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Environmental & Social Review Summary
Project Number
32247
Company Name
Minerva S/A.
Date ESRS Disclosed
Mar 29, 2013
Country
Brazil
Region
Latin America and the Caribbean
Last Updated Date
Mar 20, 2024
Environmental Category
A - Significant
Status
Completed
Previous Events
Approved : May 30, 2013
Signed : Sep 6, 2013
Invested : Sep 10, 2013
Sector
Animal Slaughtering and Processing
Industry
Agribusiness and Forestry
Department
Gbl Ind, Manufact, Agribus & Services
Project Description
The proposed Project with Minerva S.A. (“Minerva” or “the Company”), the third largest meat processor in Brazil, will support the implementation of a regional expansion program and address the environmental and social impacts of cattle ranching in Brazil. The proposed investment consists of an A-Loan and/or Equity investment.
The Company is undertaking an investment plan over the next four years to: (i) expand the processing and slaughtering operations in South America, more specifically in Brazil, Uruguay and Paraguay; (ii) potentially develop a slaughtering plant in Colombia; (iii) construct, acquire and/or lease six distribution centers across Brazil; and (iv) expand the processing capacity of the Minerva Dawn Farms plant in Brazil (the “Project”).
The Company is undertaking an investment plan over the next four years to: (i) expand the processing and slaughtering operations in South America, more specifically in Brazil, Uruguay and Paraguay; (ii) potentially develop a slaughtering plant in Colombia; (iii) construct, acquire and/or lease six distribution centers across Brazil; and (iv) expand the processing capacity of the Minerva Dawn Farms plant in Brazil (the “Project”).
E & S Project Categorization and Applicable Standard
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
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
This is category A project according to IFC’s Policy on Social and Environmental Sustainability. As a result of Minerva’s slaughtering activities in both Amazon and Chaco regions in South America, it was found that the potential risks and impacts of Minerva’s supply chain’s related issues with cattle suppliers could be significant, that are diverse, irreversible and unprecedented. Issues include deforestation, child/forced labor, encroachment on Indigenous People land, and respect of customary rights by the Company’s primary suppliers.
Environmental and Social Mitigation Measures
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.
Environmental and Social Assessment: Minerva manages its environmental and social aspects seeking compliance with national and local laws and regulations. Minerva has obtained all the valid environmental licenses for its existing operations, but most existing plants were not required to have an ESIA before the construction phase. More recently, slaughterhouses started to be subject to formal Environmental Impact Assessments (EIAs) before construction in Brazil, and Minerva presented a full EIA for an expansion in Araguaína and a rapid impact assessment for the construction of the Campina Verde site. Minerva just acquired a slaughterhouse in Paraguay, in which an environmental due diligence was conducted before acquisition. As described above, Minerva expects to expand the number of slaughterhouses in Brazil as well as distribution centers. As set forth in the Environmental and Social Action Plan (ESAP), Minerva will develop an Environmental and Social Impact Assessment Policy framework consistent with host countries legal requirements and IFC Performance Standards (PS).
Key Environmental aspects of its operations such as water use and wastewater management, solids and hazardous wastes management, underground water quality, environmental licensing and conditions of operation are managed following State level Environmental Authorities requirements.
Minerva has conducted the OHS risk assessment as well as worker’s health and ergonomic assessments, as described in PS2 section below. Minerva follows international best practices of food safety standards and is certified under British Food Safety Standard (BRC) and HACCP (Hazard Analysis and Critical Control Points). As set forth in the ESAP, Minerva will implement an integrated EHS Management system (ESMS) covering Environmental, Occupational Health and Safety consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001 (Environmental Management System), OHSAS 18001 (OHS management system) and ISO 22001 (food safety management system), although certification of hereon standards are not required. As part of ESMS implementation, Minerva will define an overarching policy defining environmental and social objectives and principles that guide the company to achieve sound environmental and social performance.
Minerva follows international best practices of animal welfare and all slaughterhouses follows Mrs. Temple Grandin, PhD system under a WSPA (World Society for the Protection of Animals) certification program. The practices are also in conformity with Brazilian and European requirements of animal welfare.
Organizational Capacity: E&S organization, at corporate level, includes a HR manager, an environmental manager, an OHS Manager and a sustainability manager. Every plant has a team of OHS staff that includes an OHS engineer, OHS technicians, nurses and a physiotherapist. Each plant also relies on a team of envir
onmental analysts and an HR staff that report to their respective plant-level managers. As set forth in the ESAP, Minerva will hire/appoint a corporate sustainability director that will integrate and manage environmental, OHS, stakeholder engagement and corporate sustainability areas on a higher/strategic level.
Management Programs: Minerva currently has some E&S mandatory programs in place, such as OHS risk prevention and health management programs, solid waste management, food safety management, hearing protection, job observation and ergonomic programs. As part of the above mentioned integrated EHS management system implementation, Minerva will further develop all necessary management procedures and programs (i.e. water efficiency, air emissions monitoring, sustainable biomass supply, fall prevention) to deal with the possible gaps identified during the preparation of the EHS risk assessment, in order to meet the requirements of the PS.
Training: Minerva provides a basic EHS training for all workers during their induction program that includes specific EHS aspects. Other trainings are provided based on specific workplace needs, such as training for working in confined spaces, working at heights, working with electrical devices and for the boilers operator. As part of the integrated EHS management system implementation mentioned above, Minerva will further structure and consolidate a comprehensive training program for each business unit.
Monitoring: Minerva already has a set of key performance indicators, such as wastewater quality, water consumption, energy consumption, wood/biomass and fuel consumption, wastes generation and accident rates consistent with World Bank Group EHS guidelines requirements. As a set forth in ESAP, Minerva will start monitoring boilers’ emissions using quantitative methodologies following CONAMA 382/06 and 436/11 requirements. Minerva will also include Nitrogen and Phosphorous parameters in the wastewater monitoring of all slaughterhouses following legal framework requirements. Minerva developed an internal OHS performance indicator that is a mix of accident rates, turnover, absenteeism and occupational disease related working loss days. Minerva also has an internal auditing system that includes some E&S aspects and they also audit some key service providers (e.g. tanneries) to verify licenses/permits and compliance with some local environmental requirements. As part of the integrated EHS management system implementation mentioned above, Minerva will further develop specific overall monitoring program covering all relevant E&S performance indicators (Key Performance Indicators). Minerva will enhance internal E&S auditing system covering all aspects of the ESMS (risk/impact assessment, gap analysis and management programs, organizational capacity, training programs, stakeholder engagement, monitoring and reporting), and Minerva will also develop specific auditing protocols for key services providers, including en
vironmental, labor and OHS aspects. In cooperation with the Brazilian Beef Cattle Association (ABIEC) and along with another player from the sector, Minerva hired a company to develop a GIS web based verification system integrated with their own supply chain database, to check E&S information from all primary suppliers in the Amazon Region. The verification system is sophisticated and includes information collected from primary suppliers (land title documentation, tax number, CAR mapping and registration), overlapping farms’ maps with legal protected areas, legislated IP lands and information from official monitoring of deforestation in the Amazon Region. Farmers’ tax numbers are used to check the official forced labor list and embargoed areas from the Environmental Authority (IBAMA) for every purchase made by the Company in Brazil, not only in the Amazon Region. The whole system is audited by an independent reliable third party (BDO). As a set forth in ESAP, Minerva will develop a supply chain management framework to identify other regions/countries in which they operate and where there is high risk of child/forced labor and natural/critical habitats conversion in the primary supply chain, and develop similar verification/management practices as described above, taking into consideration the public data available in each country. Notwithstanding IFC’s ongoing monitoring and Minerva own commitments, Minerva’s ability to manage aspects of its supply chain in some geographical areas will be challenging and there can be no absolute guarantee that harmful child labor and/or conversion of natural/critical habitats will not be present at the primary supplier level. However, should such situation be detected by Minerva, the supplier would be immediately excluded from Minerva''s base of suppliers.
