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 Environmental & Social Review Procedure as adverse environmental and social risks and impacts arising from the project are limited, generally site-specific and could be addressed through the implementation of standard Good International Industry Practice (GIIP). Land for the development of the project has been acquired on a willing-buyer, willing-seller basis from private land owners; there was no involuntary land acquisition, hence Performance Standard (PS) 5 is not considered to be applicable. The project is located in an abandoned sisal plantation (Agave sisalana) that was used for fiber production. The coastal environment in the vicinity is severely degraded through overexploitation of coastal resources, erosion and pollution. Although some sporadic mangroves were located along the shoreline, the biodiversity value is considered low, hence PS 6 is thus not considered to be applicable. Immediately adjacent to the project site are two manufacturing facilities (grain and feed mills) that were established in the 1970s. There are no legally protected areas or internationally recognized areas in the vicinity. There are likewise no Indigenous Peoples in the vicinity of the project, hence PS 7 is not considered to be applicable. Given previous land use (i.e. sisal plantations), it is considered unlikely that the development of the terminal will have impacts on culture heritage, hence PS 8 is not considered applicable. That said, this aspect and others, including the communities’ use of surrounding natural resources, will be investigated in more detail in the assessments described below (see PS 1 sub-section on ‘Environmental and Management Assessment’), and a Chance Finds Protocol will be included in the company’s 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 Management System



A framework ESMS and an Occupational Health, Safety, Security and Environment Policy has been developed for Lafito Global and will be applied to the project. The policy emphasizes preventative measures, setting targets, monitoring and documenting performance with respect to EHSS aspects. The policy will be communicated to all employees, contractors and stakeholders. The Group has also developed eight ‘Business Principles’ to govern how companies will operate. Principle 4 involves ‘Health, Safety, Security and Environment’ to reduce impacts; Principle 5 involves ‘Local Communities’ (contribute to the well-being of local communities and to mitigate and manage any potential adverse impacts); Principle 6 involves ‘Communication and Engagement’ with employees, business partners and local communities; and Principle 7 involves ‘Compliance’ with international standards, in addition to Haitian legislation.



The ESMS document provides a corporate-level framework for the management of EHSS and has been designed to be consistent with requirements of ISO 14001 for environmental management, OHSAS 18001 for occupational health and safety in the workplace, the International Labor Organization (ILO)-OSH 2001 Guidelines on Occupational, Safety and Health Management Systems and the International Ship and Port Facility Security (ISPS) Code. As indicated in Action Item Number (#)1 in the ESAP, social aspects will also be integrated in the ESMS that will be applied to the project.



Environmental and Social Assessment



An Environmental Impact Assessment (EIA) was carried out for the terminal by a third party. The document provided a description of the environmental conditions of the area, an assessment of impacts and mitigation measures were prescribed. As described in ESAP Action Item #2, the company will conduct an environmental and social impact analysis (ESIA) to meet the requirements of Performance Standard 1. The ESIA will contain a quantitative baseline for air quality, noise, water and sediments. The document will also contain a social impacts assessment based on a baseline that will be established for the Lafiteau and Simonette villages, which are settlements of several thousand inhabitants located adjacent to the project site. The socio-economic assessment will include a review of natural resource use by communities. As the project site is located in an arid environment, potential cumulative impacts on water will also be projected.



Related to the ESIA are the ‘Guidelines for Risk Assessment and Control’ as presented in the ESMS. This risk assessment for the terminal will be conducted in tandem with the revised ESIA. The results of the risk assessment will help determine the EHSS management response.





Management Program



Mitigation measures have been identified as part of the initial EIA and will be further developed as part of the ESIA. An overarching framework for the content
of the management plans has been developed for Lafito Global (entitled the Health, Safety, Security and Environmental Plan). As indicated in ESAP Action Item #3, the construction and dredging contractor (REPSA) is in the process of developing an Environmental, Health & Safety Plan (EHS) Construction Management Plan and an EHS Dredge Management Plan that will contain site-specific occupational health and safety as well as environmental aspects, most notably waste management. REPSA is a company that is owned by the Group, which will facilitate contractor management in terms of implementation of EHSS commitments. The company will review and approve both plans. For the operations phase, the company will develop an Environmental Management Plan and an Occupational Health and Safety (OHS) Management Plan as indicated in ESAP Action Item #4.



