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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The proposed investment is expected to have limited environmental and social impacts. 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. This is therefore a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy.

Key E&S issues applicable for this investment are: (i) operational licenses of the manufacturing facilities and certification of the supply chain – RSPO certification for palm oil suppliers, and FSC certification for suppliers of wood; (ii) environmental, occupational health and safety (OHS), food safety and social management system and related procedures, including Hazard Assessment and Critical Control Point (HACCP) Principles and ISO 22000 certification; (iii) EHS organizational structure and internal capacity; (iv) adherence to Kenyan labor law, working conditions, standards and OHS risk prevention and management, including each facility’s employees, contractors and nearby communities; (v) Life and Fire Safety (L&FS) provisions and emergency preparedness and response; (vi) use of public utilities (water supply and energy), optimization of water and energy use through project design and resource conservation measures and greenhouse gas emissions; (vii) wastewater collection and treatment, solid waste disposal, potable water quality, treatment and monitoring, hazardous material handling, management and control of pest and rodents; (viii) food and transport safety, and (ix) engagement with communities on EHS, food and traffic safety and social performance.

Impacts related to PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainable Natural Resources Management, PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected with this investment for the following reasons: the land acquisition for the proposed expansion will be within the footprint of the existing facility and the 99-year lease for the Project’s factory was bought privately on a on a willing buyer-seller basis and did not involve involuntary resettlement and/or economic displacement; all facilities are located within existing industrial areas and no conversion of natural/critical habitats has taken place; there is no presence of Indigenous Peoples or known cultural artifacts. In the event that issues anticipated by these PSs arise from the Environmental Impact Assessment Report (EIA), each facility will promptly inform IFC. Screening and assessment of these issues against Performance Standards requirements will be done through each plant’s existing and/or planned environmental and social management system (ESMS).

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 Risk and Impact Assessment In accordance with the Kenyan Environmental Regulations and for purposes of obtaining a building permit for the Project’s new factory, an Environmental and Social Impact Assessment (ESIA) is required. The construction permit will be obtained from the Kenyan Environmental Protection Agency once the EIA is completed and other licenses are obtained (expected by the middle of 2014). The ESIA will meet the Kenyan statutory requirements as well as comply with the IFC’s Performance Standards and the World Bank Group’s Environmental, Health and Safety Guidelines.

The practices implemented at the current Thika factory site complies with all applicable Kenyan legislation. The existing facility has successfully obtained necessary and required provincial and local certificates, permits and/or licenses (e.g. land use and building permit, letter of authorization from the Kenya Environmental Protection Agency, company registration certificate from the Department of Industry, water extraction permit, sewage and waste water discharge permit, electrical safety certificate, Life & Fire Safety certificate, including fire prevention and emergency system, food safety permit). Copies of these were reviewed during the due diligence.

Management Programs. Bidco has implemented a formal and structured approach to social and environmental risk assessment and management, which is governed by comprehensive corporate policies and programs. The Company is currently certified to ISO9001:2008, ISO 14001:2006, BS OSHAS ISO 18000 and ISO 22000 (HACCP), and has also integrated a Total Quality Management Program with ‘The Kaizen Zero-Investment Improvement’ throughout the Company. This divides the Company into “value streams” with Value Stream Champions who manage the processes. The Japanese 5S concept (sorting, straightening, systematic cleaning, standardizing and sustaining) is applied as an integral part of the Kaizen practice. The Project’s new factory will also be managed in this manner, alongside the necessary statutory licenses, including a Certificate of Registration of Workplace, which must be approved by the Director of Occupational Safety & Health Services to allow the occupier use the land as a factory.

The expansion of Bidco’s capacity in existing products will take place on the existing factory site and will follow all applicable Bidco standards and management systems as implemented in the current operations.

The expansion of Bidco’s capacity into new FMCG products will be constructed on a greenfield site in Thika, Kenya, and will require compliance (in addition to the EHS and OHS statutes) to Kenyan legislation for hygiene and safety in the food and drink manufacturing industry. Food, Drug and Chemical Substance License must be obtained to manufacture and sell under the set parameters as prescribed under the law. The Environmental Impact Assessment (EIA) has been completed and has been presented to NEMA for a
pproval and expected approval is by June 2014. Since this Project has not yet commenced, the Environmental, OHS and Labor management system and programs have not been defined. However, Bidco has agreed to develop and implement an Environmental, OHS and food safety management system, including policies, plans, manuals and procedures – consistent with ISO 14001, OHSAS 18001 and HACCP/ISO 22001 - into an Integrated EHS Management System, as currently followed in their existing oil refining and soaps & detergent factory. This will be in compliance with IFC’s PS1 requirements and applicable WBG General and Sector-Specific EHS Guidelines. This will be achieved by the time of plant commissioning which is scheduled for July 2015. Food safety will be supported by a quality control laboratory and food safety standards will be carefully monitored throughout the Project’s value chain. An Environmental Management Plan (EMP), which will form part of the EIA license (the EIA and the EMP will be submitted to the IFC as a condition in the ESAP), will be followed in order to minimize the environmental impacts during the construction and operational phase.

