Environmental and Social Policies. From its onset, aJ TSC has made an explicit commitment towards promoting sustainable development principles within its operations through adoption of Business Principles which commit the Company on respecting human rights, community engagement, freedom from discrimination, freedom from slavery, freedom from child labor, safe occupational health and safety conditions and products, freedom of association and the right to collective bargaining, fair working conditions, precautionary principles, etc. These principles represent the highest level document for aJ TSC. The aJ TSC Business Plan was developed in adherence with these principles, including its translation into a mission statement (“aJ TSC will consistently create sustainable value for all its stakeholders and provide a model of how investment can promote sustainable development in Africa”) and vision (“by 2012, aJ TSC will become the leading producer and supplier of tropical juices from Ethiopia and aims to become the First FairTrade tropical juice producer in sub-Saharan Africa”). The Sustainable Development Strategy (SDS), adopted in June 2010, represent the expression of this strategy for how the high level plans in the Business Plan will be translated into genuine sustainable development. Accountability for implementation of the SDS has been delegated to concerned aJ TSC senior management and organizational structures through definition of EHS policies, annual work plans, including setting goals and targets for environmental, OHS and social performance measurements indicators, implementation mechanisms, management/monitoring system procedures and reporting procedures/systems.
Specifically, aJ TSC has adopted key EHS policies, including Occupational Health and Safety Policy (June 2010) as well as Human Resource Policy (May 2012). However, these policies are not yet fully implemented. Findings from due diligence are the following: i) scope of the aJ TSC policy framework is deficient as there has not yet been an environmental policy adopted to date (ref. this absence explains the existence of several non-compliance findings as described under PS3); (ii) performance based E&S requirements are not referring specifically to the IFC Performance Standards and applicable WBG EHS Guidelines; (iii) implementation effectiveness and performance review of this policy framework has not been audited since 2010, including lack of quantifiable performance targets and indicators to demonstrate continuous improvement; (iv) accountability framework need to be clarified, including clearly identifying in the organigram the assigned E&S team, to mainstream EHS responsibilities into operational managers’ job description, and to ensure communication strategy to all employees, suppliers and partners. As set for in the attached Environmental and Social Action Plan (ESAP), aJ TSC will strengthen its EHS policy framework through development and/or review of its set of EHS polic
ies, and most importantly development of SOPs, definition of accountability framework and commitment to performance based EHS requirements on IFC Performance Standards and applicable WBG EHS Guidelines. As it is understood that the Human Resources Department has scheduled in its FY13/14 work plan to update its policies and procedures, this proposed exercise is timely. Comprehensive communication strategy with aJ TSC employees through awareness-raising during induction session, board posting and town hall meetings with senior management and Board members is required.
Environmental and Social Assessment and Management System. In accordance with Ethiopia’s Proclamation on Environmental Impact Assessment No. 299/2002 and related guidelines, aJ TSC has commissioned the preparation of an Environmental Impact Assessment (EIA) Study for the tropical fruit processing plant. This study was contracted to an external local consultancy firm. The detailed EIA study was finalized in June 2009 and presented to the Oromia Regional Government’ Bureau of Land and Environmental Protection (OLEPB) for review and approval. Such approval was obtained on July 3rd, 2009. Terms and conditions of this approval included the following: (i) proper implementation of the Environmental Management/Monitoring Program during construction and operations phases (main mitigation/monitoring measures recommended during operations were the following: solid and hazardous waste management, provision of safe working conditions to workers, efficient use of underground water, monitoring of liquid effluents through the construction of a waste water treatment (WWT) plant and monitoring of air emissions from boilers and generators, continuous improvement of EHS performance, and establishment of an Environmental and Safety Management Unit); (ii) regularly report to OLEPB on the environmental performance of the project; (iii) notify OLEPB about occurrences of unforeseen events; (iv) joint field monitoring between aJ-TSC and OLEPB; and, (v) undertake environmental audit and report audit results to OLEPB on a bi-annual basis. aJ TSC has not been able to provide to IFC during field appraisal any supporting documentation evidence of on-going progress and/or completion as it related to points (ii), (iii), (iv) and (v).
