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Environmental & Social Review Summary
Project Number
34738
Company Name
COFCO AGRI LIMITED
Date ESRS Disclosed
Jul 30, 2014
Country
World Region
Region
Global
Last Updated Date
Jun 12, 2021
Environmental Category
A - Significant
Status
Completed
Previous Events
Approved : Sep 25, 2014
Signed : Sep 30, 2014
Invested : Oct 7, 2014
Sector
Grains and Beans
Industry
Agribusiness and Forestry
Department
Regional Industry - MAS Asia & Pac
Project Description
The Project involves an IFC equity investment of about US$75 million in an investment holding company (HoldCo.) to be incorporated to house COFCO’s 51% stake in Noble Agri that it has entered into agreement to acquire. IFC would invest alongside COFCO (leading agribusiness group in China), Hopu (a Chinese private equity firm) and other international investor(s) in this leveraged HoldCo. As such, IFC would have an effective estimated 5% indirect shareholding in Noble.
Noble has the following major assets: a soy crushing and biodiesel facility in Argentina; four oil seed (soy and palm oil) crushing facilities and one seed oil refinery in China; four sugar cane crushing and ethanol production facilities and 143,000 ha of sugar cane plantations in Brazil; three grain port facilities in Argentina, Paraguay, and Uruguay and a grain and sugar port facility in Brazil; and grain silos in Argentina (4), Brazil (4), Paraguay (5), Ukraine (3), and China (1). Noble has also recently completed or been constructing: a sunflower seed crushing facility in Ukraine; a soy crushing facility in South Africa; a soy and palm crushing facility in India; and soy and biodiesel plant in Brazil.
Noble’s palm oil plantations and a palm oil crushing facility in Indonesia are not included in the acquisition.
Noble post COFCO acquisition is expected to continue to leverage Noble’s know-how and good management practices for the expansion of grain sourcing, processing and exporting infrastructure in Brazil and Argentina, as well as in relation to all environmental and social aspects of the projects. Therefore, the review of Noble’s E&S performance is relevant, not only as providing insight into the track record of Noble but also because it will continue to build upon Noble’s E&S resources, policies, and procedures.
Noble has the following major assets: a soy crushing and biodiesel facility in Argentina; four oil seed (soy and palm oil) crushing facilities and one seed oil refinery in China; four sugar cane crushing and ethanol production facilities and 143,000 ha of sugar cane plantations in Brazil; three grain port facilities in Argentina, Paraguay, and Uruguay and a grain and sugar port facility in Brazil; and grain silos in Argentina (4), Brazil (4), Paraguay (5), Ukraine (3), and China (1). Noble has also recently completed or been constructing: a sunflower seed crushing facility in Ukraine; a soy crushing facility in South Africa; a soy and palm crushing facility in India; and soy and biodiesel plant in Brazil.
Noble’s palm oil plantations and a palm oil crushing facility in Indonesia are not included in the acquisition.
Noble post COFCO acquisition is expected to continue to leverage Noble’s know-how and good management practices for the expansion of grain sourcing, processing and exporting infrastructure in Brazil and Argentina, as well as in relation to all environmental and social aspects of the projects. Therefore, the review of Noble’s E&S performance is relevant, not only as providing insight into the track record of Noble but also because it will continue to build upon Noble’s E&S resources, policies, and procedures.
Overview of IFC's Scope of Review
The scope of the IFC’s environmental and social (E&S) review for this corporate investment included visits to Noble Agri’s (“Noble”) – a wholly owned subsidiary of Noble Group – offices in Hong Kong, China, as well as its operations in Brazil and Argentina, where meetings and interviews with key staff (i.e. management and human resources) were conducted, and relevant internal documents and records surrounding the Sponsor’s environmental and social (E&S) performance were analyzed. Among others, the E&S review of this project consisted of appraising the environmental, occupational health and safety (OHS), human resources, land acquisition, community engagement and social communication information provided by Noble and its South American subsidiary Noble Bioenergia and through first-hand observation and data collection during site visits to Noble sugar mills located in Potirendaba, Votuporanga, Meridiano and Catanduva (Sao Paulo State), including the Company’s farms and its suppliers. Soy logistics and processing facilities in Santos port and Votuporanga (São Paulo State), Rondonópolis (Mato Grosso State) and Rosario/ Timbúes port (Argentina) were also visited. IFC’s review included an evaluation of environmental and OHS aspects; OHS and labor conditions, terms of employment; labor practices at its own operations and in its supply chain; quality and sustainability of water supply; management of air emissions from all sources, including any bagasse-fired steam and co-generation activities; pest management in agriculture and raw material/product storage activities; management of solid, liquid and hazardous wastes from agriculture and processing activities; energy consumption and energy efficiency, including greenhouse gas emissions and carbon finance opportunities; community engagement; land acquisition process for sugarcane plantation development, facilities expansion and, land use permitting; and biodiversity related issues for its direct operations and its supply chain.