Organizational structure. Bidco will employ appropriately qualified SHE personnel to oversee the Project’s operations. The SHE specialist will be provided with appropriate support from senior management to implement the above and put an ESMS in place that will integrate with other ISO standards applied by Bidco. This is defined in the ESAP. For purposes of construction, the applicable OHS sections will be included in bidding documentation for the technical/financial proposal of the construction contractors in order to ensure that all contractors and sub-contractors are in compliance with labour laws; payment of workers’ legal benefits; timely payment of wages; OHS regulations, including PPE. This will require all bidding contractors to include in their technical proposal a detailed OHS practice handbook that it will implement during construction, including policy, procedures and training requirements. The contractor will effectively ensure implementation of the obligatory practices (as defined in the Handbook) through a role of an OHS officer who will be employed for the new site. Weekly reports from the contractors to the client are expected as part of the contractual arrangements. As defined in the ESAP, BIDCO will provide the selected contractor’s OHS documentation to IFC confirming compliance with the above requirements.



Based on the Company’s organizational chart reviewed during the due diligence, and in accordance with the Kaizen method, there is shared responsibility amongst all executives for the effective implementation of all Bidco procedures and programs, including EHS. The Chief Executive Officer (CEO), and a technical manager who has the appropriate EHS qualifications drive this. Effective implementation of the Integrated EHS management system also falls within the responsibility of Value Stre
am Champions, supervisors and, the plant manager. The Company has detailed processes, procedures, job descriptions, reporting protocols and training schedules in place which ensures that materials, water, energy, waste and waste water monitoring takes place (and is recorded) daily. This will be replicated with the same rigor for the new Project. The Board of Directors is supported by a pool of dedicated professionals in the fields of Management, Finance, Sales, Marketing, Production, Processing, IT, Legal, Human Resources and Environment, Safety and Health.



Supply Chain. Bidco sources raw materials from over 5,000 local farmers as well as from other countries. The Company agrees, as part of the ESAP, to establish a Sustainable Sourcing Policy and a Supplier’s Code of Conduct which will be phased in and will apply to all suppliers of raw materials, especially the ones which are considered “high risk” from a social (harmful child /forced labor) and biodiversity (conversion of natural/critical habitats) standpoint.



Training. The existing factory has implemented plant-level training procedures, in accordance with the Kaizen practice, which ensures continuous training of staff in order to improve operational efficiencies as well as accident and incident prevention. Among others, compulsory safety training is provided to all employees during their induction training while supervisors conduct daily refresher briefings on OHS, resource efficiency and food safety measures before and after every shift. A mentoring program, including job rotation, has been established among plant managers to ensure that skills are shared and to facilitate business continuity. Succession planning is taken into account at each level. Training and development is emphasized and provided by external providers or supervisors, according to an annual training needs assessment. Specific training on first aid is conducted every six months, and emergency or (bomb, earthquake, spills) fire drills are conducted quarterly, in coordination with the security personnel and the local fire brigade. Prior to performing work at the facilities, contract workers are required to attend a formal safety orientation on applicable EHS’s policies and procedures. This is also applicable to visitors.



Monitoring and reporting. As set out in the ESAP, the new Project factory will monitor the following EHS parameters: a) Safety – Lost Time Incidence Frequency Rate (LTIFR), Accident Free Days; b) Sustainability – Carbon (kg/ton), Water Usage (kiloliters/ton), Energy Usage (kWh/ton), wastewater effluent monitoring and air emissions parameters; c) Staff - Retention and training days. In addition, and as outlined in the ESAP, the new factory will define an integrated EHS report format and based on critical EHS key performance indicators (e.g. compliance with legal and regulatory requirements, EHS management system progress report and certification, including food safety management system (HACCP/ISO 2
2000), energy and water consumption and efficiency; air emissions (NOx, SOx, particulates), including GHG emissions; noise levels and management, solid and hazardous waste management and disposal, effluent discharges from the WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers complaints, supplier performance and community engagement activities, and will report annually to the relevant Kenyan authorities and IFC as part of the Annual Monitoring Report (AMR).