As indicated in ESAP Action Item #5, the company will develop an overarching EHS training program for all employees and contractors during operations (on topics such as the EHS policy, emergency response plan, waste management, etc.). As part of ESAP Action Item #3 the company will also ensure that during construction, the contractor is providing adequate EHS training to ensure that workers have the skills to perform their activities. The contractor has also developed a mentoring program, which includes training on topics such as concrete forming and placement, welding techniques, hydraulic dredge operation, crane rigging and pipe installation.





Organization



The company is in the process of leveraging internal Group EHSS resources to identify the project-specific team. For construction, the contractor has in place an EHS Manager and an advisor. For the operations phase of the terminal, a dedicated Port Lafito EHSS Manager will be identified with experience in the application of international standards to support terminal construction and operational activities, as indicated in ESAP Action Item #6. The company will also procure EHS support staff to ensure that the Environment and OHS Management Plans are implemented accordingly.



Monitoring and reporting



According to the overarching Health, Safety, Security and Environmental Plan, the company is expected to report on key performance indicators – KPIs. Some of the KPIs are pre-defined and are included in the sub-sections below on ‘occupational health & safety’ (within PS 2) and in PS 3. Other KPIs for the project will be identified as part of the ESIA and will be incorporated into the operations phase Management Plans as indicated in ESAP Action Item #4.



Port Lafito’s EHSS Manager will define an annual performance reporting and assurance program (and corrective action measures) based on the results of the assurance process - a self-appraisal based on the implementation of the Lafito Global ESMS and the Occupational Health, Safety, Security and Environment Policy As part of this process, non-conformances are identified.



An ext
ernal audit of the company’s EHSS performance will be conducted at least once every five years.



Emergency Preparedness and Response



The contractor will include project-specific emergency preparedness and response measures as part the construction Management Plans.



For operations, the company will develop a site specific Emergency Preparedness and Response Procedures as part of the operations management plans, as indicated in ESAP Action Item #7. The procedures will include an overview of risks and emergency scenarios, emergency preparedness and response procedures, spill prevention and control measures, roles and responsibilities, notifications and communications (including alarms, warning systems and back-up systems), equipment and resources. The procedures will also include a specific training program for employees and contractors and will be developed in coordination with local authorities and awareness / notification to the community, as appropriate.

Human Resource Policy and Management



The project is projected to create 25 direct jobs and 50 indirect jobs during construction and 160 direct jobs and 61 indirect jobs during operations. The project will give priority to hiring in local communities, based on a Local Hiring Plan. All recruitment for the project will take place through the Group’s centralized services group in Haiti, which includes, in addition to human resources, legal, insurance and communications among other services. Regarding business integrity, the Code of Ethics of the Group’s centralized services group in is under preparation.



The company recognizes five areas of responsibility to: (i) shareholders; (ii) clients or customers; (iii) employees; (iv) business partners; and, (v) society at large. Regarding employees, Port Lafito is committed to “respect the human rights of our employees and to provide them with good and safe working conditions, and competitive terms and conditions of employment…. to promote the development and best use of the talents of our employees… to create an inclusive work environment where every employee has an equal opportunity to develop his or her skills and talents… to encourage the involvement of employee in the planning and direction of their work… to provide them with channels to report concerns….” As indicated in ESAP Action Item #8, a high-level Human Resources (HR) Policy will be developed that is in line with IFC’s Performance Standard 2 and with Haitian labor laws, and that will apply to the project, and all contractors as part of contractual obligations. The HR policy will be supported by a series of procedures, some of which have already been developed (recruitment procedures, termination procedures, and disciplinary procedures).



Together, the HR Policy and Procedures will stipulate that the terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation and holiday, are established by national labor regulations; both the policy and the procedures will be provided to the employee as part of the Employee Handbook. Working conditions (including health, safety and security), employee termination, prohibition to employ minors, disciplinary actions, workers’ rights and obligations, employer’s rights and obligations and additional workers’ benefits (such as health insurance and medical assistance) will also be included in related procedures and included in the Employee Handbook.