E & S Project Categorization and Applicable Standard
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
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s 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
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
IFC has categorized this equity investment as a Category A project, according to its Policy on Social and Environmental Sustainability (January 1st, 2012). The rational underlying this categorization is based on the well documented significant adverse biodiversity risks associated with soybean sourcing in the ecologically sensitive Humid Chaco in Argentina and Paraguay, and in the Amazon and Cerrado biomes in Brazil.
Issues related to PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected with this investment for the following reasons: there is no presence of Indigenous Peoples or known cultural artifacts within the company’s operational footprint. In the event that issues anticipated by these PSs arise, Noble Agri will promptly inform IFC. Screening and assessment of these issues against PSs requirements will be done through the Company’s E&S management system (ESMS).
Issues related to PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected with this investment for the following reasons: there is no presence of Indigenous Peoples or known cultural artifacts within the company’s operational footprint. In the event that issues anticipated by these PSs arise, Noble Agri will promptly inform IFC. Screening and assessment of these issues against PSs requirements will be done through the Company’s E&S management system (ESMS).
Environmental and Social Mitigation Measures
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: Noble has developed, at corporate-level, a Corporate Responsibility Policy which has been adopted by the Board of Directors. Through this policy, Noble publicly expresses its commitment to global initiatives relating to climate change, rural development, developing sustainable supply chains and helping communities in which Noble operates. The policy is implemented under the advice and guidance of the CSR Advisory Group, which monitors ways in which the Group proactively addresses CSR issues. Noble’s corporate sustainability programme is driven by a sound strategy and management approach. There are five relevant areas which Noble prioritizes, and which form the principle focus of Noble’s sustainability strategy: occupational health & safety; governance & risk; sourcing with integrity; environmental stewardship; and livelihoods of local communities.
Noble’s parent company, the Noble Group, is a signatory to the United Nations Global Compact. Since 2010, the Group has been committed to work towards the Compact’s 10 universal principles on human rights, labor practices, environmental protection and anti-corruption.
Going forward, and as set forth in the Environmental and Social Action Plan (ESAP), Noble will develop and publish its own Environmental and Social Policy to be adopted by the new Board of Directors of the Company.
Environmental and Social Assessment: Noble’s process for the identification of environmental and social risks and impacts is defined by locally applicable licensing requirements. For example, in Brazil, Noble identifies most relevant impacts and risks from its operations that includes air emissions, effluents, solids waste and all OHS risks under Risk Prevention Plan (Plano de Prevenção de Riscos Ambientais – PPRA). While greenfield developments are typically required to complete a full environmental and social impact assessment (ESIA) process according to Brazilian environmental licensing requirements, the extent of assessment requirements applicable to the expansion of existing plants can range from a full ESIA to a more simplified Rapid Environmental Assessment, depending on the nature of the expansion, its potential E&S impacts, and the judgment of the local environmental authority. Noble has completed a full ESIA for its Sugar Mill in Meridiano as well as for its soy crushing and combined Biodiesel facilities in Rondonópolis (Brazil) and Timbues (Argentina). Rapid Impact Assessments were also completed for Votuporanga and Catanduva Mills expansions (Brazil). Also in Brazil, the suitability of land for the production of various crops, and specifically for sugarcane production, is assessed following Brazil’s CTC (Centro de Tecnologia Cana) framework, which includes soil type and fertility, erosion risk, topography, rain fall, sun light, temperature, and other factors which determine sugarcane productivity.
Going forward, and as set forth in the ESAP, Noble will develop and implement a corporate leve
l procedure for the assessment of environmental and social impacts, applicable to any future expansion of commodity sourcing, own plantations, processing facilities, and logistics activities, making reference to applicable country-level legal and regulatory requirements and the IFC Performance Standards. For existing assets or those to be acquired over time, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and Safety Guidelines.