Reporting: Minerva reports relevant mandatory E&S indicators to the competent authorities (e.g. solid wastes, hazardous wastes, wastewater, and accident rates). Minerva reports internally selective E&S performance indicators, such as production loss, energy consumption, wastewater, injury rates and working days loss. As part of the integrated EHS management system implementation as mentioned above, Minerva will further structure and develop a formal internal E&S monthly and annual reporting to the corporate Sustainability Director which will be discussed at Minerva’s Board of Directors on a regular basis. Minerva published its first annual sustainability report, which includes relevant E&S information and indicators, which is disclosed, to all stakeholders using the international reporting standard format of the Global Reporting Initiative (GRI), which is available on their website.
Stakeholder Engagement: The Company at present has fairly limited interaction with its surrounding communities, for example those in close proximity to their slaughterhouses, or with other indirect stakeholders, such as NGOs. The Company does not have a formal grievance mechanism
for monitoring and tracking complaints, although complaints are managed in an ad hoc way by the corporate HR Department, or the Plant-level Manager. At this time, no corporate Manager is formally responsible for Stakeholder Engagement.
Based on the appraisal visit to Minerva’s multiple facilities, it has been determined that there are no identified communities with potentially significant adverse impacts as a result of the slaughterhouses, feedlots or distribution centers. As a result, the client will not need to conduct Informed Consultation and Participation (ICP). However, as set forth in the ESAP, the client will be asked to develop and implement a detailed Stakeholder Engagement commensurate with the level of project risks and impacts, which are expected to be limited in scope, few in number and generally site specific, largely reversible and readily addressed through mitigation measures. Some of the potential impacts might include induced traffic and congestion around a site, noise or odors, and if the client is constructing a new facility or renovating a newly acquired existing operation, construction related impacts. Certain basic elements need to be put in place to manage community grievances as well as a plan on how the Company intends to interact with other stakeholders going forward. The Company appears to be leading best practice on its management and traceability of primary suppliers and should be further seek its best efforts to develop a pilot program . Therefore the Company will assign responsibility for Stakeholder Engagement to a Director and respective team of staff. As set forth in the ESAP, the Company will develop a Stakeholder Engagement Plan (SEP) which scope will include a stakeholder mapping exercise, a plan for engaging with various types of stakeholders and a community grievance mechanism which procedure the client will incorporate into its corporate and plant-level ESMS. The Company will disclose the SEP and consult on their expansion plan (through the ESIA process outlined above) with local communities, informing them of the project and of the Grievance Mechanism. In addition, the Company will seek its best efforts to follow up with relevant stakeholders identified in the stakeholder mapping exercise to engage further in the broader sector industry discussion on the sustainable supply chain management process for beef, of which they are currently an industry leader. IFC will ask that the Company take a more proactive role as leader in the sustainable beef initiatives going forward, promoting sustainable beef cattle production standard consistent with the commitments adopted by Minerva.
Key Environmental aspects of its operations such as water use and wastewater management, solids and hazardous wastes management, underground water quality, environmental licensing and conditions of operation are managed following State level Environmental Authorities requirements.
Minerva has conducted the OHS risk assessment as well as worker’s health and ergonomic assessments, as described in PS2 section below. Minerva follows international best practices of food safety standards and is certified under British Food Safety Standard (BRC) and HACCP (Hazard Analysis and Critical Control Points). As set forth in the ESAP, Minerva will implement an integrated EHS Management system (ESMS) covering Environmental, Occupational Health and Safety consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001 (Environmental Management System), OHSAS 18001 (OHS management system) and ISO 22001 (food safety management system), although certification of hereon standards are not required. As part of ESMS implementation, Minerva will define an overarching policy defining environmental and social objectives and principles that guide the company to achieve sound environmental and social performance.
Minerva follows international best practices of animal welfare and all slaughterhouses follows Mrs. Temple Grandin, PhD system under a WSPA (World Society for the Protection of Animals) certification program. The practices are also in conformity with Brazilian and European requirements of animal welfare.
Organizational Capacity: E&S organization, at corporate level, includes a HR manager, an environmental manager, an OHS Manager and a sustainability manager. Every plant has a team of OHS staff that includes an OHS engineer, OHS technicians, nurses and a physiotherapist. Each plant also relies on a team of envir
onmental analysts and an HR staff that report to their respective plant-level managers. As set forth in the ESAP, Minerva will hire/appoint a corporate sustainability director that will integrate and manage environmental, OHS, stakeholder engagement and corporate sustainability areas on a higher/strategic level.
Management Programs: Minerva currently has some E&S mandatory programs in place, such as OHS risk prevention and health management programs, solid waste management, food safety management, hearing protection, job observation and ergonomic programs. As part of the above mentioned integrated EHS management system implementation, Minerva will further develop all necessary management procedures and programs (i.e. water efficiency, air emissions monitoring, sustainable biomass supply, fall prevention) to deal with the possible gaps identified during the preparation of the EHS risk assessment, in order to meet the requirements of the PS.
Training: Minerva provides a basic EHS training for all workers during their induction program that includes specific EHS aspects. Other trainings are provided based on specific workplace needs, such as training for working in confined spaces, working at heights, working with electrical devices and for the boilers operator. As part of the integrated EHS management system implementation mentioned above, Minerva will further structure and consolidate a comprehensive training program for each business unit.
Monitoring: Minerva already has a set of key performance indicators, such as wastewater quality, water consumption, energy consumption, wood/biomass and fuel consumption, wastes generation and accident rates consistent with World Bank Group EHS guidelines requirements. As a set forth in ESAP, Minerva will start monitoring boilers’ emissions using quantitative methodologies following CONAMA 382/06 and 436/11 requirements. Minerva will also include Nitrogen and Phosphorous parameters in the wastewater monitoring of all slaughterhouses following legal framework requirements. Minerva developed an internal OHS performance indicator that is a mix of accident rates, turnover, absenteeism and occupational disease related working loss days. Minerva also has an internal auditing system that includes some E&S aspects and they also audit some key service providers (e.g. tanneries) to verify licenses/permits and compliance with some local environmental requirements. As part of the integrated EHS management system implementation mentioned above, Minerva will further develop specific overall monitoring program covering all relevant E&S performance indicators (Key Performance Indicators). Minerva will enhance internal E&S auditing system covering all aspects of the ESMS (risk/impact assessment, gap analysis and management programs, organizational capacity, training programs, stakeholder engagement, monitoring and reporting), and Minerva will also develop specific auditing protocols for key services providers, including en
vironmental, labor and OHS aspects. In cooperation with the Brazilian Beef Cattle Association (ABIEC) and along with another player from the sector, Minerva hired a company to develop a GIS web based verification system integrated with their own supply chain database, to check E&S information from all primary suppliers in the Amazon Region. The verification system is sophisticated and includes information collected from primary suppliers (land title documentation, tax number, CAR mapping and registration), overlapping farms’ maps with legal protected areas, legislated IP lands and information from official monitoring of deforestation in the Amazon Region. Farmers’ tax numbers are used to check the official forced labor list and embargoed areas from the Environmental Authority (IBAMA) for every purchase made by the Company in Brazil, not only in the Amazon Region. The whole system is audited by an independent reliable third party (BDO). As a set forth in ESAP, Minerva will develop a supply chain management framework to identify other regions/countries in which they operate and where there is high risk of child/forced labor and natural/critical habitats conversion in the primary supply chain, and develop similar verification/management practices as described above, taking into consideration the public data available in each country. Notwithstanding IFC’s ongoing monitoring and Minerva own commitments, Minerva’s ability to manage aspects of its supply chain in some geographical areas will be challenging and there can be no absolute guarantee that harmful child labor and/or conversion of natural/critical habitats will not be present at the primary supplier level. However, should such situation be detected by Minerva, the supplier would be immediately excluded from Minerva''s base of suppliers.