Regarding the determination of fair wages, the Group’s centralized services group in Haiti is conducting a benchmarking exercise with other sectors in Haiti to determine remuneration guidelines for direct employees and for those hired by other companies belonging to the Group based on market references for different job categories and years of experience. With respect to non-discrimination and equal opportunity, the company is committe
d to avoid all forms of discrimination against its employees, based on the age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs of its counterparties. The requirements of non-discrimination and equal opportunities will be included in the overarching human resources policy.



In line with Performance Standard 2, the Human Resources Policy and Procedures will not impede workers from freedom of association and collective bargaining. There are two labor unions associated with the national port authority (Autorite Portuaire Nationale - APN) in Haiti, the stevedores union and the employees union.



The Human Resources Policy and Procedures will explicitly reject the use of any form of forced or compulsory labor, consistent with ILO Convention 29, to which Haiti is a signatory; and, both will respect child rights and reject the use of child labor, no less than the minimum age per ILO Convention 138, to which Haiti is also a signatory.



During operations, induction training will be provided to all newly directly hired workers of the company on the Human Resources Policy. The Human Resources department will verify contracts and work documents of the workers engaged by core contractors and subcontractors to ensure that they comply with the policy. As indicated in ESAP Action Item #9, a grievance mechanism will be developed and the company will inform workers of the grievance mechanism and how to make use of it during the induction training. The grievance mechanism will also be accessible to contractors’ and subcontractors’ workers performing work in core business processes of the project.



Any day laborers, individuals are required to provide a valid national identification card to ensure that they are above the minimum age limit for work in the construction sector. Day laborers are not hired for hazardous work involving specialized occupational health and safety training. Personal protection equipment is provided when working on site, as necessary. As identified in ESAP Action Item #10, the company will develop a procedure to demonstrate that the employment of day laborers is in compliance with Haitian labor laws; the procedure will also include basic occupational health and safety training, such as safe handling for loading/unloading of equipment, awareness of on-site hazards and emergency response procedures.





Occupational Health and Safety



As stated in the framework Health, Safety, Security and Environmental Plan, the company’s occupational health and safety goal is zero lost time incidents based on the principles of reducing risk to levels “as low as reasonably practicable and still stay in the business”.



Overarching occupational health standards are provided in Lafito Global’s existing ESMS. Aspects mentioned include inter alia national statutory requirements; management programs to assess, control and document health risks arising from chemical, physical, biological, er
gonomic and psychological hazards; exposure monitoring and health surveillance programs; health risk assessments; minimum fitness for duty industry standards; health-related policies such as those covering the use of alcohol and drugs, and other substances that may impair performance, among other topics.



As part of the development of the OHS Management Plan for operations, the company will include industry-specific (and site-specific) measures such as the prevention and mitigation of risks associated with operations of mobile machinery and cranes, container handling, loading and unloading operations, heavy load lifting, as well as risks to workers in operating the machinery, particularly those associated with ergonomics, noise and vibration and risks associated with falling objects and falls from height. The contractor is in the process of developing its EHS Construction Management Plan and Dredge Management Plan, which will both include occupational health and safety measures.



The company will assess and track its occupational H&S management performance during both the construction and operation phase. For construction, pre-defined occupational H&S KPIs are specified in the overarching framework Health, Safety, Security and Environment Plan and include lost-time incidents (LTIs), total recordable incidents (TRIs) and Motor Vehicle Crash (MVCs).



For operations, occupational H&S performance evaluations are expected to be carried out for both direct employees and contractors’ employees considering both (i) lagging (or trailing / downstream) indicators, such as, for example, the number of fatalities, number of (non-fatal) lost time occupational injuries, total number of lost workdays due to injuries; and, (ii) leading (or upstream) indicators to be developed by the company, such as, for example, occupational health risk assessments performed, safety review / assessments performed and the number of direct/contractor employees that have undergone job-related health-risk / safety training.



Regarding medical facilities, the company is expected to have access to Lafito Global’s on-site medical clinic, which will be serviced through a third-party service; a nurse (with access to a doctor) will be on site.

The activities conducted at the project will relate to the handling of containerized cargo and loose bulk. The company will not be providing services to ships, such as solid and liquid waste removal, vessel repair and maintenance, vessel fueling, ballast or bilge water treatment, provision of freshwater, etc.



