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 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

The proposed investments are expected to have limited environmental and social impacts which will be site-specific with none anticipated to be significant. Further, the 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. Following implementation of the attached Environmental and Social Action Plan (“ESAP”), the project will be in compliance with applicable IFC’s Performance Standards and the World Bank Group (“WBG”) General and sector-specific (Food and Beverage Processing) Environmental, Health and Safety (“EHS”) Guidelines.

Key environmental and social issues applicable for this investment are: (i) environmental, occupational health and safety (“OHS”), food safety and social management systems and related procedures, including Hazard Assessment and Critical Control Point (“HACCP”) Principles at the food facility; (ii) EHS organizational structure and internal capacity; (iii) adherence to Nigerian labor law, working conditions, standards and OHS risk prevention and management, including each facility’s employees and contractors; (iv) Life and Fire Safety (“L&FS”) provisions and emergency preparedness and response; (v) wastewater collection and treatment, solid waste disposal, air emissions from generators and boilers, hazardous material handling and management; and (vi) food and transport safety, Specific actions have been defined in the attached Environmental and Social Action Plan (“ESAP”) to ensure these issues are adequately addressed.

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.

The Company has presented plans to address the potential environmental and social impacts to ensure that the Project and food facility will, upon implementation of the specific agreed mitigation measures outlined in the ESAP, comply with policies and standards operating procedures internal to the company, applicable Nigerian laws and regulations, IFC’s Performance Standards and the applicable WBG EHS Guidelines. The information about how these potential impacts will be addressed is summarized in the paragraphs that follow, and in the attached ESAP which is disclosed with this document.

The Nigerian Federal Environmental Protection Agency (“FEPA”) confirmed that no EIA was required for the Project and all the relevant town planning approvals and buildings permits have been obtained from the Ogun State Town Planning Department. Once the location of the food facility has been confirmed, the regulatory requirement for an EIA for this project will be confirmed with FEPA. Further, as per the ESAP, once the plant design has been finalized, Natural Prime will confirm and agree with IFC on the approach to the assessment of environmental and social impacts for this project.

To formalize the approach to EHS at the Project, Natural Prime will appoint a dedicated experienced EHS representative for the facility. Equally, once the design of the food facility has been finalized and prior to commissioning, Wings will confirm the EHS and food safety officers at this operation. In addition and as set forth in the ESAP, Wings will design and implement an integrated Environmental, Occupational Health and Safety and Social Management System consistent with the requirements of ISO 14001, OHSAS 18001 and IFC Performance Standard 1 for the Project. This requirement also applies to the food facility and the management system will also include an element related to food safety in accordance with accepted international practices. These management systems will include defined procedures for monitoring and reporting on Key Performance Indicators (KPIs), such as waste management, incidents (e.g., spills) and OHS.

In the event of an emergency at the Project, the State Fire Department will take approximately an hour to arrive at the site. Given this response time, it is important that the facility has a clearly defined and a structured approach to emergency response and to some extent is self reliant. Thus Natural Prime will commission a review of the L&FS system design for the plant to ensure this is aligned with accepted industry practice. Further, prior to the food facility being constructed, Wings will confirm the design standard being applied to L&FS for this site such that it is in accordance with recognized standards. These requirements are defined in the ESAP.

The Project is located in an industrial park and thus interactions with adjacent communities and the public are generally limited. The extent of potential engagement at the food facil
ity is still to be defined given the location is currently not known. There is though a need for the respective facilities to define an approach to stakeholder engagement, including a grievance procedure. Thus as defined in the ESAP, Wings will develop a procedure defining the approach to stakeholder engagement inclusive of a grievance procedure that will apply to the Project and food facility.

Construction of the Project is being managed by Wings and the Group has experienced personnel on-site to ensure quality control by the contractor. Whist the contractor has a defined approach to OHS, this does not similarly apply to environmental management with the focus being exclusively on ensuring solid waste is collected and disposed of via licensed waste contractors. Thus Wings will develop and implement an Environmental Management Plan (“EMP”) for the construction phase as detailed in the ESAP. This EMP will also be extended to include the food facility once construction commences.

The Project is expected to employ approximately 1,200 personnel while the number of employees at the food facility has not been defined. Of the total number of workers, it is expected that approximately 65% will be women. Prior to commissioning both the Project and food facility, the respective human resources documentation will be submitted to IFC to confirm alignment with this Performance Standard.



The minimum age for employment in Nigeria is 18 years and collective bargaining and the right to join unions is provided for via national legislation.



Where the Project and the food facility have standing agreements with contractors to provide regular services to the organization or vice versa, the respective organizations will confirm that the labor practices align with the requirements of this Performance Standard. Equally, Natural Prime and the food facility will develop internal procedures to ensure ongoing monitoring of contractors labor and working conditions as necessary. This requirement will commence with a review of the construction contractor’s approach to human resource management. Where gaps are identified, an action plan will be agreed with IFC to ensure compliance. Equally, prior to the food facility being constructed, the construction contractor’s human resource documentation will be submitted to IFC to confirm compliance with this Performance Standard.



