at a relatively early planning stage, with no formal site plans drawn up. The CAPEX for the plant and related civil work has been assigned, however, and expressions of interest from qualified contractors sought. The WWTP design is likely to replicate that installed by TM at their processing plant in American Samoa (but on a smaller scale to match SolTuna processing capacity), which utilizes dissolved air flotation (DAF) treatment technology and which meets the water quality guidelines of the U.S. Environmental Protection Agency (EPA). The current proposed location for the WWTP requires the wharf re-construction to be completed before it is viable: as such the WWTP will likely come on in Q3 of 2014, after a nine-month construction period. Sludge disposal options will be assessed as part of the detailed WWTP planning.



The performance expectations (COD, BOD, TSS) of the DAF treatment option in terms of wastewater flows is not available at this time due to the early stage of the project. Although the treated water will meet EPA parameters, it is likely to exceed the WBG Environmental Health and Safety Guidelines for fish processing (250mg/l, 50mg/l and 50mg/l respectively). As part of the detailed design work, the treatment specifications will either need to be amended in order to meet guidelines limits or, if a deviation is sought, SolTuna will be required to demonstrate, through an environmental assessment process, that (1) the increased levels of discharge will not result in the degradation of the existing ambient conditions in the receiving marine ecosystem and (2) that alternative treatment options are not viable within the physical project site and/or fail accepted cost-benefit criteria for Good International Industry Practice.

Hazardous Materials Management and Safety

The construction of a 3,200 m3 diesel storage facility - to serve both SolTuna and NFD (boat refuelling) - is part of the proposed IFC financing. The facility will be built on the SolTuna site, but NFD staff will be responsible for its management and maintenance. The storage facility will be constructed in accordance to a number of internationally recognized codes, including AS 1692 - Steel tanks for flammable and combustible liquids and AS 2885 - Pipelines—Gas and liquid petroleum. 



An existing interceptor, which served a (now decommissioned) Solomon Islands Electricity Authority plant, will be renovated to serve the storage facility (e.g. draining of rain water from within the secondary containment area).



Through bulk purchase and storage, SolTuna and NFD will benefit from reduced costs for diesel for their own operations and NFD will be able to offer (long line) fishing vessels competitive re-fuelling rates. The latter is crucial in order to attract more boats to unload at Noro and in doing so, assure an adequate albacore supply to SolTuna.



Community Exposure to Disease

SolTuna is actively seeking to increase its local workforce (see PS2) but continues to rely on labor from other provinces in the Solomon Islands. All new employees are subject to medical screening for communicable diseases that could compromise SolTuna operations. SolTuna provides a clinic service, staffed by 1 doctor part time and 2 nurse aids, and is available to all SolTuna employees and their immediate family members. There is also a clinic located in Noro staffed by a registered nurse providing medical services to all residents. A hospital staffed with doctors and nurses is located in Munda. In addition, the SolTuna-NFD Community Affairs Officer (appointed in September 2012) plans to strengthen community education programs in relation to family health issues (e.g. STDs, road safety awareness, good hygiene practices).



Emergency Preparedness and Response

The need for SolTuna to establish and maintain an emergency preparedness and response system is addressed under PS1 and in the ESAP. In terms of risk to Affected Communities, the distances involved between the SolTuna/NFD site and nearest communities make it unlikely that any direct community impact (as envisaged by PS4) would occur, even under a worst case scenario (e.g. a catastrophic fire or the failure of the diesel bulk storage tank).



Security Personnel

Security personnel are employed to patrol the SolTuna and NFD sites. These are direct employees and carry no weapons. Background checks are undertaken prior to employment. No complaints have been received to date about the conduct of security personnel, but as described in the Stakeholder Engagement section of PS1, The Community Affairs Officer will also formalize, implement and communicate a community-focused grievance mechanism, including ongoing reporting on issues identified as a concern.

Protection and Conservation of Biodiversity

The SolTuna plant is located in an industrial area (albeit small in size). SolTuna operations have been ongoing for over forty years and therefore modifications to original habitat (e.g. through the development of its coastal strip) are not recent. The proposed improvements to the wharf – which will extend the current wharf by 5-18m on the seaward side – are therefore not anticipated to cause any adverse impact to any areas of high biodiversity value, although an impact assessment to demonstrate such will be required before work commences (see PS1). Similar requirements apply to the waste water treatment plant and other CAPEX projects for which IFC financing will be used. Biodiversity reviews undertaken to date do not indicate any protected or sensitive habitats in the immediate vicinity of the SolTuna plant.