Reporting: Minerva reports relevant mandatory E&S indicators to the competent authorities (e.g. solid wastes, hazardous wastes, wastewater, and accident rates). Minerva reports internally selective E&S performance indicators, such as production loss, energy consumption, wastewater, injury rates and working days loss. As part of the integrated EHS management system implementation as mentioned above, Minerva will further structure and develop a formal internal E&S monthly and annual reporting to the corporate Sustainability Director which will be discussed at Minerva’s Board of Directors on a regular basis. Minerva published its first annual sustainability report, which includes relevant E&S information and indicators, which is disclosed, to all stakeholders using the international reporting standard format of the Global Reporting Initiative (GRI), which is available on their website.
Stakeholder Engagement: The Company at present has fairly limited interaction with its surrounding communities, for example those in close proximity to their slaughterhouses, or with other indirect stakeholders, such as NGOs. The Company does not have a formal grievance mechanism
for monitoring and tracking complaints, although complaints are managed in an ad hoc way by the corporate HR Department, or the Plant-level Manager. At this time, no corporate Manager is formally responsible for Stakeholder Engagement.
Based on the appraisal visit to Minerva’s multiple facilities, it has been determined that there are no identified communities with potentially significant adverse impacts as a result of the slaughterhouses, feedlots or distribution centers. As a result, the client will not need to conduct Informed Consultation and Participation (ICP). However, as set forth in the ESAP, the client will be asked to develop and implement a detailed Stakeholder Engagement commensurate with the level of project risks and impacts, which are expected to be limited in scope, few in number and generally site specific, largely reversible and readily addressed through mitigation measures. Some of the potential impacts might include induced traffic and congestion around a site, noise or odors, and if the client is constructing a new facility or renovating a newly acquired existing operation, construction related impacts. Certain basic elements need to be put in place to manage community grievances as well as a plan on how the Company intends to interact with other stakeholders going forward. The Company appears to be leading best practice on its management and traceability of primary suppliers and should be further seek its best efforts to develop a pilot program . Therefore the Company will assign responsibility for Stakeholder Engagement to a Director and respective team of staff. As set forth in the ESAP, the Company will develop a Stakeholder Engagement Plan (SEP) which scope will include a stakeholder mapping exercise, a plan for engaging with various types of stakeholders and a community grievance mechanism which procedure the client will incorporate into its corporate and plant-level ESMS. The Company will disclose the SEP and consult on their expansion plan (through the ESIA process outlined above) with local communities, informing them of the project and of the Grievance Mechanism. In addition, the Company will seek its best efforts to follow up with relevant stakeholders identified in the stakeholder mapping exercise to engage further in the broader sector industry discussion on the sustainable supply chain management process for beef, of which they are currently an industry leader. IFC will ask that the Company take a more proactive role as leader in the sustainable beef initiatives going forward, promoting sustainable beef cattle production standard consistent with the commitments adopted by Minerva.
Human Resource Policy and Management: The Company has a well defined human resources policy and an on-line corporate wide system. There is a corporate Human Resource Manager who takes charge of recruitment and professional development. The strategy is developed at the corporate level but there is a plant-level Manager at each operation who is in charge of OHS and administrative support on HR issues. There is a corporate training program on various topics, focusing on supervisors as the point person to generate the most support, as they feel the supervisor will pass it on to his employees as he manages his team on a day to day basis. The supervisors are responsible for two indicators: turnover, absenteeism and accident rates, in order to have them more vested in the monitoring, reporting and improvement process. The Company instituted this program as they felt the supervisors were too distant from their employees and they wanted them to be more involved. A number of training programs are offered to employees, such as training on finance and payroll deductable loans for employees. There are several pillars in HR that the Company focuses on: competencies, quality, results, teamwork, commitment and client focus. Minerva wants to establish itself as a desirable place to work among Brazilian processing and meatpackers industry. The Company also has policies on recruitment, professional development and enumeration. Benefits fall under enumeration, such as health and life insurance; subsidy meal and transport follow industry standards and country regulations.
There is a suggestion box and an open door policy but no real formal written employee grievance mechanism. If someone has a complaint, they go to their supervisor, if the problem is with a supervisor they go to their Manager or the HR Manager in that unit. If the complainant is known, HR can give some feedback but if it is anonymous grievance that is not possible. They have internal audits where teams go to different units other than their own and evaluate processes which they do on an annual basis. They keep a written log of the grievance issues and attempt to close them out. However, the process could use some improvement and the Company will further develop and formalize an employee grievance mechanism procedure and communicate it to their employees and will be implemented in each of its operations, as set forth in the attached ESAP.
Worker’s Organizations: In Brazil, all workers must join a union, and contribute one day of wages per year as a mandatory fee. They can choose which union they belong to but in this case, most of their work force belongs to the Regulated Food Industry Union (“Sindicato da Industria Alimentícia”). There are representatives of the union working as active members of the union within the Company, although not in a large number. There are collective bargaining agreements which set annual salaries, benefits and terms of employment. There is a national baseline well es
tablished by law for certain parameters, such as the minimum wage. The unions are very strong, particularly in Uruguay. The Company had one strike in the past two years in Paraguay. The Company negotiated directly with the workers and came to an acceptable agreement, without the Union. There have been no plant closures by the Ministry of Labor or the Sanitary Authority for working condition or sanitary violations.
Non-Discrimination and Equal Opportunity: The Company has a Code of Ethics which covers sexual harassment, gifting and interactions with clients and suppliers. It addresses the type of work an employee can do outside the corporation as long as it is not in conflict with their existing job. They have never had a breach of the code of ethics.
Retrenchment: The industry is prone to market fluctuations and sometimes the Company says it is necessary to close a plant, temporarily or even permanently. There is a legal framework for retrenchment in Brazil that they follow, which includes a mandatory lump sum payout to the workers. All retrenchment has to be negotiated with the unions. First the Company attempts to avoid layoffs of staff and puts them on mandatory annual leave. They try to find places for some of their strategic workers that they don’t want to lose and also keep a skeleton crew on for maintenance and security purposes. Usually the staff are hired back once the plant can start up again, which is sometimes 3 to 4 months later. As set forth in the ESAP, the client will develop and implement a Retrenchment Framework, to use when necessary, that is in compliance with the requirements of PS2.