Whist for the most part activities related to the Project and food facility will not pose substantive OHS risks, the respective operations will need a clearly defined approach to OHS management. Thus as defined under Performance Standard 1, Natural Prime will develop and implement an OHS management system aligned with requirements of OHSAS 18001 and Performance Standard 2 related OHS requirements. This will similarly apply to the food facility. Further, once the facilities are operational, an OHS audit will be undertaken to confirm alignment with IFC’s requirements and ensure effective implementation of the applicable systems.



The primary construction contractor at the detergent facility, Vita Construction Limited, has a detailed Safety Practice Handbook that includes policy, procedures and training requirements related to all aspects of OHS. Implementation of the requisite practices as defined in the Handbook is provided for via a full time safety officer employed by the contractor. Weekly reports are compiled on safety and to date the contractor has not reported any incidents since construction commenced. Prior to construction of the food facility and as outlined in the ESAP, the contractors OHS documentation will be submitted to IFC for review and confirmation.

The primary liquid raw materials required for the production of detergent include lapsa, caustic soda and sodium silicate. These products along with other liquid raw materials required in smaller quantities will be stored in above ground bunded tanks. Other dry raw materials, such as sodium sulfate and soda ash will be stored in designated areas.



The total water consumption for the Project is estimated at 150 m3 per day. Approximately 90 m3 will be sourced from on-site boreholes and the remaining quantity supplied as treated water via the waste water treatment plant. The total water consumption allied to water purification and treatment requirements for the noodle plant are still to be defined.



At the Project site all stormwater collected on site will be channeled off-site into the industrial park’s stormwater management system. The approach to stormwater management for the food facility is still to be defined. All domestic sewerage generated at both the Project and food facility will be disposed of via septic tanks.



Power requirements for the Project will be provided via natural gas and used to fire the burner and boiler. In addition, there will be three 1000 kVa generators for standby power requirements. The estimated CO2 emission is 1062 ton per annum. The energy requirements for the food facility are still to be defined.



To limit the discharge of detergent to atmosphere, bag filters will be installed on the raw material and finished product silos, and product transfer points. As defined in the ESAP, a monitoring plan for emissions and waste water quality will be compiled for the Project in alignment with the requirement of the WBG EHS Guidelines. This will similarly apply to the food facility.



All solid waste at the Project and food facility will be contained in designated areas and thereafter collected by a licensed waste disposal company for disposal at the State operated landfill. At the Project, product that is not within the required specification will be recycled back in to the process. At both the Project and the food facility, aside from used oils that will be collected for re-use, the wastes generated will be largely domestic in nature, inclusive of packaging materials. Given opportunities to recycle waste in Nigeria are limited, waste segregation at source will not be practiced and all the waste will be disposed of via landfill. This approach to solid waste management will also apply to the Project and the food facility.

The Project is located within an existing industrial park which includes various heavy industrial operations and to a large extent they are removed from residential areas. Thus potential adverse impacts on communities are related to primarily to traffic. However, the industrial park is well serviced by existing road networks and the current traffic volumes generated along with the future increase will not pose a significant risk to local communities. Product will be typically transported by sub-contractors and as defined in the ESAP, Wings will develop and implement a driving program that will apply to all drivers inclusive of sub-contractors. Potential impacts to communities as a result of the food facility will be defined in the assessment to be undertaken for this project and a driving program will also be implemented at this facility.



While there is currently no emergency response procedure for the existing operations, as previously indicated under PS1, this will be developed by Wings.



Security at the Project will be partially outsourced and the Project will also employ its own guards. None of the guards will be armed other than the policeman who will be stationed at the gates to the facility. A similar approach to security will apply at the noodle plant.

There are risks associated with the use of palm oil in that it could be sourced from areas where there has been significant conversion of natural and/or critical habitat for the production of the oil. Thus Wings will endeavor to enhance its supply review process for palm oil purchased in Nigeria and overseas such that there is engagement with their primary suppliers to ensure the oil is not sourced from such areas. In doing so, procurement will be limited to areas where such conversion is absent.

No EIA was undertaken for the Project and thus consultation on the project has been limited primarily to government agencies. However, given the location of the facility within an established industrial park, community engagement is not considered necessary and the facility has received the necessary government approvals. Once the design for the food facility has been finalized, the approach to the assessment of environmental and social issues will be defined in agreement with IFC, along with the extent of the community engagement. Community engagement for both operations will be defined in the Stakeholder Engagement Plan to be applied to the respective operations.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. In addition, an advertisement will be lodged in a local newspaper informing the public that the ESRS and ESAP are available for review at the site for the detergent facility in Ogun State.

Name                        : Nur Bambang Jokoraharjo Physical Address        : 15, Commercial Road                           Apapa, Lagos Telephone                 : +234 8035016290                           +628170874784 Email                        : mailto:bambang.jokoraharjo@wingscorp.com

Broad Community Support is not applicable for this project