Supply Chain

At present, all the tuna processed by SolTuna is supplied National Fisheries Developments Ltd (NFD), effectively a ‘sister company’ which is owned and operated by Tri Marine (the majority shareholder of SolTuna). NFD’s on shore facilities in Noro are located adjacent to those of SolTuna. PS1 describes the relationship between NFD and SolTuna in more detail.



NFD supplies SolTuna with skipjack, yellowfin, albacore and bigeye tuna, sourced using its fleet of five purse seine vessels and two pole and line vessels (with two others under refurbishment). It also handles (albacore) tuna landed to its Noro base by foreign longline vessels, which are also sold to SolTuna. A small, community based handline operation for larger yellowfin and bigeye to serve the fresh and frozen (sushi) market is also proposed, once new freezing capacity is on line and improvements to Munda airport are completed. About 95% of NFD’s catch from its own fleets is from within the waters of the Main Group Archipelago, where commercial tuna fishing is reserved for domestic vessels landing tuna for local processing.



NFD is therefore considered a primary supplier and further, one where the relationship between the two companies provides SolTuna with a high degree of management control and influence. The Tuna Sourcing and Sustainability Report, appended to this document, provides detail of IFC’s appraisal of the supply chain aspect of PS6 and in particular, assessment against the criteria for (i) supply origin and habitat affected; (ii) supply chains mapping and review; (iii) demonstration of not contributing to significant conversion of natural and/or critical habitats (including third party certification options) and (iv) actions to improve the E&S performance of NFD operations over time.



The supply chain implications of SolTuna’s proposed expansion to 150mt/day are also assessed within the Report. From a Solomon Islands’ fisheries sustainability perspective, the increase in volume required by SolTuna will arise through SolTuna securing a greater percentage of the existing catch, rather than
a significant increase in total catch (from 15.6% to 22% of the total Solomon Islands tuna catch by 2019). This is consistent with the Solomon Islands management plan of limiting effort and increasing local processing.



Seven actions are included in the ESAP to implement the recommendations of the Report. These include improving identification and monitoring of by catch (purse seine and longline operations); mapping of bait fishing areas (for pole and line operations) against marine protected areas; Marine Stewardship Council (MSC) pre-certifications for all three fishing types (purse seine, pole and line, longline) and supporting the Ministry of Fisheries and Marine Resources in the implementation of the Solomon Islands Tuna Management and Development Plan (provided as an annex to the Report).



A number of NGO stakeholders were consulted during the supply chain appraisal and invited to provide feedback. The key issues raised were:

- the imperative to restrict effort and overall catch with key management recommendations of the implementation of reference points and harvest control rules. Whilst most NGOs are of the view that skipjack, yellowfin and albacore stocks are healthy, their status could change if effort is not reduced;

- bycatch of non-target species, particularly by longline tuna vessels;

- concern of the overfishing of bigeye and greater effort directed to a coordinated approach to reducing bigeye mortality; and

- the importance of Marine Protected Areas (MPAs) and that some areas should be off limits to fishing.



The consultation brief is appended to this document.

A joint SolTuna-NFD Community Affairs Officer was appointed into post in September 2012, with a mandate to maintain strong community relations and ensure their concerns and needs are pro-actively heard and where possible, addressed. SolTuna receives support from some of its key customers in this respect - for instance in relation to education programs (e.g. construction of a school hall, provision of a computer training facility).

SolTuna sponsors a number of community events as part of its outreach/support work, including World Tuna Day and the Lagoon Festival which are other community outreach/support initiatives. The Community Affairs Officer sees such work as part of an ongoing effort to change the perception of SolTuna/NFD as primarily ‘charity providers’ (e.g. donations of tinned product) to an active, engaged member of the Noro and wider Western Province community.