Protecting the Work Force: The Company has a policy on no slave, child labor or casual labor in its direct operations. All workers must be over the age of 18 and they are checked using their birth certificates during the employment screening. However, there is a young apprenticeship program for workers 16 to 18 years of age, who can only work 4 hours per day, do administrative work (no hazardous work) and must still attend school. This program is run through the Federal government and the Company strictly follows the regulations.
Occupational Health and Safety: Minerva manages OHS risks seeking compliance with national and local regulations. Minerva has developed and successfully implemented individual OHS mandatory risk prevention plans for each plant in Brazil (PPRA), identifying the work related risks, the workers exposure to hazards agents and the need for protection. Minerva also has individual health monitoring program, including periodic clinical exams, and specific procedures on the safe ways to do the job. Minerva also has developed a workplace monitoring program with periodic field inspections and reporting of key performance indicators and corrective actions. This program covers relevant aspects of the Brazilian OHS Standard, including moving parts and machinery protection (NR12), ergonomic conditions and aspects (NR17), w
orking at heights (NR35), adequate use of PPEs, working with electrical devices (NR10), chemicals handling and storage. Accident rates vary significantly from one site to other, which shows some inconsistencies in terms of OHS performance were across the sites. Under the ESMS implementation, Minerva will further explore opportunities to enhance fall prevention and ergonomic mitigation measures. Minerva will identify all possibilities to deploy safety belts (a.e.at skinning and haggis take out), adjustable platforms for workers (a.e. at boning) and pallet’s lifter platforms at pallets loading unloading areas. As set forth in the ESAP, Minerva will define corporate standards for OHS risk prevention plans (PPRA) and define best PPEs approaches for similar job positions across the Company operations (based on best practices), summarized in a set of EHS corporate standards. Minerva will also deploy safety equipment in the ammonia storage and refrigerating systems, such as leak detectors (indoor operational areas and compressors house), secondary contention, ventilation systems, proper warning signs and emergency response equipments consistent with Brazilian standard NBR 16069. Under the requested Integrated (EHS) Management system implementation, Minerva will develop specific management programs for all sites to achieve compliance with all Brazilian OHS Standards, such as NR10 Safety of Electrical System, NR13 Safety of Boilers and pressure vessels, NR33 Confined Spaces, NR16 Hazardous work (risk of explosion), NR35 working at heights, NR 17 Ergonomics. Minerva has individual emergency response and preparedness plans for its sites and will conduct a quantitative risk assessment of all sites (slaughterhouses and distribution warehouses) following CETESB standard P4.261, for those in São Paulo State, as well as the respective risk management program.
There is a medical program with on site staff doctor, nurses and a physiotherapist. The objective is to monitor illnesses and medical sick leave and to try and reduce all accidents and work related injuries. Everything is documented. Minerva tries to prevent chronic injuries and send people to work with the physiotherapist to review each job and analyze the ergonomics so that workers will not get repetitive strain injuries, which are very typical injuries within the industry.
There are corporate indicators for OHS and they report all accidents with working days loss to the Ministry of Labor. They monitor all work related injuries/diseases and look at long term disability or even short absences as it puts a lot of pressure on the other workers. Each plant has a social worker to offer support and employees who are away from work will have reports sent to HR Managers on why the workers missed work and if they need any additional support for instance if a family member is ill or if they need more medicine.
Supply chain: Concerning the supply chain and labor issues, there are well documented risks associa
ted with harmful child and forced labor in the primary supply chain. However, as outlined in the section on PS6, the client is taking pro-active and progressive measures to alleviate risks in its primary supply chain to avoid child and forced labor in Brazil using the various resources available to them (child/forced labor lists). As spelt out under PS1, the Company will amend its corporate EHS policy in line with IFC’s PS requirements, including in its supply chain, and implement a screening tool to put in place in their operations, in particular in Paraguay, as part of their supply chain management system, as described above in PS1 section.
There is a suggestion box and an open door policy but no real formal written employee grievance mechanism. If someone has a complaint, they go to their supervisor, if the problem is with a supervisor they go to their Manager or the HR Manager in that unit. If the complainant is known, HR can give some feedback but if it is anonymous grievance that is not possible. They have internal audits where teams go to different units other than their own and evaluate processes which they do on an annual basis. They keep a written log of the grievance issues and attempt to close them out. However, the process could use some improvement and the Company will further develop and formalize an employee grievance mechanism procedure and communicate it to their employees and will be implemented in each of its operations, as set forth in the attached ESAP.
Worker’s Organizations: In Brazil, all workers must join a union, and contribute one day of wages per year as a mandatory fee. They can choose which union they belong to but in this case, most of their work force belongs to the Regulated Food Industry Union (“Sindicato da Industria Alimentícia”). There are representatives of the union working as active members of the union within the Company, although not in a large number. There are collective bargaining agreements which set annual salaries, benefits and terms of employment. There is a national baseline well es
tablished by law for certain parameters, such as the minimum wage. The unions are very strong, particularly in Uruguay. The Company had one strike in the past two years in Paraguay. The Company negotiated directly with the workers and came to an acceptable agreement, without the Union. There have been no plant closures by the Ministry of Labor or the Sanitary Authority for working condition or sanitary violations.
Non-Discrimination and Equal Opportunity: The Company has a Code of Ethics which covers sexual harassment, gifting and interactions with clients and suppliers. It addresses the type of work an employee can do outside the corporation as long as it is not in conflict with their existing job. They have never had a breach of the code of ethics.
Retrenchment: The industry is prone to market fluctuations and sometimes the Company says it is necessary to close a plant, temporarily or even permanently. There is a legal framework for retrenchment in Brazil that they follow, which includes a mandatory lump sum payout to the workers. All retrenchment has to be negotiated with the unions. First the Company attempts to avoid layoffs of staff and puts them on mandatory annual leave. They try to find places for some of their strategic workers that they don’t want to lose and also keep a skeleton crew on for maintenance and security purposes. Usually the staff are hired back once the plant can start up again, which is sometimes 3 to 4 months later. As set forth in the ESAP, the client will develop and implement a Retrenchment Framework, to use when necessary, that is in compliance with the requirements of PS2.
Protecting the Work Force: The Company has a policy on no slave, child labor or casual labor in its direct operations. All workers must be over the age of 18 and they are checked using their birth certificates during the employment screening. However, there is a young apprenticeship program for workers 16 to 18 years of age, who can only work 4 hours per day, do administrative work (no hazardous work) and must still attend school. This program is run through the Federal government and the Company strictly follows the regulations.
