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 proposed investment is expected to have limited environmental and social impacts which are expected to be site-specific and none is expected to be significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria, as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. This categorization is in accordance with other similar type of projects within the sector. The project is designed to avoid, minimize and manage E&S risks and impacts of the Company’s operations in compliance with applicable IFC’s PSs and IFC/World Bank Group (WBG) General and sector-specific (Dairy Processing and the Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines.

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 for the processing plant was acquired in 2005 from the Diass Rural Community in accordance with Law no 72-02 on Land Administration and there was no conversion of natural/critical habitats. In addition, Kirene is sourcing raw milk from farms where cows and fodder are confined in established pasture/consolidated agricultural areas; there is no presence of Indigenous Peoples or known cultural artifacts in project’s footprint. In the event that issues anticipated by these PSs arise, Kirene will promptly inform IFC. Screening and assessment of these issues against PSs requirements will be done through the proposed E&S management system (ESMS).

Key risks and issues associated with project relate to the Company’s capacity to: i) undertake adequate social and environmental assessment and maintain management measures commensurate with the impacts of the Company’s expansion plan and operation of warehouse and beverage processing plant; ii) ensure that the design and construction of all facilities comply with recognized building codes and life and fire safety standards; iii) maintain fair, safe and healthy working conditions during expansion and operations of facilities for direct employees as well as for contract workers; iv) establish and maintain internationally acceptable food safety standards (e.g. HACCP) in preparation, storage, and delivery of products, including water, juice and milk.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System



Kirene’s facilities (one plant and one warehouse) are located on public land in a rural area. Although Kirene’s activities aim at extracting and selling water resources, no Environmental and Social Impact Assessment (ESIA) has been undertaken under the Senegalese Environment Law no 2001-01. The impact of water extraction on groundwater reserves is not well understood.



Kirene is committed to achieve ISO 9001, 14001, and 22000 certification in the next two years. It has already developed a Food Safety Management System and Procedures covering issues like microbiological and physico-chemical controls. Quality control procedures are in place to assess raw milk at the farm where a Kirene Quality Assurance Technician is stationed and at the plant for finished products. No environmental, occupational health and safety and social management system and procedures have yet being developed. Going forward, as set forth in the Environmental and Social Action Plan (ESAP), Kirene will develop and implement an Integrated Environmental, OHS and food safety management system, including policies, plans, manuals and procedures – consistent with ISO 9001, 14001, and HACCP/ISO 22000. Kirene will also seek to be certified under ISO 22000. The system will include the following elements: (i) policy; (ii) identification of risks and impacts; (iii) management programs; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) stakeholder engagement; and (vii) monitoring and review. An ESIA will also be conducted for the expansion of the warehouse (from 2,000 m2 to 6,000 m2) and production lines. Emphasis of the study will be put on the impact of water extraction on groundwater reserves, stakeholder identification and consultations, wastewater treatment, environmental and social management plans for warehouse construction and overall operation of the plant.



Policy



Kirene has adopted a Social and Environmental Responsibility (SER) Charter. It contains provisions related to responsible supply chains, commitment to environment protection, awareness raising of staff about environmental and OHS issues, energy and resources efficiency, waste management, community engagement with regards to environment protection, recruitment, training, OHS and Life & Fire Safety committee, etc. Many issues covered in the SER Charter are yet to be operationalized, especially those related to environmental and OHS procedures, energy and resources efficiency, and waste management. Kirene will review its product labeling in line with the World Health Organization International Code of Marketing on Breast Milk Substitutes in connection with its HACCP/ISO 22000 certification.



Organizational Capacity and Competency



Kirene’s Organizational Chart includes, among others, a Production Manager, a Maintenance Manager, a Quality Manager, and an OHS Manager. To be in line with IFC’s PSs, Kirene will ass
ign an Environment function to the Health and Safety (EHS) Manager position who reports to the Quality, Environment, Health, and Safety Manager (former Quality Controller). The latter will have a direct reporting line with management and new EHS attributions will be added to its job description. The tasks of the EHS Manager will be to implement the overall ESH management system, to develop EHS Action Plans, to ensure training of all workers on EHS issues, to implement procedures for reporting injuries, rules for use of Protective Personnel Equipment (PPE), transport safety practices, waste management, resources monitoring, etc.



