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

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. The environmental and social risks and impacts associated with this project are limited, site-specific and can be readily addressed through generally accepted mitigation measures as described in this document and the attached Environmental and Social Action Plan (ESAP).

IFC’s review indicates that the investment will have impacts that must be managed in a manner consistent with Nigerian legal and regulatory requirements, the above mentioned Performance Standards and the World Bank Group’s General and Sector-Specific (Food and Beverage) Environmental, Health and Safety (EHS) Guidelines. The plot of land for the plant was leased from the Estate Landlord, Tonio Property Limited, therefore, PS5 – Land Acquisition and Involuntary Resettlement is not considered relevant to the project. The plant is located in an existing semi-industrial area, therefore, PS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources is not considered relevant. Finally, PS7 – Indigenous Peoples and PS8 – Cultural Heritage have also not been identified as relevant to this project. In the event that issues anticipated by these PSs arise, BFB will promptly inform IFC.

The potential environmental, social, occupational health and safety risks associated with this project relate to environmental assessment and management in line with Nigerian Laws; food hygiene and safety procedures, including Hazard Assessment and Critical Control Point (“HACCP”) Principles; management of labor and working conditions, including occupational health and safety measures during the operation phase; resource (water and energy) efficiency during operations; solid and liquid waste management and the design and construction of the facility in accordance with recognized Nigerian building standards, including those related to life and fire safety.

BFB has presented plans to address these potential environmental and social impacts to ensure that upon the implementation of the specific agreed mitigation measures, the Project is expected to be in line with the applicable Nigerian laws and regulations, IFC’s Performance Standards and World Bank Group (WBG) general and sector-specific Environmental, Health and Safety (EHS) Guidelines. Information on how these potential impacts are addressed is contained in the following paragraphs and in the attached Environmental and Social Action Plan (ESAP).

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.

IFC’s assessment considered: BFB’s management of its environmental and OHS performance; compliance with Nigerian permitting requirements; and public engagement and disclosure of information about its operations.



Environmental and Social Assessment and Identification of Risks and Impacts: An environmental baseline assessment study was conducted for this project and submitted to Oyo State Ministry of Environment and Habitat. The report was acknowledged by the ministry and approval was granted for the construction and operation of the project. The baseline study identified the pre-operation levels of environmental parameters within the project site and the affected environment – air quality (nitrous oxides (NOx) sulfuric oxides (SO2), particulate matter etc); water quality (surface and groundwater parameters – dissolved oxygen, pH, dissolved solids, suspended solids, ions etc); soil quality (composition, metals and non-metals etc); and noise levels at various locations on the site.



As BFB is a greenfield operation, the Company has not yet adopted an environmental and social management system (ESMS) and associated operational procedures; these are currently being developed by the Plant Manager. BFB plans to develop an ESMS consistent with the requirements of ISO 14001 and also implement Hazard Analysis and Critical Control Points (HACCP) procedures for food safety and hygiene. As defined in the ESAP, BFB will be required to develop and implement an Environmental and Social Management System in line with the requirements of this Performance Standard. BFB has also not yet established an Occupational Health and Safety (OHS) policy or procedures; these are being developed as part of the plant start-up process. The development and implementation of these procedures is included in the ESAP for this project; BFB will be required to develop and implement OHS procedures that meet the requirements of OHSAS 18001 and Performance Standard 2. No OHS procedures were developed for the construction of the plant; the project was managed by the estate landlord. BFB will be required to develop OHS and implement procedures to manage contractors for any future construction projects. BFB will provide appropriate PPE for all employees and provide the required training to ensure that employees work in a safe manner.



Management Programs: As part of the ESMS, BFB will be required to develop management programs to address the risks and impacts identified, including procedures related to OHS, the management of energy, water, raw materials and wastes (solids and liquids). As indicated in the attached ESAP, BFB 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 - as well as the requirements of this Performance Standard and applicable WBG General and Sector-Specific EHS Guidelines.