Also, when aJ TSC took over the management control of the Tibila Farm from the Government of Ethiopia (GoE)’ Upper Awash Agro-Industry Enterprise (UAAIE) in April 2009, aJ TSC undertook an EIA study for the farming operations focusing on the impact of the land use changes, including introduction of passion fruit as a new crop, change from furrow irrigation to drip irrigation, etc.). Main mitigation outlined in the EIA’s Environmental Management Plan (EMP) encompass the definition and implementation of water resource management policy and management program, biodiversity action plan, pesticide management plan, including an Integrated Pest Management (IPM) Plan, nutrient management
plan, preparedness plan and response in case of natural hazards (e.g. flooding), organic/solid waste management plan, and finally on-going monitoring through assigned farm-level EHS officer. aJ TSC has made good progress on some of these measures but has not been able to provide to IFC during the field appraisal any progress status and/or implementation completion of several of these measures (e.g. biodiversity action plan, IPM plan, preparedness response plan for natural events, waste management plan, etc).
Going forward, as set forth in the ESAP, aJ TSC will review and update completion status of its EIA’s EMP for its plantation operations and processing plant and will present to IFC, for review and approval, a consolidated report on all recommended mitigation measures, progress/completion status and action plan with defined timetable for effective implementation, including center of responsibilities.
aJ TSC has received required permits and licenses from the GoE to operate, including its Business License, and its certificate of competence for food manufacturing organization from the Food Medicine and Health Care Administration and Control Authority of Ethiopia. Water right extraction from the Awash Basin Authority has also been obtained in March 2010.
EHS Management Programs. aJ TSC has designed a corporate management system in June 2009 which was specifically outlining the development of a range of policies, standards, procedures and guidelines to support mainstreaming of EHS issues into aJ TSC operations and ensuring continuous EHS improvement. Since then, significant progress has been achieved, especially in 2009 and 2010, including the development and adoption of a Sustainable Development Policy (2010), an Occupational Health, Safety and Environment Policy (2010), and a Human Resources Policy (2012). In addition, aJ TSC has developed numerous other policies (e.g. road transport, drug and alcohol, smoking, malaria), plans (e.g. emergency response, social management, HSE for construction phase of the processing unit and for the operational phase of the plantations), and programs (e.g. training, farm community health and safety improvement plan, etc.). Despite the above, original commitment of aJ TSC in developing set of standards, procedures and guidelines to implement EHS policies is yet to be completed. In addition, based on IFC review, it is challenging to reconcile the alignment, hierarchy, implementation progress and quantifiable performance outcomes of all these additional policies, plans and programs to guide daily activities performance and/or work plan. Manual of Standard Operating Procedures (SOPs) for processing plant exist in the context of the HACCP system certification process but still remain to be developed for the plantations. aJ TSC has indicated during the field appraisal that it intends to complete the EHS procedures for the farming operations by end of 2013.
Going forwards, as set forth in the attached
ESAP, aJ TSC has agreed to develop and implement an Environmental, OHS and Food safety management systems, including policies, plans, manuals and procedures – consistent with ISO 14001, OHSAS 18001 and HACCP/ISO22001 – into an Integrated EHS Management System. Furthermore, this will be in compliance with IFC’s PS1 requirements and applicable WBG General and Sector-specific EHS Guidelines.