Emergency Preparedness and Response



In the absence of a formal Emergency Preparedness and Response Plan, to be in line with requirements of IFC’s PS 1, as outlined in the ESAP, Kirene will prepare an Emergency Preparedness and Response Plan. The plan will include the following elements: procedures for shutting down equipment, production and evacuations procedures, including means of egress and a designated meeting place outside the plant. It will also include specific training and practice (simulations and drills with periodicity), schedules and equipment requirements for employees who are responsible for rescue operations, medical duties, threats and incident responses. As part of the plant’s EHS inspection, fire extinguishers, hydrants and the fire fighting system will be inspected on a regular manner. In coordination with local fire brigades, neighboring farmers and surrounding companies, the assigned Company’s security team will undertake periodic fire drills.



Monitoring and Review



As set forth in the ESAP, Kirene will adopt a structured EHS monitoring and reporting system on environmental, OHS and social impacts of its operations. Monitoring frequencies and methodology will be defined by the above mentioned ESMS and monitoring data will be stored in a centralized database for monthly and annual report production. Kirene will report on Key Performance Indicators (KPIs) in order to monitor the following EHS parameters: a) Safety – Lost Time Injury Frequency Rate (LTIFR), Accident Free Days; b) Resource Efficiency – Carbon (kg/ton), Water Usage (kiloliters/ton), Energy Usage (kWh/ton), wastewater monitoring effluents and air emissions parameters from boiler, generators in line with IFC/WBG General and Sector specific EHS Guidelines; c) Staff - Retention and training days. Other issues to monitor include customers and community complaints, supplier’s performance and community engagement activities. Based on data provided during the appraisal, baseline for Kirene’s KPIs is as follows: LTIFR: 17,326 (per million hours); Water Usage: 1.36 kiloliters/ton (milk, juice, water); Energy: 0.0035 kWh/ton (milk, juice, water). On a quarterly basis, Kirene is required to send results of bottled water laboratory testing to the Ministry of Health. Analyzed parameters (pH, nitrate, sulfate, E. Coli, Streptococcus, sulfite-
reducing anaerobes) are within the World Health Organization Guidelines value for drinking water. In case of any accidents or work related illnesses, Kirene is also required to notify the Ministry of Labor. The Company will report annually to IFC as part of the Annual Monitoring Report (AMR).





Stakeholder Engagement



In 2001, before the start of Kirene’s operations, meetings with local communities have been held to discuss land occupation and employment opportunities. Kirene has also established a strong relationship with local communities by building boreholes, providing books, health center, etc. Kirene is involved in religious events like those of Touba, Gamou and Popenguine where they market their products. Kirene has also started a program called ‘’Dakar Clean City’’ and has installed garbage cans in the beach areas in collaboration with Orange and the City of Dakar.



External Communications and Grievance Mechanisms



There is no formalized procedure for external communications or to receive and resolve grievances from affected communities. As set forth in the ESAP, Kirene will develop and implement a procedure to (i) receive and register external communications from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) adjust the management program, as appropriate.

Human Resources (HR) Policies and Procedures



Kirene currently has 186 employees (among which 35 women) of which 49 are based in Dakar and the others are at the Diass factory. There is also a pool of 140 daily workers coming from surrounding communities and about 25 are hired daily as cleaning staff and as dockers. All contracted workers are eligible to coverage by the National Bureau of Social Security (‘’Caisse nationale de sécurité sociale’’) and by the Provident Society (‘’Institut de prévoyance maladie). The lowest salary is about 50% above the minimum wage in Senegal. Most workers have open-ended contracts. Two shifts of 8 hours over 5 days are scheduled at the plant.