Monitoring and Review: BFB has p
lans in place for effluent and noise monitoring. The Company will be required to formalize the monitoring and review process as part of the ESMS. All parameters that require monitoring in line with local regulations and WBG EHS guidelines will be monitored, as defined in the ESAP. Environmental audits will be conducted by BFB and submitted to Oyo State Ministry of Environment and Habitat and to the National Environmental Standards and Regulations Enforcement Agency (NESREA); this will be done once in three years. BFB will define Key Performance Indicators (KPIs) in order to monitor the following EHS parameters: (a) Safety – Lost Time Incidence Frequency Rate (LTIFR), accident free days; (b) Sustainability – carbon (kg/ton), water consumption (kiloliters/ton), energy consumption (kWh/ton), wastewater parameters and air emissions parameters from boilers and generators in line with WBG’s General and Sector specific EHS guidelines; (c) Staff - retention and training days. In addition, the EHS Manager/Officer will define an integrated EHS report to cover key EHS KPIs, such as compliance with legal and regulatory requirements, EHS management system progress report and certification, including quality control and the food safety management system (HACCP/ISO22000), energy and water efficiency; air emissions, waste management, effluent discharges from the WWTP, compliance with national OHS requirements, customer and community complaints, and community engagement activities, and present it to senior management for review.

Organizational Capacity: Under the proposed structure from BFB, the Quality Assurance (QA) Manager will be responsible for implementing and managing the ESMS. BFB plans to retain an external consultant to provide additional support to the QA Manager. As set forth in the ESAP, BFB will be required to formally confirm the appointment of the person(s) responsible for EHS issues.



Emergency Preparedness and Response: BFB currently has no formal Emergency Response Plan. This plan and the associated procedures will be developed to meet the requirements of this Performance Standard. With regards to fire safety, BFB has plans in place for a site-wide firefighting system and associated fire safety equipment; installation is expected to be completed in the last phase of construction. The plant was designed and constructed in line with National (United States) Fire Protection Association (NFPA) Standards 1(fire code) & 20 (installation of stationary pumps). Regular inspections and fire drills will be carried out by the Oyo State Fire Brigade and certificates of compliance will be provided to BFB, as applicable.



External Communications and Grievance Mechanisms: There has been no community engagement as part of this project and BFB currently has no procedure for external communications or grievance mechanism; this will be addressed as part of the ESMS. Although the plant is located in a semi-industrial estate, the presence of residential uni
ts in the estate requires BFB to have a process to address any grievances. Also, there is a small village two kilometers from the estate. The main access road to the estate is a busy highway and there are a number of other companies within the estate using this route. Within the estate, the access road to the BFB plant is narrow and untarred. The estate landlord is expected to improve access to the site. BFB will be required to develop a traffic management plan to control the movement of its trucks within the estate to minimize any potential impacts on the residential community and provide adequate driver safety training to truck drivers.

IFC’s review considered BFB’s operations with regards to fair, safe and healthy working conditions in the BFB plant (based on the review of documents made available during due diligence).



Human Resources Policy and Management: When fully operational, BFB will employ a total of 316 staff – 226 direct employees and 90 contractors – in both the Ibadan and Lagos locations. A proposed 20% of the workforce will be women and the minimum age of employment is expected to be 23-25 years (the minimum employment age in Nigeria is 18). There is an Administration and Personnel Manager who is responsible for all human resources related issues.



The terms and conditions of employment for direct employees are described in the Employee Handbooks – the junior staff handbook and the senior staff handbook. The handbooks cover the employment policy, employment requirements, employee obligations, working hours, overtime, leave, benefits, company rules, disciplinary procedures, termination procedures, and grievance mechanism. The handbooks will be provided to all employees as part of the induction process. All employees will be provided with medical care (for employees and their families) through a registered Health Management Organization (HMO) and employees will also be covered by the pension and death-in-service benefits scheme.



Worker’s Organization: BFB employees will be free to form or join workers’ organizations; the relevant union in this sector is the Nigerian Union of Food, Beverage and Tobacco Employees (NUFBTE). Although the workforce is not fully in place and no agreement has been signed with NUFBTE, the requirements of NUFBTE have been incorporated into BFB’s relevant HR policies and procedures.



Non-Discrimination and Equal Opportunity: The employee handbooks include a brief employment policy which indicates equal opportunities for all employees. As set forth in the ESAP, BFB will be required to develop and implement a formal policy on non-discrimination and equal opportunity to cover all operations.



Occupational Health and Safety (OHS): As mentioned above, BFB has not yet adopted an OHS policy or developed procedures; the development and implementation of these procedures is included in the ESAP for this project. BFB will provide appropriate PPE for all employees and provide the required training to ensure that employees work in a safe manner.