Emergency Preparedness and Response. The current factory has emergency preparedness and response policies, procedures and plans in place, in case of accidents, bomb threats, fire, breach of security, oil, chemical and fuel spills, and weather-related emergencies such as flooding. An emergency team has been established within each Value Stream, emergency phone numbers are displayed throughout the factory, with fire assembly points and directional signage. A security control room monitors all parts of the site via CCTV on a continuous basis.



Community engagement. The Company’s website, http://www.bidco-oil.com is fully online and accessible to suppliers, customers and employees and an email address is printed on all product labels: mailto:happyhealthyliving@bidco-oil.com. Feedback is given timeously and complaints are taken seriously.



The Company also works with all of its partners, suppliers and stakeholders (via representation on business forums and associations) as well as more than 5,000 farmers families. Public meetings form part of the statutory scoping phase of the ESIA process for the Project’s new factory, which will be facilitated by a specialist consultant, who will document and address any issues and/or complaints raised by surrounding stakeholders.



Bidco will adopt a formal Stakeholder Engagement Plan incorporating a Community Grievance Mechanism as part of its EHS management system, as articulated in the attached ESAP. A specific management procedure will be developed and implemented before construction phase. Its implementation will be assigned to the Corporate Communications & Public Relations (CCPR) Team Leader who is currently responsible for communications.

Human Resources (HR) Policy and Management. Bidco employs 2256 people, of which 1403 are contract workers. There are 2156 male employees (1360 of these are contract workers) and 100 women (of which 43 are contract workers). In the next two years, it is projected that the total employee numbers will grow to 2569 (contract workers will comprise 1583 people). The policies and practices that guide the Company’s approach to the management of human resources comply with IFC’s Performance Standard 2 requirements. Bidco is committed to equal opportunities, gender equality, and is against sexual harassment and discrimination, as articulated in its human resources (HR) Manual. Succession planning is actively pursued within the Company.



Employment terms at Bidco Oil Refineries Ltd (BORL) are either open-ended contracts, or fixed term employment, but all are regarded as employees and have equal rights and benefits. The minimum working age in the East Africa region is 18 years of age, which is strictly applied. All candidates are required to go for a medical fitness test, and only when a candidate is certified medically fit, the candidate will be employed. All employees of Bidco are provided with workplace accident and occupational illness insurance.

It is the policy of Bidco to conduct orientation as per the Induction Guidelines booklet for new employees. Casual workers also receive training but are not required to work for more than five (5) consecutive days in a seven (7) day week. Casual workers are also provided with uniforms and required safety equipment while at work.

The Company considers normal working hours to be fifty-two, (52) hours per week spread over six days (as allowed in Kenyan labor law). All employees are provided with an employee identification card which they are required to display at all times when within the factory premises. Sanitary facilities and water are provided for employees (male/female toilets and showers). Free food and tea is provided at the Company’s staff canteen for employees.

All employees are entitled to annual leave after the completion of 12 months in employment (between 21 and 30 days depending on the level; after two months continuous service, each employee is entitled to a maximum of seven (7) days sick leave with full pay and thereafter to a maximum of seven (7) days sick leave with half pay in each period of 12 months consecutive service with the Company. Female employees do not forfeit their annual leave when taking maternity leave (3 months); male employees are given 2 weeks paternity leave.

All permanent employees are entitled to transport to and from work. All employees are entitled to a free bar of soap per month and may purchase the company products at discounted prices for domestic use.

Employee wellness. There is no official HIV/Aids voluntary testing or program, however there is annual employee medical monitoring (medicals), particularly for food handlers (this is a statutory requirement in
Kenya) and a requirement for employees to have a medical fitness certificate. Health awareness information is available which includes employee wellness. Seasonal absenteeism is experienced from malaria, however treatment in clinics and hospitals is well established and recovery rates are rapid. The Company subscribes to a network of hospitals where employees are fully subsidised for the treatment of injuries or illnesses.



Working Conditions. In Kenya, there are 2-3 dominant unions that employees are free to join; a recognition agreement exists (since Nov 2012) between the Chemical and Allied Workers Union of Kenya and the employees of Bidco. Prior to this arrangement, the employees were not unionized.

All employers in Kenya are required to register their workers with the National Social Security Fund (NSSF). Employers must make a monthly contribution to the pension body on behalf of the workers so that the workers receive a pension after retirement. It''s illegal to not register with the NSSF or to neglect to make the monthly payments. All businesses are also required to register their employees with the National Hospital Insurance Fund (NHIF) and make a monthly contribution on behalf of the workers. The money is used to take care of employees'' medical bills if they''re admitted to the hospital.

Employees are eligible to join BESCO, a savings and credit co-operative society for staff of Bidco Oil Refineries Limited (BORL) from which employees may secure loans to cater for their needs.