Management Programs: Noble’s management programs are defined at the regional or local level depending on a number of factors which include size and structure and type of operating activity of the respective business lines. Regional management programs for environmental, health, and safety (EHS) are complemented by locally defined or plant level requirements. For example, the sugar cane mills in Brazil have detailed, plant-specific, EHS plans and procedures whose scope is defined in the ESIAs during the environmental licensing phase and which consists of environmental and social (E&S) management programs spelling out prevention, control, mitigation, and monitoring requirements for each of the identified impacts (this E&S management program is referred to as PBA, or Plano Básico de Ação in Portuguese). These plans most often cover specific aspects of the construction and operational phases separately, such as waste management, environmental noise and air quality, surface water quality, vinasse application program (in case of sugar mills), and traffic safety and control, among others. The agriculture division from sugarcane mills also has an annual sugarcane plantation and harvesting management program that includes specific procedures for soil conservation, use of fertilizers and integrated pest management program. In Brazil and Argentina, similar programs have been developed to cover occupational health and safety (OHS) aspects, as further described in the respective section below under PS2, Labor and Working Conditions.
As a matter of corporate policy commitment, Noble attempts to pursue applicable industry certifications of owned assets including in many cases specific environmental, health, safety and social (EHSS) management plans and procedures. Below is a list of EHSS certifications currently held by Noble’s assets and subsidiaries:
Going forward, and as set forth in the ESAP, Noble will develop and implement a corporate Environmental, Health and Safety, and Social (EHSS) Management System in accordance with IFC PS1, applicable to development, construction and operational phases of business activities globally. The EHSS Management System shall include plans and procedures applicable to the Company’s business activities in order to comply with applicable national laws and regulations, IFC’s Performance Standards requirements and applicable WBG’s Environmental, Health and Safety Guidelines. The new global EHSS plans and procedures shall be communicated to all Company operations, including employees and contractors. Copies of the EHSS policies will be shared with every new employee at the time of hiring and induction training. Noble shall make available evidence of complete and effective implementation of the EHSS Management System (MS) at the regional, country, and local operational level (e.g. final documentation of the EHSS MS, including policies, plans, manual procedures and programs, e.g. training logs, monitoring records, minutes of progress reviews).
Management Capacity: Accountability of E&S matters in Noble is decentralized along regions and business units. For example, ultimate accountability for E&S matters in the Division of Grains and Oils is part of the scope of the G&O held by the Division’s Global Technical Director who further delegates t
hese responsibilities at the sub-divisional or local level typically in the form of the local plant managers (i.e. China, Argentina/ Southern Cone, Ukraine, and South Africa) or the regional technical operations manager (occasionally with arrangements for cross-division support). At the local level, regional or plant managers are further supported by the E&S management structure. For example, the Noble Bioenergy division in Brazil has an EHS manager that is also supporting soy operations in Latin America and who is further supported by the following typical arrangement: Environmental Monitoring is under the responsibility of quality assurance (QA); OHS management is part of the Human Resources (HR) department; and the management of environmental control equipment/ facilities is under the responsibility of plant or site operations. The sugar mills operations in Brazil have a dedicated environmental analyst and a team of OHS professionals (OHS engineers, OHS technicians, doctors and nurses) reporting to the Environmental and OHS Coordinators respectively. Going forward, and as set forth in the ESAP, Noble will hire an experienced and qualified Global Corporate EHSS Director as well as ensure that the Company has adequate regional management to oversee EHSS compliance matters globally. This includes the hiring of a Social Sustainability Manager for Latin America.
Training: The definition of training requirements takes place at the regional and local level and depends on the structure and nature of the operations as well as to local regulatory requirements. For example, Noble’s operations in Brazil have structured training programs that include an EHS induction for new employee’s (and contractors), as well as specific trainings, as needed for the job in industrial or field operations, such as working in heights, working in confined spaces, machine operators, boiler operators, pesticides use and handling, vinasse irrigation, and general environmental best practices, among others. Going forward, and as set forth in the ESAP, Noble will develop and implement a management system procedure and evidence of the implementation of the staff training, at corporate and country level, including mainstreaming into corporate/country-level training manual, addressing the Company’s EHSS and Sustainability Sourcing policies, IFC’s PS requirements (direct operations and supply chain) and WBG’s EHS Guidelines (for direct operations).
Monitoring and Reporting: Monitoring, internal, and external reporting practices at Noble are defined by the respective business units at the global, regional, and local levels and depend on the respective business unit practice defined by experience and local regulatory requirements. For example, within the operations of Grains and Oils Division, Noble monitors key performance indicators (KPIs) pertaining to OHS matters of its employees and contractors, such as Medical Aid Frequency Rate, Lost-Time Frequency Rates, Accident Sever
ity Rate, Decreasing Failure Rate, Safety Index, and Fatalities. The G&O Division also monitors training hours and overall safety performance of each site which are recorded in a monthly operational safety report compiled for the whole G&O Division.