In line with the Senegalese Labor Law (‘’Code du travail Loi n°97-17 du 1er décembre 1997’’), in 2011, Kirene has adopted Internal Regulations (‘’Règlement intérieur’’) and procedures covering issues like recruitment, work schedule, leave, health and safety, and disciplinary measures. An audit conducted in 2011 by a Senegalese firm (AKM) to improve Kirene’s management and production strategy found that the recruitment process should be reinforced for selecting potential candidates and that the disciplinary measures are not standardized. As set forth in the ESAP to comply with the requirement of IFC’s PS 2, the Sponsor will develop a HR Policy (or supplement its Internal Regulations) that will cover all type of workers, including direct workers and contracted workers. At a minimum, the HR Policy will include the following provisions: working relationship, working conditions, terms of employment, workers’ organizations, non-discrimination and equal opportunity, retrenchment, grievance mechanism, prohibition of child and forced labor in its direct operations, occupational health and safety, workers engaged by third parties, and supply chain. Specific procedures will be developed for the recruitment and disciplinary measures, among others. The HR Policy will be communicated to all new employees during the induction process.



Grievance Mechanism



There is actually no formal grievance mechanism for workers. Workers are represented by 10 delegates who are part of the Senegalese Workers Union (‘’Confédération nationale des travailleurs du Sénégal’’). The delegates meet the HR department and Kirene’s senior management once a month to discuss and solve employees’ grievances. As set forth in the ESAP, Kirene will establish a structured grievance mechanism procedure that will meet IFC’s PS2 requirements. This procedure will include steps to be taken for workers to manifest any concern, engage in a mediation process, contact responsible persons, and provide feedback. Awareness raising on the grievance mechanism procedure will take place during the worker’s induction session. The scope of this grievance mechanism will also apply to contractors.



Occupational Health and Safety



Kirene does not have specific procedures for Occupational Health and Safety (OHS) related to elec
trical equipment, personal protective equipment, safety signage, machine safety, handling of chemicals, fire extinguishers, first aid kits, and noise level. A plant-level EHS Committee is established to undertake task hazard analysis for each activity. The committee is composed of three workers, the plant manager, the medical doctor and the Health and Safety Manager. In 2012, about 60 employees were trained in health and safety issues. There are two full time nurses at the infirmary. A medical doctor comes once a week. As outlined under PS1 above, OHS related matters will be integrated in the Environmental, OHS and food safety management system. As set forth in the ESAP before the start of the warehouse construction, an Environmental, Health, and Safety Management Plan will be developed and implemented. A specific KPI is proposed under PS1 above to continuously monitor OHS performance.



Supply Chain



Juice concentrates for nectar production (orange, apple, pineapple, mango, goyava) comes from Dohler which maintains Fair Trade certification promoting decent working conditions as defined in ILO Conventions and environmental sustainability. Milk is prepared with a mix of powdered and fresh milk. Powdered milk is supplied by Candia who maintains ISO 9000, FSSC 22000, and Ecocert certification. Candia is also member of the Sodiaal Group which promotes environmental sustainability. Kirene is sourcing raw milk from two industrial farms (Fappo and Pastagri Farms) and has developed procedures for controlling product quality from suppliers. It is also planning to set up a comprehensive milk collection scheme to collect good quality raw milk from individual farmers around the city of Thies. According to a Unicef report, in Senegal 15 % of children of 5-14 year old are working for an average of 30 hours a week, mostly in the agriculture sector (including cattle raising). In order to mitigate any incidence of harmful child labor in its supply chain, Kirene will adopt, as set forth in the ESAP, a management procedure for its supply chain, which will include the development and implementation of a Supplier’s Code of Conduct which will be mainstreamed into its contractual agreements with farmers. This Code of Conduct will include provisions against child and forced labor. Application of this code will be monitored on a daily basis by Kirene’s Quality Assurance Technician based at the different collection centers. In the event that milk is sourced from farmers, Kirene will integrate in his EHS system monitoring of individual suppliers to make sure that the code is respected and that awareness of farmers is raised about this issue.