Grievance Mechanism. Within the factory, there is an established grievance mechanism procedure which meets IFC’s PS2 requirements and which is found in the Human Resources Manual. This procedure includes steps to be taken for workers to raise concerns, discuss solutions, and provide feedback. Awareness-raising on grievance mechanism procedures take place during the induction training. The grievance mechanism also applies to contract workers.



Training. Within the Total Quality Management Program and ‘The Kaizen Zero-Investment Improvement’, a program called ‘Total Employee Involvement’ is observed and implemented. The Kaizen process emphasises shared responsibility, shared solution-building and consensus and training. As a result, workers feel empowered and turnover is low. New employees are taught these practices to enable them adapt to the Bidco work environment. Bidco encourages continuous competency development through process-based training. Each department/ process has a fully trained departmental trainer with the responsibility for guiding their colleagues in identifying training and development gaps in liaison with the staff training and development unit. Departmental meetings are recorded and any significant issues (such as safety incidents or letters from authorities) are discussed at Board meetings. Board resolutions are recorded and communicated to employees. This practice will be applied to the new operations.



Occupational Health and Safe
ty. As indicated in PS 1, Bidco is OHSAS 18000 certified and has comprehensive OHS management system procedures in place with ongoing monitoring. The Occupational Health & Safety (OHS) procedures are followed rigorously. Employees are provided with personal protective equipment (PPE) in accordance with their job descriptions and the PPE issuance policy. Warnings about hazards and hygiene are clear and are posted onto walls or equipment in order to avoid incidents. Employees are generally compliant and do wear/use PPE. The site visit confirmed effective implementation of these measures. In the past year, occupational health and safety incidents on the Thika oil refining site have been minor, generally related to the packers (backache, cuts and bruises). An incident report is compiled with corrective measures (displayed on a white board), and records are kept for all injuries. No nurse or doctor is on duty on the factory site; employees with injuries are taken to the local hospital and treated at the Company expense or under the National Hospital Insurance Fund (NHIF).



All OHS parameters are recorded in each Value Stream section on large boards, along with responsibilities and corrective actions. Daily and weekly operational meetings take place to review each Value Stream’s performance, including OHS, and identify necessary mitigation measures. Minutes of the weekly and monthly OHS meetings are registered and corrective action plan (CAP) tasks addressed immediately. Effectiveness of this system has been verified during due diligence. Annual OHS Risk Assessments are performed across the Company by and independent certified OHS auditor in order to maintain the OHAS 18000 certification, as well as to fulfill the requirements of the Kenyan Occupational Health & Safety Act (2007) Part II, S6(3), (4) and (5). The reports arising from these audits (most recently undertaken in 2012) were verified during the due diligence. Annually, an independent engineer is also required to do a statutory inspection of the high pressure boiler. The due diligence verified that this is implemented.



Life and Fire Safety. In Thika, the fire detection system design and maintenance is outsourced to a certified company. 21 first aiders are trained on an ongoing basis (refresher courses every 6 months), and emergency procedures and phone numbers are displayed in the factory for easy access. Fire drills and lock-down procedures are held quarterly, and are expected to occur at the new site with the same frequency. The Company also has 50 trained fire marshals and 28 Safety Committee members. A siren, fire extinguishers and smoke detectors have been installed in the office buildings and factory, and are maintained regularly. There is clear signage indicating either warnings, fire hazard or fire evacuation, wherever it is appropriate. Fire hydrants are checked every 6 months; fire hoses in the packaged goods area are connected to a separate water tank system that is fully auto
mated (it is activated from the security control centre). Other safety elements in place in the Thika factory include: an intercom; firewalls; and a fire escape. Every shift, safety briefings are given, and safety incidents or near misses are discussed at all departmental and general staff meetings (monthly). Fire and life safety training is currently provided to all workers according to the Emergency Preparedness and Procedures document. Other policies address: bomb & earthquake emergency response; first-aid emergency response; and spill emergency response on site. First aid kits are available in the Company office, and first-aiders are trained in each value stream (identifiable by a different coloured hard hat). The factory has not suffered any fatalities since commissioning (2002). Visitors to the sites receive safety information and are fitted with PPE (during construction phase) or hair covering (during operation) and a white coat or reflective vest.



The Company is committed to implementing best practice measures, and agrees to compile a comprehensive Fire and Life safety plan for the new site, with appropriate procedures for both construction and operation phases. These are included in the attached ESAP. Consistent with its current oil refining and detergent manufacturing operations, the Project will only employ people in accordance with the existing HR Manual and ensure consistent implementation and compliance with IFC PS2 requirements.

