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.

Land for all sites has been acquired through willing buyer-willing seller transactions. All sites are in an area of general commercial development, including stores and other office buildings. Thus, PS 5 on Land Acquisition and Involuntary Resettlement does not apply. Sites are located within heavily modified habitat in developed urban areas, so PS 6 does not apply. There are no Indigenous People as defined for the purposes of PS 7 in the areas around the project sites, so this Standard does not apply either. There are no known items of cultural heritage that would be affected by the proposed project, so PS8 Cultural Heritage does not apply.

Key risks and issues associated with the 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 warehouses; 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 storage, and delivery of products.

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.

Policy



Marina Market developed an environmental and social policy for its facilities in Burkina Faso and Niger. This policy includes provisions related to environmental awareness, resource consumption and efficiency, waste management, support to the local community, and the attributions of an environmental committee. To be in line with requirements of PS1, an environmental and social policy will be drafted for the Ghana facility.



Organizational Capacity and Competency



In Burkina Faso, the Deputy General Manager is Marina Market’s nominated person who is designated to specifically oversee environmental and social management issues.



Emergency Preparedness and Response



The Life and Fire Safety Audit report drafted by Bureau Veritas in February 2013 identified the gaps to efficiently manage emergencies in the Burkina Faso facility (‘’Grand Marché’’). Action items to be undertaken by Marina Market include the following: update of the current evacuation plan, development of procedures in case of emergencies, list of equipment available, location of first aid kits, etc.



Monitoring and Review



The implementation of the environmental and social policy will be supported by an environmental committee that will meet once every three months. The Committee will develop a plan for improving environmental performance, with measurable indicators where possible, and will report to management and relevant stakeholders on its progress annually. In addition, its activity will be publicized both through the internal newsletter, and externally as appropriate, through a variety of media.



External Communications and Grievance Mechanism



As set forth in the ESAP, Marina Market will implement and maintain a procedure for external communications that include methods 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. In case of grievance, Marina Market will facilitate resolution of affected communities’concerns.

Human Resources Policies and Procedures



Marina Market has about 400 employees in Burkina Faso. It developed a human resource manual including policies and procedures. The manual encompasses working conditions such a schedule, salary, overtime, probationary period, leave and holidays, contract termination, health and safety. The procedures include also disciplinary measures, layoff, grievance mechanism, and provisions related to equity, discrimination, harassment, etc. The grievance mechanism is structured in two streams, informal and official and is spelled out in the human resource manual. Freedom of association is in line with the Burkina Faso Labor Code (‘’Code du travail no 28-2008’’) and there are one to two workers representatives per store (4 stores in Ouagadougou). Local unions are not currently represented.



Each employee has a work contract that stipulates wages, overtime and holidays. Marina Market''s HR Manager confirmed that all employees are above 18 years and 10% of employees are women. Women typically don''t apply to positions in warehousing facilities; they mostly work in the supermarket at the cash registry. All salaries are above minimum wages. The Labor department undertakes an annual unscheduled inspection to ensure contracts are valid and that contribution to social security is in order.



The company provides training to its employees on work methodology to improve the way they work/and learn new skills coupled with a test to assess understanding. This is also a mean of obtaining salary increase upon successful completion of the training program. The company sets objectives for staff and rewards performance to motivate staff.



Marina Market created a "mutual fund" for its employees whereby Marina Market injected CFA 10 million (approximately $USD 24,000), and each month employees put in a fee of CFA 500 each ($1.19). This fund is used to provide cash advance with no interest to employees. The company gives 25,000 CFA for death in the family, and 15,000 CFA for any birth.



Occupational Health and Safety



All employees are registered at the Social Security Bureau (‘’Caisse nationale de sécurité sociale’’) and are covered by the state insurance in case of injuries and illnesses. Accidents are reported to the site supervisor. Apparently most accidents are related to either commuting or injuries during butchering. Employees are required to wear Marina Market’s uniform, overall, and butchering gloves (although not chainmail). All accidents have to be reported to Social Security for employee reimbursement. Marina Market does not have a private insurance in place for workers, since an internal poll indicated that Marina Market employees would prefer housing loans to insurance. Annual medical visits are organized for each employee. Lost time incident frequency rates are not monitored. To be in line with requirements of PS2 and IFC/World Bank Group EHS General Guidelines, as set forth in the ESAP, Marina Market will
develop procedures and systems for reporting and recording occupational accidents and diseases, and dangerous occurrences and incidents. The system will also include the development and implementation of preventive measures.

Resource Efficiency



Energy at the stores in Burkina Faso is provided by the national grid. Backup generators are available in each store and at the main office (2 x 100 kVA; 1 x 350 kVA; 1 x 80 kVA; 2 x 40 kVA; 3 x 20kVA). The main warehouse in Burkina Faso is designed without lighting. The roof is made out of translucent panels and natural light shines in without letting in the heat (they don''t operate at night time). The temperature is comfortable and slightly cooler than outdoor temperatures. Stock management is computerized using a software system which stipulates, sales, expiration dates, and stock. Average duration of inventory is about 70 days. In the stores, Marina Market is using LED lights. Water comes from the National Bureau of Water and Sanitation (‘’Office national de l’eau et de l’assainissement – ONEA). Water and energy usages are not monitored. To be in line with requirements of PS3, Marina Market will develop Key Performance Indicators to monitor water and energy consumption and will propose a plan to improve efficiency.



Wastes



In Burkina Faso, wastewater and storm water are evacuated through grease traps and a drainage system into municipal networks. The ONEA is responsible for treatment of waste water. Daily treatment capacity is 5,400 m3 and currently functions at 3500m3. Based on ONEA’s statement, waste water is treated through decantation, filtration, and aeration (biological treatment) – water is then used in agricultural field. Marina Market undertakes some level of recycling activities: in the supermarkets, cardboard is reused as means of packaging groceries for clients in order to minimize the use of plastic bags. The sponsor mentioned that despite their effort, clients keep requesting plastic bags. Plastic, empty bottles are typically sent to third party for recycling.



Pest control is managed by a third party company called Terminator. For treatment of insects, Terminator uses Fipronil which is a class II (moderately hazardous) pesticide according to the World Health Organization (WHO). Class II pesticides will not be accessible to personnel without proper training, equipment, and facilities to handle, store, apply, and dispose of these products properly.

Infrastructure and Equipment Design and Safety



In February 2013, a Life and Fire Safety audit was undertaken by Bureau Veritas at Marina Market’s Grand Marché in downtown Ouagadougou. The audit was conducted against French Life and Fire Safety regulations and led to an audit report and a corrective action plan. As set forth in the ESAP, the client will agree on a timeline to implement the proposed corrective actions.

Marina Market will implement and maintain a procedure for external communications that include methods 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.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. The Company will also be requested to make IFC’s environmental and social review summary (ESRS) and ESAP available for consultation at their office in Ouagadougou.

Marina Market
Avenue du Grand Marché
Ouagadougou, Burkina Faso
Georges Restom (mailto:grestom@marina-market.com)

Broad Community Support is not applicable for this project

Task Title/Description	Anticipated Completion Date
1.Implement and maintain a procedure for external communications	3/1/2014
2.Develop procedures and systems for reporting and recording occupational accidents and diseases, and dangerous occurrences and incidents	3/1/2014
3.Following the Life and Fire Safety Audit held at the Burkina Faso facility in February 2013, agree to a timeline for the implementation of corrective actions	1/1/2014