Resource Efficiency



Energy at the plant is provided by the 30 kva national grid and three backup generators (two 850 kva; one 1000 kva). Steam is produced through a 2.5t boiler. There are two fuel tanks for the generator (30,000 L and 5,000 L), and one furnace oil tank for the boiler (15,000 L) with secondary containment. Kirene owns 21 trucks to deliver juice and milk. Annual fuel consumption for the truck fleet equals to 176,785 L. Annual GHG emissions are estimated at around 2,500 tonnes CO2 equivalent. LED lamps and tube lights with protective cover are used in the plant.



Water Supply and Consumption



Water is used for bottled water, juice preparation, cleaning, sanitation, and cooling purposes. Sourcing of raw water comes from 2 boreholes (11m3/hre at 88m depth; 22m3/hre at 123m depth). A reserve of water is stored in an underground tank of 400m3. Annual raw water consumption (in liter) used per product is about 70 million for bottled water, 4 million for juice and 1 million for milk. Kirene will adopt a specific KPI which will monitor its water use efficiency performance on a monthly basis. Currently, the KPI for water usage is not segregated by product. As part of the EHS monitoring and reporting system described above under PS1, expected performance for water usage will be in line with the industry benchmarks for milk (1.0-1.5 L/L) and juice (6.5 m3/ton) (IFC/WBG EHS Guidelines for Dairy Processing, and for Food and Beverage Processing). Disinfection of water used in bottled water and juice is ensured by filtration through millipore membranes and an ozone generator.



Air Emissions



Main source of air emissions are mostly from the furnace oil fired steam boiler and generators that burn diesel to produce electricity, heat and hot water. The boiler and generators undergo quarterly maintenance inspection to optimize efficiency.





Wastes



Wastewater is composed of process water, including dilutions of milk, detergents lubricants, chemicals, boiler blow down and purging, and domestic effluent. Dairy industry wastes are characterized by high biological organic demand (BOD) variable in quantity and composition. Parameters of concern are pH, fats, suspended solids, dissolved solids, BOD and COD. A wastewater treatment plant was constructed on-site in 2005 with a capacity of 45m³/day. It includes a pumping station, an aeration tank, a deaerator, and a clarification tank. Treatment includes screening and grit removal, sedimentation, biological treatment, sludge digestion and disposal. The effluent after treatment is discharged onto land for irrigation. Dried sludge is used as fertilizer. As mentioned above under PS1, a EHS monitoring system will be established to assess compliance of the effluents with WBG EHS Guidelines for Food and Beverage Processing.



Kirene will also develop a waste management plan that will include the following: review of waste sources, pollution prevention opportunities, and necessary treatment, storage
, and disposal infrastructure; characterization of waste by type, quantities, and potential use/disposition establishment of priorities based on a risk analysis that takes into account the potential EHS risks during the waste cycle and the availability of infrastructure to manage the waste in an environmentally sound manner; opportunities for source reduction, as well as reuse and recycling; procedures and operational controls for onsite storage; options / procedures / operational controls for treatment and final disposal.



Hazardous Materials Management



A cleaning in place (CIP) system is used to minimize the use of chemicals and water. Hazardous waste present in all operations is minimal and characterized by used oils and used reagents from the laboratory’s product analysis. To be in line with requirements of the IFC/WBG General EHS Guidelines as set forth in the ESAP, secondary containment will be installed for Hazardous Materials. Material Safety Data Sheets (MSDS) for laboratory reactants and other Hazardous Materials will be visible on products used, including the on-site registry, and stored safely in a separate and locked room.

Community Health and Safety



The processing plant is located in a rural area and next to a secondary road. As such, potential adverse impacts from its operations would be limited to induced increased traffic which should not represent a significant risk for the local population. However distribution centers for Kirene products are located in the city of Dakar where traffic is heavy and risks of accidents high. Transport employees and sub-contractors will be requested to produce a validated driver license. As set forth in the ESAP, the Company will develop and implement a safe driver and transport safety vehicle procedure, including training session for its own and third party haulage contractors.