Occupational Health and Safety: Minerva manages OHS risks seeking compliance with national and local regulations. Minerva has developed and successfully implemented individual OHS mandatory risk prevention plans for each plant in Brazil (PPRA), identifying the work related risks, the workers exposure to hazards agents and the need for protection. Minerva also has individual health monitoring program, including periodic clinical exams, and specific procedures on the safe ways to do the job. Minerva also has developed a workplace monitoring program with periodic field inspections and reporting of key performance indicators and corrective actions. This program covers relevant aspects of the Brazilian OHS Standard, including moving parts and machinery protection (NR12), ergonomic conditions and aspects (NR17), w
orking at heights (NR35), adequate use of PPEs, working with electrical devices (NR10), chemicals handling and storage. Accident rates vary significantly from one site to other, which shows some inconsistencies in terms of OHS performance were across the sites. Under the ESMS implementation, Minerva will further explore opportunities to enhance fall prevention and ergonomic mitigation measures. Minerva will identify all possibilities to deploy safety belts (a.e.at skinning and haggis take out), adjustable platforms for workers (a.e. at boning) and pallet’s lifter platforms at pallets loading unloading areas. As set forth in the ESAP, Minerva will define corporate standards for OHS risk prevention plans (PPRA) and define best PPEs approaches for similar job positions across the Company operations (based on best practices), summarized in a set of EHS corporate standards. Minerva will also deploy safety equipment in the ammonia storage and refrigerating systems, such as leak detectors (indoor operational areas and compressors house), secondary contention, ventilation systems, proper warning signs and emergency response equipments consistent with Brazilian standard NBR 16069. Under the requested Integrated (EHS) Management system implementation, Minerva will develop specific management programs for all sites to achieve compliance with all Brazilian OHS Standards, such as NR10 Safety of Electrical System, NR13 Safety of Boilers and pressure vessels, NR33 Confined Spaces, NR16 Hazardous work (risk of explosion), NR35 working at heights, NR 17 Ergonomics. Minerva has individual emergency response and preparedness plans for its sites and will conduct a quantitative risk assessment of all sites (slaughterhouses and distribution warehouses) following CETESB standard P4.261, for those in São Paulo State, as well as the respective risk management program.
There is a medical program with on site staff doctor, nurses and a physiotherapist. The objective is to monitor illnesses and medical sick leave and to try and reduce all accidents and work related injuries. Everything is documented. Minerva tries to prevent chronic injuries and send people to work with the physiotherapist to review each job and analyze the ergonomics so that workers will not get repetitive strain injuries, which are very typical injuries within the industry.
There are corporate indicators for OHS and they report all accidents with working days loss to the Ministry of Labor. They monitor all work related injuries/diseases and look at long term disability or even short absences as it puts a lot of pressure on the other workers. Each plant has a social worker to offer support and employees who are away from work will have reports sent to HR Managers on why the workers missed work and if they need any additional support for instance if a family member is ill or if they need more medicine.
Supply chain: Concerning the supply chain and labor issues, there are well documented risks associa
ted with harmful child and forced labor in the primary supply chain. However, as outlined in the section on PS6, the client is taking pro-active and progressive measures to alleviate risks in its primary supply chain to avoid child and forced labor in Brazil using the various resources available to them (child/forced labor lists). As spelt out under PS1, the Company will amend its corporate EHS policy in line with IFC’s PS requirements, including in its supply chain, and implement a screening tool to put in place in their operations, in particular in Paraguay, as part of their supply chain management system, as described above in PS1 section.
Resource Efficiency: Minerva’s slaughterhouses use small boilers (less than 50 MWth) to burn wood and wastes (recovered animal fat and organic waste) to generate steam electricity. Energy is purchased from the distribution grid and water extracted from rivers and wells. Water is used mainly on cleaning/washing at production areas and Minerva has a target for water reduction. As part of ESMS implementation, Minerva will conduct a water use assessment and develop water management programs to achieve its goals. As set forth in the ESAP, Minerva will also conduct an energy efficiency assessment to identify cost-effective opportunities to enhance efficiency to benchmark themselves with other players in the sector whenever possible.
Greenhouse Gases: Main sources of GHG are the energy consumption from the grid, diesel/gasoline consumption by trucks/vehicles, emissions from wastewater treatment lagoons and emissions from boilers in Araguaína and Rolim de Moura, which use wood from clearings of natural areas (legal) and wood wastes from sawmills, respectively. Boiler’s emissions from other sites can be considered neutral due to the fact that they use renewable source of energy (planted wood/recovered animal fat). As a set forth in ESAP, As described above Minerva will conduct an energy efficiency assessment to identify cost-effective opportunities to enhance efficiency and reduce energy related GHG emissions..
Wastes: Operational solid wastes from slaughterhouses are managed according to organic wastes from corral and animal rumen content, solid wastes from wastewater treatment lagoons and hazard wastes (chemicals, wastes from maintenance shops and from ambulatories). Paperboard scraps and used package boxes, used lubricant oil and empty containers of chemicals are delivered for recycling. Organic solid wastes from wastes are delivered to licensed farmers for organic composting and use in crop production.
Wastewater: Slaughterhouses generate significant amounts of wastewater, mainly resulting from cleaning and washing of operational areas. Typical wastewater treatment process in Brazil includes a strainer, flotation and physical separation of greases, tri-decanter (liquid, oil and solid separation) and a sequence of anaerobic, facultative and final clarification lagoons with bio-remediation. Wastewater treatment efficiency is about 90% of removal of organic matter (main contaminant). Key controlled parameters are BOD, COD, PH, oil and grasses, temperature and suspended solids. Treatment systems are managed to achieve compliance with state level requirements as described in the Environmental licenses.
As set forth in ESAP, Minerva will include Nitrogen and Phosphorous parameters in wastewater discharge monitoring, and will conduct pollution dispersion models to assess whether emissions are consistent with receiving water body use class and assimilative capacity. Whenever dispersion models show inconsistencies with receiving water body classificati
on, Minerva will explore alternative technological approaches to close the gaps. Any new site construction will have to deploy wastewater treatment plants designed to achieve compliance with WBG EHS guidelines for meat processing requirements as described in table 1.
Some wastewater ponds are lined with high density polyethylene (HDPE) sheet, but most of them are lined only with compacted clay and, when requested by local environmental authority, underground water contamination is monitored. Although it is expected that old wastewater ponds had been completely sealed by compacted clay and organic matter, and as a part of ESMS implementation, the Company will deploy piezometers to monitor underground water contamination, whenever they use waste water tanks without HDPE lining.
Air emissions: As described above, main sources of air emissions are from the boilers and wastewater ponds. Under the proposed ESMS implementation outlined in the ESAP, slaughterhouses will start monitoring air emissions and will deploy means of control to bring them into compliance with local legal requirements (CONAMA 382/06 and 436/11) and WBG guidelines. In addition, whenever the client considers replacing a boiler, they will deploy air emissions control systems with an operational capacity consistent with WBG EHS guidelines requirements.
Pesticide Use and Management: Minerva uses small number of authorized herbicides for weed control at their spare farms in Belém before cattle is leaded on ships. Minerva does not use pesticides that fall in WHO pesticides hazard classification system class I (a) or I (b).
Greenhouse Gases: Main sources of GHG are the energy consumption from the grid, diesel/gasoline consumption by trucks/vehicles, emissions from wastewater treatment lagoons and emissions from boilers in Araguaína and Rolim de Moura, which use wood from clearings of natural areas (legal) and wood wastes from sawmills, respectively. Boiler’s emissions from other sites can be considered neutral due to the fact that they use renewable source of energy (planted wood/recovered animal fat). As a set forth in ESAP, As described above Minerva will conduct an energy efficiency assessment to identify cost-effective opportunities to enhance efficiency and reduce energy related GHG emissions..
Wastes: Operational solid wastes from slaughterhouses are managed according to organic wastes from corral and animal rumen content, solid wastes from wastewater treatment lagoons and hazard wastes (chemicals, wastes from maintenance shops and from ambulatories). Paperboard scraps and used package boxes, used lubricant oil and empty containers of chemicals are delivered for recycling. Organic solid wastes from wastes are delivered to licensed farmers for organic composting and use in crop production.