During construction and initial operations, power will be generated through a 1 MW diesel generator located on-site. Other energy alternatives will be further evaluated and considered as other projects develop in Lafito Global. The project currently includes Gottwald mobile cranes that will be equipped with an independent power source (700kW diesel generator) and reach stackers. Maintenance conducted within the terminal will be limited to services provided for cranes, generators and other on-site equipment.



Good International Industry Practices will be followed by the company for dust suppression, noise management, waste management and disposal and will be detailed in the Environmental Management Plan for the operations phase in a manner that complies with the World Bank Group’s EHS General Guidelines and EHS Guidelines for Ports, Harbors, and Terminals. Monthly air and noise monitoring will take place during operations.



Solid and liquid waste streams will be identified as part of the development of the operations phase Environmental Management Plan. Solid waste collection and disposal will be provided through a waste management supplier that is licensed to operate in the Dominican Republic and Haiti. The company will be conducting an audit of the supplier to ensure it meets company policy and procedures. Options for waste minimization re-use and recycling will be explored as part of the development of the management plan. While recycling options are limited in Haiti, there is a market for waste metals. Related KPIs include the sum in weight and/or volume of domestic, hazardous and wastewater generated.



Wastewater at the port will be collected on-site and disposed of through a third party and will comply with national requirements. Stormwater from the maintenance area will be physically treated via an oil water separator. Oily water will be skimmed and treated as liquid hazardous waste.



Water will be provided from a well located on site (~75-meters deep). Water will be piped into retention lagoons on-site and used for wastewater sanitary use (toilets) and fire suppression. The sum of gallons of waters used (and kW of electricity) will be included amongst the KPIs. Bottled water will be provided for drinking.



Containers transporting hazardous materials will be stored in a dedicated area. There will be special procedures in place for managing such containers. Safety Data Sheets (SDS), in appropriate languages will be available for all marketed products and hazardous materials at their respective storage and handling areas during operations. Hazardous wastes generated from port operations are proje
cted to be minimal (largely limited to used oils and solvents, and oily water from workshop areas). Hazardous wastes will be stored on site and disposed of through the licensed waste management supplier which will be periodically audited by the company (as mentioned above). Chain of custody documentation to the final destination will be maintained.



Eight hectares of coastal water have been reclaimed for the project. Dredging will take place to a depth of 12 meters. Capital and maintenance dredging volumes, dredge methods, sediments characterization (for pollution as well) will be included in the Dredge Management Plan. No dredge permit is required by the government of Haiti. Sediment characterization will also take place during maintenance dredging. As wave action is minimal, there are no plans to construct a breakwater.

Potential project-related impacts on the Lafiteau and Simonette villages will be assessed in the revised ESIA, and, if needed, mitigations will be proposed in accordance with IFC’s Performance Standards. A limited amount of fishing occurs in the vicinity of the project area and during IFC’s meeting with community representatives in Lafiteau, Project-related adverse impacts on livelihoods were not cited as an area of concern. This will be reassessed in the ESIA and mitigated if necessary.



With respect to the well site, and as part of the EIA, the company will identify if there are other wells in the vicinity belonging to communities that could potentially be affected by the drawdown from the project’s well site. This will include a review of water needs of the terminal (maximum daily water consumption at the project site, sub-divided by use, versus estimated drawdown at well due to consumption), as indicated in ESAP Action Item #11. On-going monitoring of water use at the well site will also be included as part of EHS monitoring in the Environment Management Plan for the operations phase. If surface water sites are identified for the project’s use in the future, the company will identify any potential users from the surrounding communities of those water sources and the sustainability of extraction in a separate assessment.



The company will maintain control of terminal access, and all contracted truck traffic will be held at a truck staging area and will only gain access after receiving a specific work order and clearance to approach. As indicated in ESAP Action Item #12, for operations, the company will ensure that the selected trucking contractor develops and implements traffic safety procedures with respect to occupational health and safety issues within the project and interactions with communities on public roads (such as speed limits, limitations on waiting times, specific pick-up hours).



Regarding security forces, the company will seek third party certification to the ISPS Code, which is a comprehensive set of measures to enhance the security of ships and port facilities, developed by the International Marine Organization (IMO) in response to the perceived threats to ships and port facilities. The ISPS Code is implemented through chapter XI-2 Special measures to enhance maritime security in the International Convention for the Safety of Life at Sea (SOLAS).