Potential pollution issues identified during the appraisal visit are those typically associated with construction and operations include, amongst others, dust, gas and diesel storage and use, storm water runoff, diesel and oil spills, litter and construction waste management. The Safety, Health and Environment (SHE) manager will be responsible for ensuring that the Company standards and policies are implemented at all Bidco operations.



The area for the Project’s new factory has been cleared and has reticulated (municipal) sewerage treatment, a water supply and electricity. The entire development area receives its electricity from the municipal grid, and usage will primarily be associated with manufacturing machinery, refrigeration and lighting. The physical infrastructure is well developed, with tarmac access roads, storm water drainage and electric street lighting. Sewage discharges to the city treatment plant. The site will have a dual access, with traffic and access control. Kenyan building standards impose solar water heating, grey water systems and local material use, which will be incorporated into the design of the new premises. Bidco is aiming as far as possible to have a ‘zero waste” plant.



Resource management. Energy, water and waste management and conservation is emphasised in the factory and throughout Bidco’s operations. The Kaizen philosophy emphasises process efficiency, and this is taken very seriously. Boards at every value stream record the daily and monthly energy and water use, against Bidco targets or benchmarks, which are reported at management meetings. When targets are exceeded, corrective plans are put in place with the input from all employees working in the Value Stream. Materials are only ordered, and manufacturing of the different brands are shifted and adjusted, according to real time orders from customers.



Management of solid & hazardous waste. Waste at the existing factory is almost all reused or recycled (paper is sent to a Kenyan company for toilet paper production; ink cartridges are sent to HP, equipment is sold or salvaged for parts, packaging is returned to the process and reused). Husks from the seed crushing (sunflower, maize and soybean) operations are fortified with Vitamin A & D and sold for animal feed. Hazardous wastes present in operations are minimal and characterized by used oils and used reagents from laboratory’s product analysis. The former are collected by authorized Kenyan service providers. Chemicals are purchased for the 4 quality testing laboratories and for the fractionation process. 15 chemicals are used in the oil and soap manufacturing process – caustic soda, phosphoric acid and hexane are the most hazardous. These are stored in underground tanks and are strictly controlled and handled by trained employees (there is also restricted access). An inventory of hazardous substances is maintained in the factory with supporting MSDS; in the event of a spill, adsorbents are used to r
emove components and disposed to a hazardous site via a government-approved/licensed waste contractor. Cylinders of compressed gas are used in some work situations. Training is provided on gases to be used and the correct procedure for their storage, handling and use.



Energy use. An energy co-generation plant has been erected at the oil refining factory site. The co-generation plant uses waste biomass as a fuel feed (such as coffee husks), supplemented with wood, which generates steam for energy. When fully operational, the turbine has a capacity to generate 2.25MW of electrical power, with a biomass consumption rate of 150-200 metric tons a day. This will be replicated at the new site. Three diesel generators delivering 2500 KVA are on standby power availability on site presently in Thika and the existing diesel tank storage area has a bund wall for purposes of secondary containment, checked and serviced regularly. Fuel for the generators in the new site will be delivered via two underground storage tanks with leak detection systems and alarms.



Water use. The current water use is 32 million litres per annum, provided partly from municipal and partly from borehole water, which is extracted and treated on site. The projected water consumption at the new factory is approximately 350,000L per day (70Mn litres per annum). Municipal water in Kenya is not compliant with WBG drinking water parameters; therefore a water treatment plant (reverse osmosis) will be included in the design of the Project’s new factory. The clarified waste water will be discharged to sewer, as per the license issued by the Kenyan Water and Sewage Company, certifying that effluent arising from any drain, sanitary convenience or nuisance complies with their standards. Monitoring of this water will be undertaken and the results submitted to IFC via the Annual Monitoring Report (AMR) to confirm compliance with the WBG EHS Guidelines as well as the Kenyan Environmental Management and Coordination, (Water Quality) Regulations (2004).



Waste water. Bidco prides itself on setting more stringent effluent pollution levels than the Kenyan waste water treatment guidelines. As articulated in the ESAP (as part of the ESMS mentioned in PS1), the Company has committed to installing a waste water treatment facility which will treat waste water to comply with WBG General EHS Guidelines.



Noise. Annually, an audit is conducted across the factory site. Noise levels are tested throughout the factory. In four areas, noise levels exceed 80dB, and in these areas ear protection plugs are worn by workers and enforced. This practice will also be followed at the new facility.



Pest management and control. Fumigation is outsourced at the current operations, and this will also be the case on the Project’s new site. Fumigant is sprayed outside the factory on a weekly basis, and twice a month inside the factory. As defined in the ESAP (as part of the ESMS mentioned in PS1), Bidco is required t
o compile and implement a pest control and management procedure that is consistent with the WBG General EHS Guidelines. The relevant government departments (Health & Labour) in Kenya undertake regular inspections to check food handling procedures, certification of food handlers and check if product quality meets the legal requirements.