Wastewater: Slaughterhouses generate significant amounts of wastewater, mainly resulting from cleaning and washing of operational areas. Typical wastewater treatment process in Brazil includes a strainer, flotation and physical separation of greases, tri-decanter (liquid, oil and solid separation) and a sequence of anaerobic, facultative and final clarification lagoons with bio-remediation. Wastewater treatment efficiency is about 90% of removal of organic matter (main contaminant). Key controlled parameters are BOD, COD, PH, oil and grasses, temperature and suspended solids. Treatment systems are managed to achieve compliance with state level requirements as described in the Environmental licenses.
As set forth in ESAP, Minerva will include Nitrogen and Phosphorous parameters in wastewater discharge monitoring, and will conduct pollution dispersion models to assess whether emissions are consistent with receiving water body use class and assimilative capacity. Whenever dispersion models show inconsistencies with receiving water body classificati
on, Minerva will explore alternative technological approaches to close the gaps. Any new site construction will have to deploy wastewater treatment plants designed to achieve compliance with WBG EHS guidelines for meat processing requirements as described in table 1.
Some wastewater ponds are lined with high density polyethylene (HDPE) sheet, but most of them are lined only with compacted clay and, when requested by local environmental authority, underground water contamination is monitored. Although it is expected that old wastewater ponds had been completely sealed by compacted clay and organic matter, and as a part of ESMS implementation, the Company will deploy piezometers to monitor underground water contamination, whenever they use waste water tanks without HDPE lining.
Air emissions: As described above, main sources of air emissions are from the boilers and wastewater ponds. Under the proposed ESMS implementation outlined in the ESAP, slaughterhouses will start monitoring air emissions and will deploy means of control to bring them into compliance with local legal requirements (CONAMA 382/06 and 436/11) and WBG guidelines. In addition, whenever the client considers replacing a boiler, they will deploy air emissions control systems with an operational capacity consistent with WBG EHS guidelines requirements.
Pesticide Use and Management: Minerva uses small number of authorized herbicides for weed control at their spare farms in Belém before cattle is leaded on ships. Minerva does not use pesticides that fall in WHO pesticides hazard classification system class I (a) or I (b).
Minerva’s operations can potentially negatively affect communities’ health and safety in different ways: (i) impacts from wastewater discharge to community’s supply of fresh water; (ii) nuisance to adjacent communities due to induced trucks traffic, noise emissions or odours; (iii) ammonia leaks, explosions or fires.
Although most of the slaughterhouses are located in remote rural areas, it is possible to find some cases where local communities, could be potentially negatively affected. Minerva currently has good EHS treatment/control and monitoring systems as described above to mitigate potential risks/impacts to nearby communities Minerva will complete a stakeholder mapping process as well as a Stakeholder Engagement Plan (SEP) commensurate with the project’s risks and impacts as outlined in PS1.
Consumers of Minerva’s products can be potentially affected due to food safety/sanitary issues. As already described in PS1 section, Minerva’s sites are certified under the British food safety standard (BRC) that also includes recall policy and procedures for its products.
Hazardous materials management and safety: Minerva’s slaughterhouses use and store significant amounts of ammonia used in the refrigeration systems. Storage tanks are identified and placed outdoor on naturally ventilated area. Minerva has respiration cylinders and emergency gear with proper protection at all sites. Operators are trained end emergency drills are conducted annually. As a set forth in ESAP, and within the scope of the ESMS implementation, Minerva will also deploy safety equipment in the ammonia storage and refrigerating systems, such as leak detectors (indoor operational areas and compressors house), secondary contention, ventilation systems, proper warning signs and emergency response equipments consistent with Brazilian standard NBR 16069. Diesel tanks have secondary containment to avoid spills at all plants.
Emergency preparedness and response: Minerva has emergency plans, covering different possible scenarios, such as fires, chemical spills, medical emergency as well as emergency contact numbers and communication procedure, emergency equipment and execution of emergency response procedure. As set forth in the ESAP, and within the scope of the ESMS implementation, Minerva will conduct a quantitative risk assessment of all sites (slaughterhouses and distribution warehouses) following CETESB standard P4.261 (In Sao Paulo State) as well as the respective risk management program.
Security Personnel: The Company have their own in house security in Brazil, which is unarmed. Employees can be asked to open their bags but they cannot be searched physically say, for example, by a pat down. However, in Paraguay and Uruguay, the security guards are armed, according to the countries regulations. There is no Code of Conduct but there have not been any incidents reported.
The Company will review existing management practices in all three countries of operation, and devel
op specific management programs to follow the requirements laid out in PS4. As set forth in the ESAP, Minerva will develop and implement a Code of Conduct for security personnel including provisions on how to respond to threats guided by the principle of proportionality. As part of their Community Grievance Mechanism, Minerva will provide a means for communities to raise issues about the Company’s security arrangements or personnel.
Although most of the slaughterhouses are located in remote rural areas, it is possible to find some cases where local communities, could be potentially negatively affected. Minerva currently has good EHS treatment/control and monitoring systems as described above to mitigate potential risks/impacts to nearby communities Minerva will complete a stakeholder mapping process as well as a Stakeholder Engagement Plan (SEP) commensurate with the project’s risks and impacts as outlined in PS1.
Consumers of Minerva’s products can be potentially affected due to food safety/sanitary issues. As already described in PS1 section, Minerva’s sites are certified under the British food safety standard (BRC) that also includes recall policy and procedures for its products.
Hazardous materials management and safety: Minerva’s slaughterhouses use and store significant amounts of ammonia used in the refrigeration systems. Storage tanks are identified and placed outdoor on naturally ventilated area. Minerva has respiration cylinders and emergency gear with proper protection at all sites. Operators are trained end emergency drills are conducted annually. As a set forth in ESAP, and within the scope of the ESMS implementation, Minerva will also deploy safety equipment in the ammonia storage and refrigerating systems, such as leak detectors (indoor operational areas and compressors house), secondary contention, ventilation systems, proper warning signs and emergency response equipments consistent with Brazilian standard NBR 16069. Diesel tanks have secondary containment to avoid spills at all plants.
Emergency preparedness and response: Minerva has emergency plans, covering different possible scenarios, such as fires, chemical spills, medical emergency as well as emergency contact numbers and communication procedure, emergency equipment and execution of emergency response procedure. As set forth in the ESAP, and within the scope of the ESMS implementation, Minerva will conduct a quantitative risk assessment of all sites (slaughterhouses and distribution warehouses) following CETESB standard P4.261 (In Sao Paulo State) as well as the respective risk management program.
Security Personnel: The Company have their own in house security in Brazil, which is unarmed. Employees can be asked to open their bags but they cannot be searched physically say, for example, by a pat down. However, in Paraguay and Uruguay, the security guards are armed, according to the countries regulations. There is no Code of Conduct but there have not been any incidents reported.
The Company will review existing management practices in all three countries of operation, and devel
op specific management programs to follow the requirements laid out in PS4. As set forth in the ESAP, Minerva will develop and implement a Code of Conduct for security personnel including provisions on how to respond to threats guided by the principle of proportionality. As part of their Community Grievance Mechanism, Minerva will provide a means for communities to raise issues about the Company’s security arrangements or personnel.