Worthwhile to underline that aJ TSC has obtained its HACCP based food safety system certification in September 2011 (valid until September 28, 2014). Scope of this certification encompassed the receipt of fruits, processing, packaging and dispatch of mango puree and passion fruit NFC (not from concentrate). In addition, aJ TSC has obtained certificate of conformity on FairTrade standards which scope include the processing and plantations operations in December 2012 (valid until December 2016). Lastly, aJ TSC has been audited and successfully achieved its registration with the Voluntary Control System (VCS) of SGF as verified quality juice supplier. SGF is a German-based non-profit organization pioneering industrial self-control in the fruit juice industry. The first SGF/IRMA (International Raw Material Assurance) audit took place in March 2012. The scope of the SGF audit included the sampling of ongoing production and from the warehouse (counter samples for production and delivery) for analytical examination, hygiene audit, review of documentation and traceability as well as system rules, review of SGF/Code of Labeling of semi-finished goods and review of SGF/Code of Conduct, including verification of minimum social and ecological standards (ref. working time regulations, payment of adequate wages, prohibition of child and forced labor and ban on discrimination. It also regulates matters, such as occupational safety and the freedom of association). Correction Action Plan was provided to aJ TSC in 2012 which has successfully completed by the time of the 2nd audit in March, 2013. Successful SGF audit result has just been obtained, including confirmation of negative laboratory analytical results for residual pesticides/chemicals. Global Gap certification has been obtained for the production of green beans, but not for the entire fruit and vegetable farming production. aJ TSC should consider adopting such certification for its fruit production operations.
Organizational structure and technical capacity. In the original organizational structure in 2009, and as defined in the EIA’s EMP, general manager, operational managers and supervisors were to be directly involved in the effective management of environmental and social actions, including a training coordinator, a full-time HSE manager, a community liaison and public relations manager, a sustainable development manager and a community development officer. During the last four years of aJ TSC operations, this structure has been significantly rationalized and there is only one HSE officer and a training coord
inator, under the guidance of the Human Resource Manager, whom remain. The HSE officer (now referred to as the Health and Community Services Officer) is the key position responsible for all social and environmental related issues. He is assisted by a team of three nurses who are responsible for the health clinics at the three farm units as well as housing officers responsible for the implementation for the Housing Improvement Program (HIP). Since his recruitment 18 months ago, the HSE officer has been able to achieve significant progress, including the realization of the FairTrade, HACCP and SGF certification for the passion fruit production and juice processing. Worthwhile to underline that an OHS Sub-Committee has also be established at the processing unit, in the context of HACCP requirements. Minutes of a meeting which took place in May 2012 have been shared with IFC during the due diligence. This being said, as mentioned above, significant efforts are still required to be invested in the review and update of the EHS policies, plans and related procedures for aJ TSC operations, especially as it relates to its farming operations, and internal auditing. In order to strengthen the responsiveness of the HSE officer in face of these challenges, aJ TSC will review and update job description of all key operational managers to ensure to mainstream responsibilities in the design of the Integrated EHS management system and to support its effective implementation on an on-going basis. In addition, the EHS team will be clearly identified in the aJ-TSC organigram and will report directly to the Chief Operation Officer (COO) in order to ensure that internal EHS audit’s findings are effectively and timely addressed through work plan and budgetary allocations.
Training. aJ TSC shared with IFC during the due diligence the training plans for aJ TSC for the last two years (July 2011-June 2012 and July 2012-June 2013). Main emphasis of the training curriculum was concentrated toward HACCP based food safety management, ISO 9001 implementation, ISO system audit, OHS training, application of fire extinguishers, first-aid response, transport and logistics procedure and procurement program and Standard Operating Procedures (SOPs). This emphasis is reflective of the genuine efforts committed by aJ TSC to achieve HACCP, FairTrade and SGF certification. In addition, under its OHS policy, a specific generic OHS training has been developed whose objective is that any new employee’s training program be conducted before the employee operates any equipment or machinery or exposed himself/herself to workplace hazards. Examples of training to be conducted include hazard communication program, use of Personal Protective Equipments, first aid/ CPR, blood borne infectious diseases, back safety, fire extinguishers, etc. Unfortunately, supporting evidence of the implementation of this OHS training has not been provided during due diligence. Lastly, supporting evidence of train
ing delivery to plantations staff, such as safe storage, handling and use of pesticides, supervision of spraying, farm safety rules and accident procedures, etc. has not been provided to IFC. Going forwards, as set forth in the ESAP, upon completion of the Integrated EHS Management System’ policies, plans, manuals and procedures, aJ TSC will define a comprehensive and multi-year training plan for its staffs at the processing plant and farming operations, including the out grower scheme, for IFC review and approval, including center of responsibilities for its effective implementation and budgetary allocations.