Dust. Dust will be an issue during construction and will be suppressed with water sprays. No ozone depleting substances or asbestos is utilized on the existing factory site, or will be used on the new site. Waste from construction sites will be collected in skips, which will be collected by the local municipality providing waste collection and disposal services. A waste management plan for the new site, as required in the attached ESAP (as part of the ESMS mentioned in PS1) , will give details of how waste is to be minimized, separated and disposed during both construction and operational phases. Storm water drainage will be designed in accordance with the local authority’s specifications.

Community Health and Safety. Distribution of product is currently outsourced to 8 groups of owner-managed truck companies or SMEs, all of which have exclusive contracts with Bidco. The drivers are all trained on road safety, occupational health and safety, and rudimentary first aid. All are screened with respect to licences, fines, training, language competency etc. The new project will distribute product via 54 partners in the same way. They will also undergo orientation training and must comply with all of Bidco’s policies. In BORL, any person driving a Fork Lift or a Front End Loader is required to have a license or a permit to operate the equipment, as per the Bidco guidelines.



In relation to food safety, all BIDCO products are quality tested in on site laboratories. BIDCO applies HACCP (Hazard Analysis, Critical Control Points) systems through the manufacturing process, industry monitoring of residues/contaminants. The shelf-life of products varies from 6 to 24 months and this is intended to be the case for the new products also. All through the factory, hygienic practices are enforced – hand washing must take place every half hour. Food is prepared in canteens/kitchen facilities on site. These require a permit from the Health authorities in accordance with the Food Safety and Food Handling regulations. Employees working directly with product in the factory, or food in the canteen, are trained in food safety issues and follow established procedures for hand washing, working attire (clothes, shoes, gloves and hair coverage), and how to handle injuries and diseases. A grease trap is installed at the effluent discharge point, which is cleaned daily. This will be implemented at the new site.



Security. Bidco employs unarmed security staff at the Thika factory, whose role is to control access, patrol, identify hazards and coordinate fire safety. They are registered with the appropriate security body and have certificates of compliance. In addition to the security personnel employed by BIDCO, the Company also outsources to a security company (Security Group) for specific emergency situations (armed response), advice or audits and identification of security weaknesses. Security incidents experienced in the past are predominantly theft of product or hardware. Investigations are undertaken in cooperation with the police. A boundary wall of 2-3m will be erected around the Project’s new production site, with dual access.



Community Grievance Mechanism: Regular interaction and communication takes place within the oil refining and soap factory through an open door policy. A grievance mechanism has been adopted in order to receive and to address any issues and/or complaints raised by surrounding stakeholders and end-customers resulting from production and transport activities. This is done via the website, the email address mailto:happyhealthyliving@bidco-oil.com that is widely advertised on products, telephonic communication, and walk-in visitor
s. Complaints and suggestions are given equal attention by management. Every Director receives a daily report of comments, complaints, suggestions and requests for meetings from stakeholders, for their information and response.

The Company’s website, http://www.bidco-oil.com is fully online and accessible to suppliers, customers and employees. Suggestions and opinions are invited using the email printed on all product labels: mailto:happyhealthyliving@bidco-oil.com. Feedback is given timeously and complaints are taken seriously.The Company also works with all of its partners, suppliers and stakeholders (via representation on business forums and associations) as well as more than 5,000 farmers families. Public meetings form part of the statutory scoping phase of the ESIA process for the Project’s new factory, which will be facilitated by a specialist consultant, who will document and address any issues and/or complaints raised by surrounding stakeholders.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. The Company will also be requested to place an advertisement in a local newspaper to inform the public that results from IFC’s environmental and social review (ESRS) and ESAP is available at public sites, such as municipality offices.

Vimal Shah
Director, Bidco Oil Refineries Limited
Bidco Group
P.O. Box 239 – 01000 Thika, Kenya
Tel: 254 67 282 1000
Fax: 254 67 30103
Email: mailto:director@bidco-oil.com