Mr. Adrian Wickham
Managing Director
SolTuna Limited
1 Tuna Drive, Noro
Western Province, Solomon Islands

Tel: +(677) 61084
Fax: +(677) 61029
E-mail: mailto:aewickham@trimarinegroup.com
Website: http://www.trimarinegroup.com

Broad Community Support is not applicable for this project

Ref	Action	Timeline
	PS1: Assessment and Management of E&S Risks and Impacts
1	E&S Assessment and Management System SolTuna will establish, implement and maintain an environmental and social management system (ESMS) appropriate to the nature of its operations and level of E&S risk (including those through its primary suppliers). The ESMS will incorporate (i) policy; (ii) identification of risks and impacts; (iii) management programs; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) stakeholder engagement and (vii), monitoring and review. For ESMS aspects in relation to primary suppliers, also see PS6-1 through PS6-7..	Plan: end July 2013 Subsequent updates: via Annual Monitoring Report (AMR)
2	Identification of Risks and Impacts - For SolTuna operational risks and impacts: see 1, 4 and 14; - For SolTuna risks and impacts through primary suppliers and other third parties (i.e. paragraphs 8-11): see 16-22 - For SolTuna risks and impacts in relation to disadvantaged or vulnerable individuals or groups: see 15 and 15a.
3	Organizational Capacity and Competency SolTuna to provide job descriptions and organogram to show how E&S responsibilities will be assigned at plant level, including those for Managing Director; Plant Manager; Maintenance Manager; Safety Manager; Community Relations Manager and HR Manager.	Plan: end July 2013 Subsequent updates: via Annual Monitoring Report (AMR)
4	Emergency Preparedness and Response Through its ESMS and in collaboration with relevant third parties (e.g. government, NFD), SolTuna to establish and maintain an emergency preparedness and response system, to address scenarios including earthquake; tsunami and catastrophic failure of bulk fuel tanks. Benchmarks to include IFC Performance Standards and the WBG General EHS guideline. Scope of EPRS, work plan and implementation timetable EPRS initial implementation	End July 2013 End December 2013 Subsequent updates: AMR
5	Monitoring and Review SolTuna to establish an E&S Review Committee. Oversight on programs, performance and resources assigned to E&S impacts from direct operations (including cleaner production) and indirect, particularly through fish supply chain/primary suppliers. Also other requirements as specified in paragraph 24 of PS-1.	Establishment: end July 2013 Subsequent updates: minutes/actions kept on file: attach as Annex to AMR
	PS2: Labor and Working Conditions
	Working Conditions and Management of Worker Relationship
6	Accommodation assignment process - establishment of a formal procedure which explains selection criteria for company accommodation, addressing the issues of non-discrimination and equal opportunity.	End December 2013 or commencement of work on housing project, whichever is earlier Status/implementation updates: AMR
7	Review of current housing stock (especially Okinawa housing): inspect and rectify for unsafe wiring, broken or poorly functioning services (e.g. plumbing, running water). Communicate expectations to tenants on their responsibilities in relation to maintenance and safety concerns (e.g. structural defects, malfunctioning services, pest infestation).	End November 2013
8	SolTuna and SINWU officials to deliver training to workers on grievance mechanisms and process.	End November 2013
9	SolTuna career incentive plan for women workers: with the strategic goal of increasing female representation at supervisor and management levels.	Initial plan: end November 2013 Status/implementation updates: AMR
10	SolTuna retrenchment policy - creation of, to detail process/with clarity on process (including analysis of alternatives). Criteria to reflect expectations of PS2.	End November 2013 Status/implementation updates: AMR
	Occupational Health and Safety
11	SolTuna OHS monitoring: commence tracking of non-reportable accidents (<3 days) and near misses. OHS analysis, trends and recommendations (e.g. for preventative actions) to be submitted to E&S Review Committee as a standing agenda item.	First submission by end November 2013 Status/implementation updates: AMR
	Workers Engaged by Third Parties
12	Supply Chain Develop and implement a procedure to address child labor, forced labor and health and safety aspects of primary supplier operations. To include:  verification/assurance of minimum age of employees;  verification of nature of work for any employees under the age of 18;  verification that no forced labor used;  health and safety procedures (including training) to prevent life-threatening situations e.g. unloading (boat and wharf), tank clean out. Provision of primary supplier H&S monitoring data (e.g. fatalities, lost time accidents, accident frequency (accidents per 10,000 hours worked), corrective and preventative actions taken.	Policy developed by end July 2013 Status/implementation updates: AMR
	PS3: Resource Efficiency and Pollution Prevention
	Resource Efficiency