Monitoring and Reporting. aJ TSC has not yet defined and/or implemented a comprehensive corporate EHS monitoring and reporting system procedure, including a report format. aJ TSC has made such a commitment during IFC due diligence. This being said, through its on-going compliance with Ethiopia’s legal and regulatory requirements and on-going EHS management systems efforts through HACCP, FairTrade and SGF certification/registration process, aJ TSC has adopted a number of internal Key Performance Indicators (KPIs) on occupational health and safety (ref. Loss Time Frequency Injury Rate – LTFIR), water consumption at processing unit and for the plantation under drip irrigation, and energy consumption. Particularly, aJ TSC is monitoring LTFIR as a key indicator of its EHS management system effectiveness at the processing plant. Through its existing and planned EHS systems, internal inspections are performed monthly by the EHS officer and his team while external follow-up audits from HACCP, SGF and FairTrade are taken place annually. Supporting evidence for internal EHS audit and follow-up has not been provided during appraisal. aJ TSC has shared with IFC the FairTrade 2012 audit and associated CAP as well as SGF 2013 audit. In addition, end-customers of aJ TSC (e.g. Dohler) are also undertaken independent audits to assess strict enforcement of client’s technical/food specifications. These audit reports, incorporating corrective action plans, are submitted to relevant senior aJ TSC operation teams for the effective implementation. Ethiopian authorities (ref. Labor and Social Affairs) also undertake annual review of aJ TSC operations, in addition of aJ TSC trimestrial and annual reports on general health of workers and accident records.
Key findings from the due diligence are the following: (i) the scope of the EHS monitoring of aJ TSC is incomplete as several WBG EHS Guidelines requirements (ref. Food and Beverage Processing) are not addressed, e.g. noise, air emissions, and waste water effluents are not monitored; (ii) aside from monitoring water consumption in the farm operations under drip irrigation system, there is no water consumption monitoring for plantations under furrow irrigation. In addition, set of KPIs at the farming operations as defined under WBG EHS Guidelines for plantation crop (ref. Table 1 on water, soil and produce
quality guidelines) does not exist; (iii) central storage and management of monthly and annual EHS indicators as well as EHS reports is urgently needed as access to these has been challenging during the field appraisal. Monitoring reports of other financiers of aJ TSC should also be easily accessible, including implementation progress status of CAP. Based on information provided during appraisal, aJ TSC did not incur over the last four years any material regulatory penalties, fines or sanctions for contraventions or non-compliance with statutory obligations, as well as not reported any fatalities on sites at any of its operations.
h ♪
♪
Going forwards, as set for the in the ESAP, aJ TSC will define a comprehensive set of Key Performance Indicators (KPIs) in order to monitor on a monthly/annual basis the following EHS parameters: a) Safety – Lost Time Incidence Frequency Rate (LTIFR), Accident Free Days; b) Sustainability – Carbon (kg/ton), Water Usage (kiloliters/ton) at processing and farm operations, Energy Usage (kWh/ton), wastewater monitoring effluents, noise, air emissions parameters from boiler/genset, and on-site incinerator at Degaga Farm in line with WBG’s General and Sector specific EHS Guidelines, use of fertilizers and pesticides, quantifiable indicators reflecting the implementation progress of the Housing Improvement Program (HIP) on an on-going basis; c) Staff - Retention and training days. In addition, the EHS officer will define an integrated EHS report format and based on critical EHS key performance indicators (e.g., compliance with Ethiopian legal and regulatory requirements, EHS management system progress report and certification, energy and water consumption and efficiency; air emissions (Nitrous and sulfur oxides (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 and community complaints, supplier performance and community engagement activities. The Company will also report annually to relevant Ethiopian authorities and IFC as part of the Annual Monitoring Report (AMR).