Brazilian operations are further monitored to comply with local regulatory requirements such as work related injuries, air emissions, watershed quality, field application of vinasse wastewater, pesticides consumption, water consumption and solid wastes generation and disposal. In the State of Sao Paulo, Brazil, the sugar mills report indicators defined by state environmental regulator CETESB (Companhia de Tecnologia de Saneamento Ambiental) and federal environmental regulator IBAMA (Instituto Brasileiro de Meio Ambiente), on an annual basis. Brazilian soy crushing facilities and combined biodiesel plants also have their own EHS monitoring plans, which include air emissions and wastewater monitoring, OHS accident and severity rates, waste production and disposal, and environmental noise monitoring. OHS exposure to hazardous agents such as noise, dust and heat is also monitored at all sites. Noble also has an OHS health monitoring program (PCMSO – Plano Medico de Controle da Saúde Ocupacional) that includes periodic clinical assessment as well as specific tests and exams such as audiometry, eye testing, blood pressure, diabetes, urine and blood testing for specific chemical contamination indicators.
Noble’s facilities globally who are the subject of various third party certifications (previously summarized in this report) are further audited as part of the certification renewal process. Going forward, and as set forth in the ESAP, the Company will, for its direct operations (e.g. plantations and processing facilities), review and expand its existing Key Performance Indicators (KPIs) to mainstream EHSS parameters, including a) Safety – Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (kiloliters/ton) and Efficiency - Consumed versus tons produced; Energy Usage (kWh/ton) - Energy consumed/tons produced; Wastewater monitoring effluents and air emissions parameters (including VOC); c) Staff - Retention - Number of full time equivalents leaving in the period /Avg. full time equivalents - and Training days - Number of training days provided to new and existing employees.
Noble will further prepare an integrated annual EHSS report format based on critical EHSS key performance indicators (e.g. compliance with legal and regulatory requirements, EHSS management system progress report covering aspects such as facility and commodity certification initiatives; energy and water consumption and efficiency; air emissions (NOx, SOx, particulates), including GHG emissions; noise levels and management, solid and ha
zardous waste management and disposal, effluent discharges from WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers complaints, supplier performance and community engagement activities). A summary of the EHSS report shall be publicly disclosed annually following a format equivalent to the Global Reporting Initiative (GRI).
Noble’s parent company, the Noble Group, is a signatory to the United Nations Global Compact. Since 2010, the Group has been committed to work towards the Compact’s 10 universal principles on human rights, labor practices, environmental protection and anti-corruption.
Going forward, and as set forth in the Environmental and Social Action Plan (ESAP), Noble will develop and publish its own Environmental and Social Policy to be adopted by the new Board of Directors of the Company.
Environmental and Social Assessment: Noble’s process for the identification of environmental and social risks and impacts is defined by locally applicable licensing requirements. For example, in Brazil, Noble identifies most relevant impacts and risks from its operations that includes air emissions, effluents, solids waste and all OHS risks under Risk Prevention Plan (Plano de Prevenção de Riscos Ambientais – PPRA). While greenfield developments are typically required to complete a full environmental and social impact assessment (ESIA) process according to Brazilian environmental licensing requirements, the extent of assessment requirements applicable to the expansion of existing plants can range from a full ESIA to a more simplified Rapid Environmental Assessment, depending on the nature of the expansion, its potential E&S impacts, and the judgment of the local environmental authority. Noble has completed a full ESIA for its Sugar Mill in Meridiano as well as for its soy crushing and combined Biodiesel facilities in Rondonópolis (Brazil) and Timbues (Argentina). Rapid Impact Assessments were also completed for Votuporanga and Catanduva Mills expansions (Brazil). Also in Brazil, the suitability of land for the production of various crops, and specifically for sugarcane production, is assessed following Brazil’s CTC (Centro de Tecnologia Cana) framework, which includes soil type and fertility, erosion risk, topography, rain fall, sun light, temperature, and other factors which determine sugarcane productivity.
Going forward, and as set forth in the ESAP, Noble will develop and implement a corporate leve
l procedure for the assessment of environmental and social impacts, applicable to any future expansion of commodity sourcing, own plantations, processing facilities, and logistics activities, making reference to applicable country-level legal and regulatory requirements and the IFC Performance Standards. For existing assets or those to be acquired over time, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and Safety Guidelines.