With regards to food safety of Kirene’s products, microbiological testing is conducted hourly for 0,5 and 1,5 L and every three hours for 5 and 10 L. For other products, each stock is tested according to a specific sampling design. All the samples of raw materials and finished products are referenced and kept in a sample bank for 8 months.



Infrastructure and Equipment Design and Safety



To be in line with requirements of IFC’s PS 4 as set forth in the ESAP, Kirene will obtain certification of structural and fire safety aspects by engineering and fire safety professionals registered with national or international professional organizations to perform such certification and/or local regulatory agencies with oversight on these matters.



Security Personnel



Kirene is outsourcing its security personnel through a security contractor (Siga Vision). Five guards unarmed are found on the premises at any one time. Kirene will make reasonable inquiries to investigate the employment record and other available records, including any criminal record, of individuals or firms and will not employ or use any individuals or companies that have abused or violated human rights in the past. Security personnel should be instructed to exercise restraint and caution, clearly prioritizing prevention of injuries or fatalities and peaceful resolution of disputes. The use of physical force should be reported to and investigated by the client.

In 2001, before the start of Kirene’s operations, meetings with local communities have been held to discuss land occupation and employment opportunities. Kirene has also established a strong relationship with local communities by building boreholes, providing books, health center, etc. Kirene is involved in religious events like those of Touba, Gamou and Popenguine where they market their products. Kirene has also started a program called ‘’Dakar Clean City’’ and has installed garbage cans in the beach areas in collaboration with Orange and the City of Dakar.

The environmental documents will be accessible at:

Société Industrielle Agro-Alimentaire (SIAGRO) Av. Malick Sy Immeuble Sehran 6e étage à cote Colis Postaux

Public Information Center, The World Bank Senegal Country Office, Corniche Ouest X Rue Leon Gontran Damas, Dakar, Senegal

World Bank Group InfoShop at 701 18th Street N.W., Washington D.C, USA.
IFC’s website at http://www.ifc.org.

Broad Community Support is not applicable for this project

Task Title/Description	Anticipated Completion Date
1.Framework of an Environmental, OHS and food safety management system, including policies, plans, manuals and procedures – consistent with ISO 9001, 14001, and HACCP/ISO 22000	6/1/2014
2.Gap analysis for ISO 22000	12/1/2014
3.Certification under ISO 22000	12/31/2015
4.Impact assessment on water reserves	1/31/2014
5.Environmental and Social Management Plan for warehouse construction	6/1/2014
6.Complete ESIA	12/1/2014
7.Assign an environment function to the Health and Safety Manager	6/1/2014
8.Develop an Emergency Preparedness and Response Plan	6/1/2014
9.Develop a monitoring and reporting system	12/1/2014
10.Develop and implement a procedure to receive and register external communications from the public	12/1/2014
11.Develop a Human Resources Policy and associated procedures for operations	12/1/2014
12.Develop a grievance mechanism for workers	12/1/2014
13.Develop and implement a Supplier''''s Code of Conduct which will be mainstreamed into contractual agreements with farmers. This will include provisions against child and forced labor.	12/1/2014
14.Develop a waste management plan	12/1/2014
15. Install secondary containment for all hazardous materials and develop Material Safety Data Sheets for laboratory reactants and other Hazardous Materials.	12/1/2014
16.Develop and implement a safe driver and transport safety vehicle procedure, including training session for its own and third party haulage contractors.	12/1/2014
17.Provide a certification by a qualified professional, acceptable to IFC that structural, and Fire Safety design of the warehouse to be built is fully responsive to the requirements of the IFC/WBG General EHS Guidelines	3/1/2014
18. Conduct an audit of the warehouse as built to obtain certification of structural and fire safety aspects	3/1/2015