The management of security forces is fully integrated into Lafito Global’s ESMS. The company will use private security forces, approximately 54 individuals in total and approximately 10 individuals will be armed. Security Plan & Procedures are being developed according to IMO/ISPS and will also demonstrate compliance with Performance Standard 4. A security risk assessment is currently underway that considers interactions between security guards and local communities.



Training will be provided to security forces will be designed to comply with Voluntar
y Principles on Security and Human Rights and Performance Standard 4, as indicated in ESAP Action Item #13. Overseas training or training by overseas personnel is also foreseen. All security management programs will be developed in coordination with the APN and with Haiti’s National Police force.

The company is in the process of developing its Stakeholder Engagement Plan (SEP), as indicated in ESAP Action Item #14, as well as the socio-economic baseline that will be included as part of the ESIA.

A stakeholder identification and analysis will be conducted to identify stakeholders that may be affected by the project and the types of engagement needed. As part of the development of the social impacts assessment with the ESIA, the company will undertake a consultation and engagement process to inform the communities of the project. The company will disclose relevant information about the site (design, construction schedule, potential EHS impacts, employment opportunities) and will incorporate feedback into the development the ESIA. This information will also be integral to the development of a local hiring plan. Information will be provided to communities in culturally appropriate manner.

The SEP will outline the engagement process throughout the life of the project, which will include mechanisms to update the community of health and safety issues with respect to the port. The engagement process during operations will include the development of a grievance mechanism in compliance with Performance Standard 1. The company will also be developing a community investment program. The scope and content of which will be based on the stakeholder identification/analysis exercise and community consultation.

For additional information please contact:

Name: Walkiria Caamaño
Title: External Affairs Director
Company: GB Group
Address: Route Nationale #1, Port-au-Prince, Haiti
Tel: +1509 2815 0012
Mail to: mailto:portlafitoinformation@gbgroup.com
Website: gbgroup.com/our-businesses/infrastructure/port-lafito/

Broad Community Support is not applicable for this project

Title	Anticipated Completion Date	Status	Comments	Completion Date
Port Lafito, SA will incorporate social aspects into the existing Environment, Health, Safety and Security Management System.	10/01/2014	Completed	Completed	10/01/2014
Port Lafito, SA will conduct an environmental and social impact analysis (ESIA) to meet the requirements of Performance Standard 1, including the development of quantitative baselines for air quality, noise, water and sediments and a socio-economic baseline.	12/01/2014	Completed	Completed	06/15/2015
Port Lafito, SA will ensure that the construction contractor has adequately developed its environmental, health and safety (EHS) construction phase management plans and that accompanying training is taking place.	05/31/2014	Completed	Completed	09/17/2014
Port Lafito, SA will develop its operation phase EHS management plans.	12/01/2014	Over Due	Under discussion with IFC client
Port Lafito, SA will develop an overarching EHS training to all employees and contractors during operations.	03/01/2015	Over Due	Under discussion with IFC client
Port Lafito, SA will identify an EHSS Manager with experience in the application of international standards to support terminal construction and operational activities and supporting staff.	10/01/2014	Completed	Completed	10/01/2014
Port Lafito, SA will develop detailed, site specific Emergency Preparedness and Response Procedures.	12/01/2014	Over Due	Under discussion with IFC client
Port Lafito, SA will develop a Human Resources Policy in line with IFC’s Performance Standard 2 and with Haitan labor laws and will verify contracts and work documents of the workers engaged by core contractors and subcontractors to ensure that they comply with company policies and procedures.	10/01/2014	Completed	Completed	03/14/2015
Port Lafito, SA will develop a grievance mechanism for workers.	10/01/2014	Completed	Completed	04/15/2015
Port Lafito, SA will develop a procedure on the hiring of day laborers to demonstrate compliance with Haitian labor laws.	10/01/2014	Completed	Completed	03/15/2015
Port Lafito, SA will ensure that the selected trucking contractor develops and implements traffic safety procedures as part of the operations phase.	03/01/2015	Over Due	Under discussion with IFC client
Port Lafito, SA will develop a training module for security staff that aligns with the requirements of Performance Standard 4.	12/01/2014	Completed	Completed	02/23/2015
Port Lafito, SA will develop and implement a Stakeholder Engagement Plan (SEP).	12/01/2014	Completed	Completed	12/01/2014