Broad Community Support is not applicable for this project

Bidco Kenya(33385) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
BIDCO will design and implement an Integrated Environmental, Occupational Health and Safety (OHS), and Social Management System – consistent with ISO 14001, OHSAS 18001 and HACCP/ISO 22001 – in accordance with IFC PS1 requirements to be reviewed and approved by IFC, defining roles and responsibilities and manual procedures (to enable it to comply with Kenyan laws and regulations, IFC Performance Standards and applicable WBG’s Environmental, Health and Safety (EHS) Guidelines). The Management System will include mechanisms for the QA/EHS/Certification manager to report monthly environmental and social (E&S) monitoring results to the CEO who will need to sign off on the reports. Bidco will finalize job descriptions defining specific E&S roles and responsibilities, including supervisory and accountability framework, satisfactory to IFC, including composition of EHS Committee	30-Mar-2015	Completed	Completed	12/19/2018
Bidco will design and implement an Integrated Environmental, Occupational Health and Safety (OHS), and Social Management System (or an integrated ESMS) – consistent with ISO 14001, OHSAS 18001 and HACCP/ISO 22001 – in accordance with IFC PS1 requirements to be reviewed and approved by IFC, defining roles and responsibilities and manual procedures (to enable it to comply with Kenyan laws and regulations, IFC Performance Standards and applicable WBG’s Environmental, Health and Safety (EHS) Guidelines). The Management System will include mechanisms for the QA/EHS/Certification manager to report monthly environmental and social (E&S) monitoring results to the CEO who will need to sign off on the reports.	30-Sep-2015	Completed	Completed	12/19/2018
BIDCO will adopt Key Performance Indicators (KPIs) to mainstream EHS parameters, including: a) Safety – Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (kiloliters/ton) and Efficiency - Consumed versus tons produced; Energy Usage (kWh/ton) - Energy consumed/tons produced; Wastewater monitoring effluents and air emissions parameters; c) Staff - Retention - Number of full time equivalents leaving in the period /Avg. full time equivalents - and Training days - Number of training days provided to new and existing employees. Monthly and annual report will be reviewed during BIDCO’s monthly EHS Review and annually during the Company’s planning and budgetary management review.	28-Dec-2015	Completed	Completed	12/19/2018
Finalize job descriptions defining specific Environmental and Social (E&S) roles and responsibilities, including supervisory and accountability framework, satisfactory to IFC, including composition of an Environmental, Health and Safety (EHS) Committee	30-Mar-2015	Completed	Completed	12/19/2018
BIDCO will prepare an integrated EHS report format based on critical EHS key performance indicators (e.g. compliance with legal and regulatory requirements, including the EIA’s Environmental Management/Monitoring Plan, EHS management system progress report and voluntary certification, including food safety management system (HACCP/ISO22000), energy and water consumption and efficiency; GHG emissions; solid and hazardous waste management and disposal, effluent discharges from the WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers and community complaints, supplier performance and community engagement activities) and report annually to relevant Kenyan authorities and IFC as part of the Annual Monitoring Report (AMR).	30-Jul-2016	Completed	Completed	12/19/2018
Evidence of complete and effective implementation of the integrated ESMS and procedures at the plant (e.g. final documentation of the ESMS, including policies, plans, manual procedures and programs, e.g. EHS training logs, EHS monitoring and reporting plan, emergency preparedness and response, community and suppliers grievance policy and mechanism, OHS policies and procedures implementation, plant’s key performance indicators monitoring record, including liquid, air and solid effluents, waste management, hazardous chemical, fleet efficiency and safety management plan, food security procedures, wastewater, solid plant, minutes of progress reviews).	30-Mar-2015	Completed	Completed	12/19/2018
As part of its overall ESMS (please refer to ESAP, Action Item 1) BIDCO will develop and implement a specific management procedure for its supply chain, which will include the development and implementation of a Supplier’s Code of Conduct (including prohibition of harmful child/forced labor) which will be mainstreamed into contractual agreements with major suppliers. Implementation of this Code will be done through Bidco’s upstream team and associated training.	01-Oct-2015	Completed	Completed	12/19/2018
Bidco will adopt Key Performance Indicators (KPIs) to mainstream EHS parameters, including: a) Safety – Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (kiloliters/ton) and Efficiency - Consumed versus tons produced; Energy Usage (kWh/ton) - Energy consumed/tons produced; Wastewater monitoring effluents and air emissions parameters; c) Staff - Retention - Number of full time equivalents leaving in the period /Avg. full time equivalents - and Training days - Number of training days provided to new and existing employees. Reports will be reviewed during BIDCO’s monthly EHS Review and annually during the Company’s planning and budgetary management review.	30-Sep-2015	Completed	Completed	12/19/2018
Bidco will develop and implement Human Resources Policies and Procedures appropriate for its workforce that set out the approach to managing workers consistent with the requirements of Performance Standard 2 and the Kenyan Labor Code. A grievance mechanism will be included as part of the procedure.	30-Jul-2015	Completed	Completed	12/19/2018