Stakeholder Engagement Plan. Three different groups of stakeholders are identified at aJ TSC, namely (i) the employees (also called “the farm community” as the majority of permanent and/or casual employees live on the farm units); (ii) the out growers; (iii) the external wider community. For the first group, aJ TSC pro-actively undertook a Livelihood Analysis in December 2009 focusing on the 739 households (total population estimated at 2,539 persons) who were located on the three farming units of Tibila Farm. The main objective of this analysis was to assess living conditions of these peoples, most of them being either permanent or casual workers of the formerly government run Upper Awash Agro-Industry Enterprise (UAAIE). Resulting needs
assessment in term of improving living conditions were planned to be integrated into the development of the Social Development Plan, as part of the preparation of the aJ TSC’s Sustainable Development Strategy (2010). Data on health, education, electrical as well as water and sanitation statistics and available infrastructure services were collected and reviewed. In addition, in June 2010, aJ TSC conducted a Social Impact Assessment which main results outlined the potential positive impacts of aJ TSC investment, namely the improvement of water supply and sustainable provision of potable water for the farm community, increased amounts of available jobs which will improve the income of local communities, introduction of modern technologies, e.g. drip irrigation, reducing weather related vulnerabilities and improving food security, opportunities for the local farmer communities to participate into the out grower scheme.
In order to effectively implement these potential benefits, aJ TSC developed in June 2010 a Farm Community Health and Safety Improvement Program (also known under the “Housing Improvement Program” – HIP) to address below living standards of on-site workers. Main objectives of the community development activities was to improve housing conditions, health services, access to potable water and sanitation, upgrade and safety of the electricity supply and improving farm roads and compound fencing. Budgetary allocations were provided in 2010 and 2011 for its implementation. Supporting evidence on progress report of the HIP implementation has not been obtained during IFC due diligence. However, it is understood that there has been significant progress in relation to electricity supply, health clinics and potable water point access. Work plan for the next few years will be devoted to improving specifically the house and sanitation conditions.
In addition, aJ TSC has established a dedicated Out Grower Incubator Project (OIP) team, composed of a manager, supervisors, outreach workers, etc. that is focused on supporting members of the local community to start growing passion fruit as out growers for aJ TSC. The OIP team is the main interface between aJ TSC and its out growers. Progress to date with the OIP has been very limited, reaching farmers on 65ha, including 10ha under drip irrigation. During site visit, additional 45 ha at Degaga Farm with smallholders has been observed and should become operational within the next few months. Tentative target from the 1st phase in 2009 was to incorporate 1,000-2,000 ha of smallholder passion fruit farmers by 2018. In addition to the OIP’s interactions, aJ TSC also communicates directly with the out grower cooperative (only one such cooperative exists for the time being - Kilo Kersa - composed of 55 smallholders while a second one is under organization) and the local woreda (the local administrative structure) on a monthly basis.
Regarding the wider community surrounding the Tibila farm, esti
mated at 15,000 inhabitants (2010), aJ TSC have had limited interface so far and no regular meetings take place. The Human Resource Manager is approached by the local woreda (local administrative entity) whenever an issue arises, and any problems are usually solved in an amicable way. As part of HR’s objective review and update its internal policies and procedures in FY14, aJ TSC is committed to update and finalize a detailed stakeholder engagement plan which will be shared with IFC for review and approval. In addition, aJ TSc recognized that there is no formalized structure to facilitate on-going interaction between its operations and external stakeholder. As such, it is committed to develop and implement an external communication strategy.h ♪