Management Programs: Noble’s management programs are defined at the regional or local level depending on a number of factors which include size and structure and type of operating activity of the respective business lines. Regional management programs for environmental, health, and safety (EHS) are complemented by locally defined or plant level requirements. For example, the sugar cane mills in Brazil have detailed, plant-specific, EHS plans and procedures whose scope is defined in the ESIAs during the environmental licensing phase and which consists of environmental and social (E&S) management programs spelling out prevention, control, mitigation, and monitoring requirements for each of the identified impacts (this E&S management program is referred to as PBA, or Plano Básico de Ação in Portuguese). These plans most often cover specific aspects of the construction and operational phases separately, such as waste management, environmental noise and air quality, surface water quality, vinasse application program (in case of sugar mills), and traffic safety and control, among others. The agriculture division from sugarcane mills also has an annual sugarcane plantation and harvesting management program that includes specific procedures for soil conservation, use of fertilizers and integrated pest management program. In Brazil and Argentina, similar programs have been developed to cover occupational health and safety (OHS) aspects, as further described in the respective section below under PS2, Labor and Working Conditions.
As a matter of corporate policy commitment, Noble attempts to pursue applicable industry certifications of owned assets including in many cases specific environmental, health, safety and social (EHSS) management plans and procedures. Below is a list of EHSS certifications currently held by Noble’s assets and subsidiaries:
| Commodity | Asset | Country | Asset Type | Current Certification |
|---|---|---|---|---|
| Coffee | Casa Nobre Coffee Processing and Storage Facility, Alfenas, Minas Gerais | Brazil | Processing Facility, Storage Facility | TN-CC 020, ISO 14064 |
| Sugar & Ethanol | Catanduva Sugar Mill and Ethanol Production Facility | Brazil | Processing Facility | Ethanol Verde, Labour Cert., ISO 14064 |
| Sugar & Ethanol | Meridiano Sugar Mill and Ethanol Production Facility | Brazil | Processing Facility | Ethanol Verde, Labour Cert., ISO 14064 |
| Sugar & Ethanol | Potirendaba Sugar Mill and Ethanol Production Facility | Brazil | Processing Facility | Ethanol Verde, Labour Cert., ISO 14064 |
| Sugar & Ethanol | Votuporanga Sugar Mill and Ethanol Production Facility | Brazil | Processing Facility | Ethanol Verde, Labour Cert., ISO 14064 |
| Sugar | Santos, Dry Bulk Export Terminal | Brazil | Port | ISO 14001, ISO 9001, OHSAS 18001, OCP 0044, Vessels Oil Spill Emergency Plan, ISO 14064, US FDA |
| Grains & Oilseeds | Jordan Grain Handling Co. (JOGCO), Amman | Jordan | Storage Facility | GIPSA, GAFTA, ISO 14064 |
| Grains & Oilseeds | Fuling Oilseed Processing Complex | China | Processing Facility | HACCP, ISO 9001, ISO 14001, ISO 14064 |
| Grains & Oilseeds | Timbúes Oilseed processing facility,River Port Grain Terminal & Biodiesel Production Plant | Argentina | Harbor Terminal & Processing Facility | GMP+ B2 (includes guidelines HACCP+ISO 9001), ISO 14001, OSHAS 18001, 2BSvs, RFS2 individual scheme (EPA), ISO 14064, US FDA, KOSHER. |
| Grains & Oilseeds | Longkou Shandong Oilseed Processing Complex | China | Processing Facility | HACCP, ISO 14064 |
| Grains & Oilseeds | Mingfa Taixing | China | Processing Facility | HACCP, ISO 14064 |
| Grains & Oilseeds | Qinzhou Oilseed Processing Complex | China | Processing Facility | HACCP, ISO 14064 |
| Grains & Oilseeds | Nantong Oilseed Processing Complex | China | Processing Facility | HACCP, ISO 9001, ISO1 7025, ISO 14064 |
| Grains & Oilseeds | Terminal Graneleras Uruguayas (TGU) | Uruguay | Port | ISO 9001, ISO 14064 |
| Animal Feedstuffs | Noble Resources South Africa (Pty) Ltd | South Africa | Business Entity | AFMA, ISO 14064 |
Going forward, and as set forth in the ESAP, Noble will develop and implement a corporate Environmental, Health and Safety, and Social (EHSS) Management System in accordance with IFC PS1, applicable to development, construction and operational phases of business activities globally. The EHSS Management System shall include plans and procedures applicable to the Company’s business activities in order to comply with applicable national laws and regulations, IFC’s Performance Standards requirements and applicable WBG’s Environmental, Health and Safety Guidelines. The new global EHSS plans and procedures shall be communicated to all Company operations, including employees and contractors. Copies of the EHSS policies will be shared with every new employee at the time of hiring and induction training. Noble shall make available evidence of complete and effective implementation of the EHSS Management System (MS) at the regional, country, and local operational level (e.g. final documentation of the EHSS MS, including policies, plans, manual procedures and programs, e.g. training logs, monitoring records, minutes of progress reviews).