Protection and Conservation of Biodiversity: There is no expected significant conversion of natural/critical habitats directly by the client’s direct operations during the course of this project.
Supply chain: Cattle ranching is recognized as one of the key drivers of deforestation in both the Amazon and Chaco regions in South America and child/forced labor is well documented in the sector and region, especially during clearing activities. The historical process of occupation of the Amazon region, where immigrants were encouraged by the military during 70’s and 80’s to take possessions and clear public land, lead to a broad picture of environmental degradation, land conflicts and illegal activity related to development and land issues. More recently, after 2004, the Brazilian Federal Administration started specific programs to contain deforestation and organize land tenure in the region. Deforestation rates were reduced from 27,000 km2 in 2004 to 6,400 km2 in 2011. In 2009, an ambitious program was started to map and title 31 million ha of approximately 85,000 land tenants in the region. Mato Grosso and Pará States (the two states with higher rates of deforestation in the Amazon) developed a step wise approach to bring farmers to environmental conformity called CAR – Rural Environmental Cadastre. Under this program, farmers were invited to provide (through a GIS web based system) the farms’ maps, with land use information and a rehabilitation plan in accordance with Brazilian Forest code requirements. All information from CAR is publicly available and can be downloaded from the web (monitoramento.sema.pa.gov.br/simlam/MapaNavegacao/Flex/MapaCAR.html and monitoramento.sema.mt.gov.br/simlam/Default.aspx?destino=ListarTituloManejo.aspx|modo$5).
Under this context, the private sector, especially agribusiness, was also requested to engage in sector specific agreements and programs to reduce the impacts of integrated chain of productions. Following the soy sector example (in which crushers and traders agreed on a Soy Moratorium in the Amazon), the three major Brazilian meatpackers committed to the Amazon Beef Moratorium (promoted by Greenpeace), as well as to the Legal Beef program, promoted by the Brazilian Federal Public Attorney/Prosecutor. In both cases, slaughterhouses agreed to map their first tier suppliers and ban those who were encroaching on Protected Areas for Biodiversity Conservation, IP Lands (which included a third of the State of Pará), farmers who were black listed on the official forced labor list, farmers who don’t have valid land title documents, farmers involved in land disputes, or embargoed areas from IBAMA and areas deforested after October 2009.
In cooperation with Brazilian Beef Cattle Association (ABIEC) along with another player from the sector, Minerva hired a Company to develop a GIS web based map tool (mapserver) integrated with their own supply chain database, to check E&S information from all suppliers in the Amaz
on Region. The verification system is sophisticated and includes information collected from suppliers (land title documentation, tax number, CAR mapping and registration), comparing farms’ maps with protected areas, IP lands and deforestation. Farmers’ tax numbers are used to check the official forced labor list and embargoed areas from the environmental authority (IBAMA) for every purchase of cattle the Company makes in all slaughterhouses, not only in the Amazon Region. The whole system is audited by an independent reliable third party (BDO international auditing firm).
Although problems in Paraguay are similar to those encountered in the Amazon, albeit at a smaller scale, and as a set forth in ESAP, Minerva will expand/adapt its existing supply chain management practices to Paraguay and other countries, as described above in PS1 section, and has committed to IFC to map out its primary cattle supply chain in Paraguay and progressively limit the procurement to those suppliers that are not contributing to significant conversion of natural and/or critical habitats, or enrolled in forced/child labor violations.
Cattle supply chain is typically divided in three steps: the breeding (0 to 9 months), calves raising (9 to 18 months) and final cattle raising (18 to 36 months). Most of Minerva’s suppliers are the final cattle raisers or, sometimes, integrated calve/cattle raisers, and as a consequence, and despite all efforts in managing sustainability aspects of beef supply, a significant portion of cattle supply chain (second and third tier suppliers) are not covered by existing monitoring scheme. Most of these suppliers also don’t have a final environmental license or legal land title document, and child/forced labor is difficult to monitor in Paraguay (as it does not have a similar black list as in Brazil).
For sanitary reasons, the Ministry of Agriculture has been unsuccessfully trying to implement full cattle traceability system in Brazil in the last ten years, and it is unlikely that Minerva can do it by itself. Minerva’s cattle purchasing criteria and verification system can be considered best practices. As a set forth in ESAP, Minerva will pilot a cattle traceability project incorporating the cattle purchasing criteria described above with its primary suppliers.
Supply chain: Cattle ranching is recognized as one of the key drivers of deforestation in both the Amazon and Chaco regions in South America and child/forced labor is well documented in the sector and region, especially during clearing activities. The historical process of occupation of the Amazon region, where immigrants were encouraged by the military during 70’s and 80’s to take possessions and clear public land, lead to a broad picture of environmental degradation, land conflicts and illegal activity related to development and land issues. More recently, after 2004, the Brazilian Federal Administration started specific programs to contain deforestation and organize land tenure in the region. Deforestation rates were reduced from 27,000 km2 in 2004 to 6,400 km2 in 2011. In 2009, an ambitious program was started to map and title 31 million ha of approximately 85,000 land tenants in the region. Mato Grosso and Pará States (the two states with higher rates of deforestation in the Amazon) developed a step wise approach to bring farmers to environmental conformity called CAR – Rural Environmental Cadastre. Under this program, farmers were invited to provide (through a GIS web based system) the farms’ maps, with land use information and a rehabilitation plan in accordance with Brazilian Forest code requirements. All information from CAR is publicly available and can be downloaded from the web (monitoramento.sema.pa.gov.br/simlam/MapaNavegacao/Flex/MapaCAR.html and monitoramento.sema.mt.gov.br/simlam/Default.aspx?destino=ListarTituloManejo.aspx|modo$5).
Under this context, the private sector, especially agribusiness, was also requested to engage in sector specific agreements and programs to reduce the impacts of integrated chain of productions. Following the soy sector example (in which crushers and traders agreed on a Soy Moratorium in the Amazon), the three major Brazilian meatpackers committed to the Amazon Beef Moratorium (promoted by Greenpeace), as well as to the Legal Beef program, promoted by the Brazilian Federal Public Attorney/Prosecutor. In both cases, slaughterhouses agreed to map their first tier suppliers and ban those who were encroaching on Protected Areas for Biodiversity Conservation, IP Lands (which included a third of the State of Pará), farmers who were black listed on the official forced labor list, farmers who don’t have valid land title documents, farmers involved in land disputes, or embargoed areas from IBAMA and areas deforested after October 2009.
In cooperation with Brazilian Beef Cattle Association (ABIEC) along with another player from the sector, Minerva hired a Company to develop a GIS web based map tool (mapserver) integrated with their own supply chain database, to check E&S information from all suppliers in the Amaz
on Region. The verification system is sophisticated and includes information collected from suppliers (land title documentation, tax number, CAR mapping and registration), comparing farms’ maps with protected areas, IP lands and deforestation. Farmers’ tax numbers are used to check the official forced labor list and embargoed areas from the environmental authority (IBAMA) for every purchase of cattle the Company makes in all slaughterhouses, not only in the Amazon Region. The whole system is audited by an independent reliable third party (BDO international auditing firm).