Third Party Workers: BFB will employ a number of third party workers, mostly as laborers, drivers and cleaners. The contract management with the labor broker will ensure that payments due to third party workers are paid as agreed and training will be provided to these workers. All third party workers will be provided with the staff handbook and will have access to the grievance mechanism. As set forth in the ESAP, BFB will be required to develop and implement a procedure to ensure contractors’ labor and working conditions comply with the requirements of this Performance Standard.

IFC’s review considered the BFB’s management of its operations, resource use and waste disposal procedures and the impacts on the surrounding human and natural environment. The review focused on available information and estimates provided by BFB.



Resource Efficiency: The maximum electricity consumption will be 900KW from a 2000KVA transformer provided by the local power company – Power Holding Company of Nigeria (PHCN). BFB has three diesel-powered 500KVA generators which will provide backup power for the plant. BFB intends to run the generators on gas in the future, once the gas infrastructure has been developed. The plant is also equipped with two steam boilers powered by dual diesel/gas burners. As part of the efforts to minimize energy consumption, the electricity consumption will be monitored by the use of building management systems and addressable lighting controls. The estimated energy consumption per ton of product is product is 100KW/h.



Potable water use is estimated at 480m3 per day. The water will be abstracted from four boreholes and treated through chlorination, filtration, de-chlorination and reverse osmosis. The estimated wastewater volume is 240m3 per day from cleaning-in-place (CIP), floor and machine cleaning. The wastewater will be treated in a WWTP which consists of a collection tank, an aeration tank, a clarifier, a chlorination tank, a filtration system and a sludge tank. The discharge will be to a river (Ogunpa River) bordering the facility; some treated effluent will also be used for irrigation. No discharge permit is required for the effluent discharge to the river. The effluent discharge will be monitored and the estimated biological oxygen demand (BOD) and chemical oxygen demand (COD) are expected to be 200mg/l and 300mg/l respectively. These parameters do not meet the WBG EHS guidelines – 50 and 250 mg/l respectively. BFB will be required to modify the wastewater treatment processes to meet the WBG requirements; this is included in the ESAP. As part of BFB’s resource efficiency efforts, the steam distribution system is fitted with steam condensate recovery (which is estimated to amount to 250kg of condensate water consumption/per ton of product). The estimated water consumption per ton of product is 5,000 liters.



The main raw materials for production are the product concentrates (tomato, milk and juice) and sugar. These materials will be stored in the materials storage section and the consumption of these materials will be monitored to minimize wastage.



Pollution Prevention: Air emissions are expected from the generators and the burners of the boiler. Effluent from the WWTP is also a potential source of pollution. As defined in the ESAP, a monitoring program for air emissions and wastewater quality will be developed in accordance with the WBG EHS Guidelines. Other potential pollution sources include fugitive air emissions, soil and groundwater pollution due to spills/loss of containment from diesel storag
e tanks (three above ground 10,000 liter tanks). As at the time of the site visit, the diesel tanks are not bunded; bunding for the tanks will be addressed in the ESAP.



Solid Wastes: Solid wastes from the plant include paper, cartons, plastics and other packaging wastes. A solid waste management area has been defined; wastes will be collected and disposed of by a licensed waste management company.



Hazardous Materials/Chemicals: A minimal amount of chemicals will be used on site; mainly cleaning chemicals and water treatment chemicals and these are not considered hazardous. All chemicals will be stored in the storage facilities. Diesel storage is as discussed above; there are no underground chemical storage tanks in the plant.

IFC’s review considered the potential impacts of BFB operations on the residential community within the estate.



Community Health and Safety: The BFB plant is located in a semi-industrial estate and the potential impacts on community safety relate to emergency preparedness and traffic management. With regards to fire safety, BFB has plans in place for a site-wide firefighting system and associated fire safety equipment; installation is expected to be completed in the last phase of the installation of equipment on site. The plant was designed and constructed in line with National Fire Protection Association (NFPA) Standards 1(fire code) & 20 (installation of stationary pumps). Regular inspections and fire drills will be carried out by the Oyo State Fire Brigade and certificates of compliance will be provided to BFB as applicable.



In terms of traffic management within the estate, the access road to the BFB plant is narrow and untarred. The estate landlord is expected to improve access to the site. BFB will be required to develop a traffic management plan to control the movement of its trucks within the estate to minimize any potential impacts on the residential community; and also provide safety training to the drivers.