13	Waste water treatment plant: confirmation of design (including performance parameters), construction timeline, sludge disposal and projected date for coming on line/fully operational. Final design of WWTP, including analysis against performance indicators and monitoring criteria in the WBG EHS guideline for fish processing (and impact analysis to justify any proposed deviation from such).	End July 2013 End December 2013 or commencement of work on the WWTP, whichever is earlier
14	As part of phyto-sanitary program and/or other programs to improve processing, SolTuna to conduct a cleaner production audit, focusing on energy and water use, using appropriate benchmarks (e.g. Table 3 of WBG EHS guideline for fish processing).	Append to first AMR submission
	PS4: Community Health and Safety
	See 4
	PS5: Land Acquisition and Involuntary Resettlement
15	If land parcel allocation remains unknown/unconfirmed: SolTuna to develop a Resettlement Action Framework outlining general principles compatible with PS5 requirements	End December 2013 or commencement of work on the housing project, whichever is earlier
15a	If the land lease requested by SolTuna for additional housing is granted: the development of a Resettlement Action Plan that addresses the applicable requirements of PS5 (Para 22), including: (1) roles and responsibilities of SolTuna, local government and other parties; (2) baseline census and asset inventory for those affected; (3) establishment of a eligibility cut-off date; (4) options for housing with security of tenure; (%) compensation for loss of assets (other than land); (5) relocation assistance. RAP – as approved by SolTuna senior management, collaborating partners and IFC	End December 2013 or commencement of work on the housing project, whichever is earlier 30 days before any RAP related activity commences
	PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
	Supply Chain
16	SolTuna to request primary supplier (NFD) to review their catch data (from 2009) to:  develop a ‘best estimate’ of bigeye catch;  identify any factors that increase the risk of catching bigeye;  identify procedures to improve the capture and recording of big eye catch data; and  provide options available to NFD to reduce the catch of juvenile bigeye.	End July 2013
17	SolTuna to request primary supplier (NFD) to work with FFA and MFMR to:  modify and distribute updated logbooks that enable better collection of target catch and bycatch of sensitive species (retained and discarded) data to the species level (irrespective of whether the catch enters NFD or SolTuna’s supply chain);  for all longline vessels fishing on licenses held by NFD, review longline fleet catch and bycatch data to assess level of compliance with license conditions and that fishing practices and setting is consistent with targeting species sought by SolTuna (albacore and yellowfin);  implement corrective actions in the event that non-compliance is evident. Initial results/data from this request should be received by SolTuna within 120 days. Subsequent updates, with focus on status of any corrective action request to primary suppliers (NFD)	End July 2013 End November 2013 Status/implementation updates: AMR
18	In consultation with NFD, request MFMR or FFA commission a risk assessment of the risk posed by imported frozen bait as a vector for the introduction of exotic diseases to Solomon Island waters.	Append to first AMR submission
19	SolTuna to request primary supplier (NFD) to provide information on the i) overlap of bait fishing with Marine Protected Areas, ii) the community agreements that permit bait fishing in community waters, and iii) an estimate of the annual bait fish catch and an estimate of the Maximum Sustainable Yield.	End November 2013 Update: append to first AMR submission
20	SolTuna to request primary supplier (NFD) to work with FFA and MFMR to commission Marine Stewardship Council (MSC) pre-assessments or equivalent, and/or review and report on existing full-assessments applicable to the fisheries supplying SolTuna:  Solomon Islands purse seine fishery (skipjack and yellowfin);  Solomon Islands pole & line fishery (skipjack and yellowfin); and  Solomon Islands longline fishery (albacore, yellowfin and bigeye).	End July 2013 Purse seine: append to first AMR submission Pole and line and longline: append to second AMR submission
21	Using the findings from 20, develop a strategy to progress to MSC certification or equivalent the fisheries accessed by the primary supplier, where this is feasible. Where MSC certification or equivalent is not feasible, develop program to improve fisheries practices where this has been identified as a priority in the pre-assessment report.	Within 120 days of receiving final Pre-Assessment for that fishery. Status/implementation updates: AMR
22	In consultation with NFD, SolTuna to actively support the development and implementation of the Solomon Islands Tuna Management and Development Plan. Provide an annual update on:  Steps taken by SolTuna/NFD to support the implementation of the Plan, and SolTuna/NFD’s assessment of progress against state objectives in the Plan; and  SolTuna/NFD’s assessment of risks and opportunities to the supply of tuna to SolTuna arising from fisheries management.	First AMR submission and updates in each subsequent AMR