Bidco will prepare an integrated EHS report format based on critical EHS key performance indicators (e.g. compliance with legal and regulatory requirements, including the EIA’s Environmental Management/Monitoring Plan, EHS management system progress report and voluntary certification, including food safety management system (HACCP/ISO22000), energy and water consumption and efficiency; GHG emissions; solid and hazardous waste management and disposal, effluent discharges from the WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers and community complaints, supplier performance and community engagement activities) and report annually to relevant Kenyan authorities and IFC as part of the Annual Monitoring Report (AMR).	30-Mar-2016	Completed	Completed	12/19/2018
Bidco will develop and implement Occupational Health and Safety (OHS) policies and procedures demonstrating compliance with WBG’s EHS requirements. The policies and procedures should include identification of managers responsible for OHS performance, on-going training, and a mechanism for reviewing deviations from procedures and improving performance both during construction and operational phase.	30-Jul-2014	Completed	Completed	12/19/2018
As part of its overall ESMS (please refer to ESAP, Action Item 1) BIDCO will develop and implement a specific management procedure for its supply chain, which will include the development and implementation of a Supplier’s Code of Conduct (including prohibition of harmful child/forced labor) which will be mainstreamed into contractual agreements with major suppliers. Implementation of this Code will be done through Bidco’s upstream team and associated training.	30-Mar-2015	Completed	Completed	12/19/2018
Bidco will a) develop and implement a safe driver and transport safety vehicle procedure, including training and monitoring program for its drivers and contractors (to the extent that it is commercially feasible, for the fleet of transportation sub-contractors) emphasizing the following: safety aspects among drivers, improving driver skills, licensing of drivers, provision of this procedure in contractual arrangements, and overall truck maintenance; and b) Bidco will adopt a formal Stakeholder Engagement Plan incorporating a Community Grievance Mechanism as part of its EHS management system, as articulated in the attached ESAP. A specific management procedure will be developed and implemented before construction phase	30-Jul-2014	Completed	Completed	12/19/2018
Bidco will develop and implement Human Resources Policies and Procedures appropriate for its workforce that set out the approach to managing workers consistent with the requirements of Performance Standard 2 and the Kenyan Labor Code. A grievance mechanism will be included as part of the procedure.	30-Mar-2015	Completed	Completed	2/8/2019
Bidco will (a) develop and implement Occupational Health and Safety (OHS) policies and procedures demonstrating compliance with WBG’s EHS requirements. The policies and procedures should include identification of managers responsible for OHS performance, on-going training, and a mechanism for reviewing deviations from procedures and improving performance both during construction and operational phase. (b) Obtain the construction contractor’s OHS and EMP manual and contractual OHS requirements, consistent with EIA documentation. Assign a BIDCO’s OHS construction supervisor and the Factory Architect’s own OHS supervision oversight responsibilities and inspection schedule.	30-Mar-2015	Completed	Completed	12/19/2018
Diesel storage tanks on all sites are to be restricted (boundary fence or wall) and bunded with secondary containment. If underground storage tanks are used, leak detection systems, pressure testing and monitoring will be implemented, as well as providing sumps and appropriate remediation protocols in the event of any spillage or contamination incident.	30-Mar-2015	Completed	Completed	12/19/2018
Bidco will develop and implement a Pest and Rodent Management System Procedure. The procedure will eliminate the use of WHO Class 1a and 1b chemical formulations in its facilities. The company will modify service contracts for all Bidco sites to require service providers’ mandatory training of its workers and adequate PPE based upon MSDS and/or ICSCs for the materials used.	30-Mar-2015	Completed	Completed	2/8/2019
Bidco will install a water treatment facility at the new factory, and implement a water monitoring plan for the water being used in production. A water monitoring program will be implemented which must include all parameters to comply with WBG’s EHS requirements and Kenyan Environmental Management and Coordination (Water Quality) Regulations (2004).	30-Mar-2015	Completed	Completed	2/8/2019
Bidco will design and construct a Waste Water Treatment unit in compliance with Kenyan and applicable WBG’s effluents guidelines, especially for pH, BOD, COD, total suspended Solids, Grease, total nitrogen and total phosphorus. All effluents from the new Bidco factory will be treated when its WWT plant expansion is completed A wastewater monitoring program will be implemented which must include all parameters within WBG’s effluents guidelines.	30-Mar-2015	Completed	Completed	2/8/2019
Bidco will a) develop and implement a safe driver and transport safety vehicle procedure, including training and monitoring program for its drivers and contractors (to the extent that it is commercially feasible, for the fleet of transportation sub-contractors) emphasizing the following: safety aspects among drivers, improving driver skills, licensing of drivers, provision of this procedure in contractual arrangements, and overall truck maintenance; and b) Bidco will adopt a formal Stakeholder Engagement Plan incorporating a Community Grievance Mechanism as part of its EHS management system. A specific management procedure will be developed and implemented before construction phase.	30-Mar-2015	Completed	Completed	2/8/2019