Security Personnel: Site security will be managed by a private security firm who will provide unarmed security personnel and armed security if requested.

There has been no community engagement as part of this project even though there is a residential community in the estate and a village nearby (two kilometers from project site). BFB will include an external communication and grievance mechanism as part of the ESMS. The mechanism will document BFB’s approach to receiving complaints and managing communications with the public.

This ESRS document and the associated ESAP will be available at Boulos Food and Beverage:

Contact Person: Richard Nader
Address: Anthonio Village,
KM 9 Lagos-Ibadan Expressway
Ibadan
Oyo State
Nigeria

Broad Community Support is not applicable for this project

Task Title/Description	Anticipated Completion Date
1.Environmental & Social Management System: BFB shall design and implement an Integrated Environmental, Occupational Health and Safety, and Social Management System consistent with ISO 14001, OHSAS 18001 and HACCP/ISO 22001, and IFC Performance Standard 1, to be reviewed and approved by IFC. The System shall define roles and responsibilities, and other necessary elements (manual of procedures) to enable all operations to comply with Nigerian laws and regulations, IFC Performance Standards and the applicable WBG EHS Guidelines. The systems shall include emergency preparedness and response plans as well as external communications and grievance mechanism. The system shall also include mechanisms for the EHS representative to report monthly environmental and social monitoring results to senior management. BFB shall provide evidence of complete and effective implementation of the integrated EHS management system and procedures at the plant i.e. final documentation of the ESMS, including policies, plans, manual of procedures and programs such as food security procedures, EHS monitoring and reporting plan, emergency preparedness and response, community grievance policy and mechanism, OHS policies and procedures, plant’s key performance indicators, including liquid effluents, air emissions and solid waste management.	3/31/2014
2.Organizational Capacity BFB shall confirm in writing to IFC, the appointment of qualified individuals to implement the management system.	3/31/2014
3.Food Safety and Hygiene Develop and implement procedures to meet the requirements of Hazard Analysis and Critical Control Points (HACCP) system.	10/31/2014
4.Human Resource Policy Develop and implement a policy on non-discrimination and equal opportunity.	5/1/2014
5.Occupational Health and Safety Develop and implement Occupational Health and Safety (OHS) policies and procedures demonstrating compliance with WBG’s EHS requirements and Performance Standard 2. The policies and procedures should include identification of managers/persons responsible for OHS performance, on-going training, and a mechanism for reviewing deviations from procedures and improving performance both during construction and operational phase. The procedures should also include the management of contractor OHS for future construction projects. BFB shall provide a copy of the OHS policies and procedures to IFC for review and approval.	3/31/2014
6.PS2 Procedures for Third Party Workers Third Party Workers Develop and implement a procedure to ensure contractor’s labor and working conditions comply with Performance Standard 2: Labor and Wording Conditions.	5/1/2014
7.Pollution Prevention - Bunding for diesel tanks Construct a bunding wall for the diesel storage tanks.	3/31/2014
8.Wastewater Treatment Modify the wastewater treatment plant (WWTP) to meet the WBG EHS guidelines for effluent discharge.Modification of WWTP	12/31/2014
9.Emissions Monitoring Develop and implement air emissions, noise and wastewater quality monitoring programs compliant with the WBG General EHS Guidelines. The data from the monitoring program shall be reported on annual basis to IFC in the Annual Monitoring Report.	6/30/2014
10.Resource Efficiency Audit Within two years of operation, conduct a resource efficiency audit to cover energy, water and raw materials.	10/31/2015
11.Traffic Management and Driver Safety Develop and implement a Driver Safety Training Plan and Traffic Management Plan with emphasis on: safety aspects among drivers, improving driver skills, licensing of drivers, and overall truck maintenance; as well as truck movement schedules – loading and unloading schedules.	3/31/2014
12.Fire Safety Once construction and installation is complete, BFB shall provide a certificate of compliance from the local authorities and a formal statement from a qualified fire safety professional confirming that the fire safety aspects of the design of the plant is compliant with the WBG EHS Guidelines.	3/31/2014
13.Regulatory Permits BFB shall confirm that, where required, all regulatory permits and approvals relating to the project and operations including environmental and discharge permits as well as product registration approvals have been obtained. The relevant approvals/permits shall be provided to IFC.	3/31/2014