Although problems in Paraguay are similar to those encountered in the Amazon, albeit at a smaller scale, and as a set forth in ESAP, Minerva will expand/adapt its existing supply chain management practices to Paraguay and other countries, as described above in PS1 section, and has committed to IFC to map out its primary cattle supply chain in Paraguay and progressively limit the procurement to those suppliers that are not contributing to significant conversion of natural and/or critical habitats, or enrolled in forced/child labor violations.
Cattle supply chain is typically divided in three steps: the breeding (0 to 9 months), calves raising (9 to 18 months) and final cattle raising (18 to 36 months). Most of Minerva’s suppliers are the final cattle raisers or, sometimes, integrated calve/cattle raisers, and as a consequence, and despite all efforts in managing sustainability aspects of beef supply, a significant portion of cattle supply chain (second and third tier suppliers) are not covered by existing monitoring scheme. Most of these suppliers also don’t have a final environmental license or legal land title document, and child/forced labor is difficult to monitor in Paraguay (as it does not have a similar black list as in Brazil).
For sanitary reasons, the Ministry of Agriculture has been unsuccessfully trying to implement full cattle traceability system in Brazil in the last ten years, and it is unlikely that Minerva can do it by itself. Minerva’s cattle purchasing criteria and verification system can be considered best practices. As a set forth in ESAP, Minerva will pilot a cattle traceability project incorporating the cattle purchasing criteria described above with its primary suppliers.
Stakeholder Engagement
Community Engagement and CSR Activities:
As detailed above in the PS1 section, the Company does not typically engage with local communities on project related risks. However, the Company has a Corporate Sustainability Department under which the office of the Environmental Manager and the Sustainability Manager both are located and from which the Environmental and Social Management System and the Beef Cattle Sustainable Supply Chain Initiatives are managed as described in PS1 and PS6.
In addition, the Company has developed a CSR programs at an operational level where they focus on several initiatives related to waste and water, in collaboration with local schools and universities. One event that has proven very successful is an annually fashion show made from recycled materials that Minerva sponsors. In addition, the Company focuses on their employee’s family, conducting house visits, especially to potential vulnerable groups (a.g. women on pregnancy leave). Whenever they identify employees in difficult situations, Minerva will help to mobilize the employee community to help each other and provide support.
As detailed above in the PS1 section, the Company does not typically engage with local communities on project related risks. However, the Company has a Corporate Sustainability Department under which the office of the Environmental Manager and the Sustainability Manager both are located and from which the Environmental and Social Management System and the Beef Cattle Sustainable Supply Chain Initiatives are managed as described in PS1 and PS6.
In addition, the Company has developed a CSR programs at an operational level where they focus on several initiatives related to waste and water, in collaboration with local schools and universities. One event that has proven very successful is an annually fashion show made from recycled materials that Minerva sponsors. In addition, the Company focuses on their employee’s family, conducting house visits, especially to potential vulnerable groups (a.g. women on pregnancy leave). Whenever they identify employees in difficult situations, Minerva will help to mobilize the employee community to help each other and provide support.
Av. Antonio Marcos Bernardes, s/no
Rotatória Família Vilela de Queiroz
14.781-545 Barretos – SP – Brazil
Tel: + 55 17 3321-3355
Fax: + 55 17 3332-3041
Rotatória Família Vilela de Queiroz
14.781-545 Barretos – SP – Brazil
Tel: + 55 17 3321-3355
Fax: + 55 17 3332-3041
Environmental & Social Action Plan
| Minerva Beef(32247) Appraisal Disclosure Snapshot – Version 2 | |||
|---|---|---|---|
| Description | Anticipated Completion Date | Status | |
| Implement an Environmental and Social management System consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001, and OHSAS 1800 as described in ESRS. | 31-Dec-2013 | Completed | |
| Implement an Environmental and Social management System consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001, and OHSAS 1800 as described in ESRS | 31-Jul-2014 | Completed |
|
| Implement an Environmental and Social management System consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001, and OHSAS 1800 as described in ESRS | 15-Jul-2013 | Completed |
|
| Implement an Environmental and Social management System consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001, and OHSAS 1800 as described in ESRS | 31-Jul-2015 | Completed |
|
| Implement an Environmental and Social management System consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001, and OHSAS 1800 as described in ESRS | 31-Dec-2015 | Completed |
|
| Implement an Environmental and Social management System consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001, and OHSAS 1800 as described in ESRS | 30-Jun-2014 | Completed |
|
| Implement an Environmental and Social management System consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001, and OHSAS 1800 as described in ESRS | 31-Jul-2015 | Completed |
|
| Implement an Environmental and Social management System consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001, and OHSAS 1800 as described in ESRS | 30-Jun-2018 | Completed |
|
| Develop and formalize an employee grievance mechanism and communicate it to employees | 31-Jul-2014 | Completed |
|
| Minerva will develop a framework for Retrenchment | 31-Jul-2014 | Completed |
|
| Conduct a quantitative risk assessment of all sites located in Sao Paulo State (slaughterhouses and distribution warehouses) following CETESB standard P4.261 as well as the respective risk management program. | 31-Dec-2015 | Completed |
|
| Minerva will conduct an energy efficiency assessment to benchmark themselves with other players in the sector and identify cost-effective opportunities to enhance efficiency | 31-Dec-2015 | Completed |
|
| Minerva will manage security forces in accordance with IFC PS4 requirements as described in paragraph 12 and 13. | 31-Dec-2014 | Completed |
|
| Conduct a study to identify market opportunities for certified products, identifying market niches, developing specific products and marketing approaches. Provided that the study identifies specific market niches developing specific products and marketing approaches, Minerva will develop a Certification Pilot Program defining progressive targets to purchase certified Beef (SAN Standard of sustainable cattle). | 31-Dec-2014 | Completed |
|
| Monitoring Criteria 1.1. Minerva will focus on individual farm compliance, rather than high risk municipalities, using coordinates to verify its suppliers on Chaco biome. 1.2. Upon each ranch coordinate will be applied a 2km buffer to analyze geographical data | 31-Aug-2018 | Completed |
|
| Mapping Exercise: Minerva will collect 250 ranches coordinate on Chaco biome per year, using the cut-off date of January 1st, 2018. | 31-Dec-2018 | Completed |
|
| Procurement restrictions: 1. Minerva will not source from ranches in the Chaco biome overlapping illegal deforestation polygons, using the cut-off date of January 1st, 2018. 2. Minerva will not source from ranches in the Chaco biome located within protected areas officially recognized and titled by the Paraguayan Government. 3. Minerva will not source from ranches in the Chaco biome located within Indigenous Areas officially titled by the Paraguayan Government. | 30-Sep-2018 | Completed |
|
| Starting January 1st, 2022. Minerva will not source from ranches in the Chaco biome overlapping legal and illegal deforestation polygons, using the cut-off date of January 1st, 2022. | 31-Jan-2022 | Completed |
|
| Minerva will pilot a cattle traceability project incorporating existing cattle purchasing criteria. | 31-Dec-2015 | Completed |
|
| Minerva will incorporate labor/child labor issues in the supply chain management system, once an official workable basis is publicly available. | 31-Aug-2018 | Completed |
|
| Minerva will continue to engage on Paraguayan Roundtable for Sustainable Beef (Global Roundtable chapter) and other sector-wide initiatives. This is ongoing until sustainable beef sector management is in place. | 31-Jul-2018 | Completed |
|
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**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.