Management Capacity: Accountability of E&S matters in Noble is decentralized along regions and business units. For example, ultimate accountability for E&S matters in the Division of Grains and Oils is part of the scope of the G&O held by the Division’s Global Technical Director who further delegates t
hese responsibilities at the sub-divisional or local level typically in the form of the local plant managers (i.e. China, Argentina/ Southern Cone, Ukraine, and South Africa) or the regional technical operations manager (occasionally with arrangements for cross-division support). At the local level, regional or plant managers are further supported by the E&S management structure. For example, the Noble Bioenergy division in Brazil has an EHS manager that is also supporting soy operations in Latin America and who is further supported by the following typical arrangement: Environmental Monitoring is under the responsibility of quality assurance (QA); OHS management is part of the Human Resources (HR) department; and the management of environmental control equipment/ facilities is under the responsibility of plant or site operations. The sugar mills operations in Brazil have a dedicated environmental analyst and a team of OHS professionals (OHS engineers, OHS technicians, doctors and nurses) reporting to the Environmental and OHS Coordinators respectively. Going forward, and as set forth in the ESAP, Noble will hire an experienced and qualified Global Corporate EHSS Director as well as ensure that the Company has adequate regional management to oversee EHSS compliance matters globally. This includes the hiring of a Social Sustainability Manager for Latin America.
Training: The definition of training requirements takes place at the regional and local level and depends on the structure and nature of the operations as well as to local regulatory requirements. For example, Noble’s operations in Brazil have structured training programs that include an EHS induction for new employee’s (and contractors), as well as specific trainings, as needed for the job in industrial or field operations, such as working in heights, working in confined spaces, machine operators, boiler operators, pesticides use and handling, vinasse irrigation, and general environmental best practices, among others. Going forward, and as set forth in the ESAP, Noble will develop and implement a management system procedure and evidence of the implementation of the staff training, at corporate and country level, including mainstreaming into corporate/country-level training manual, addressing the Company’s EHSS and Sustainability Sourcing policies, IFC’s PS requirements (direct operations and supply chain) and WBG’s EHS Guidelines (for direct operations).
Monitoring and Reporting: Monitoring, internal, and external reporting practices at Noble are defined by the respective business units at the global, regional, and local levels and depend on the respective business unit practice defined by experience and local regulatory requirements. For example, within the operations of Grains and Oils Division, Noble monitors key performance indicators (KPIs) pertaining to OHS matters of its employees and contractors, such as Medical Aid Frequency Rate, Lost-Time Frequency Rates, Accident Sever
ity Rate, Decreasing Failure Rate, Safety Index, and Fatalities. The G&O Division also monitors training hours and overall safety performance of each site which are recorded in a monthly operational safety report compiled for the whole G&O Division.
Brazilian operations are further monitored to comply with local regulatory requirements such as work related injuries, air emissions, watershed quality, field application of vinasse wastewater, pesticides consumption, water consumption and solid wastes generation and disposal. In the State of Sao Paulo, Brazil, the sugar mills report indicators defined by state environmental regulator CETESB (Companhia de Tecnologia de Saneamento Ambiental) and federal environmental regulator IBAMA (Instituto Brasileiro de Meio Ambiente), on an annual basis. Brazilian soy crushing facilities and combined biodiesel plants also have their own EHS monitoring plans, which include air emissions and wastewater monitoring, OHS accident and severity rates, waste production and disposal, and environmental noise monitoring. OHS exposure to hazardous agents such as noise, dust and heat is also monitored at all sites. Noble also has an OHS health monitoring program (PCMSO – Plano Medico de Controle da Saúde Ocupacional) that includes periodic clinical assessment as well as specific tests and exams such as audiometry, eye testing, blood pressure, diabetes, urine and blood testing for specific chemical contamination indicators.
Noble’s facilities globally who are the subject of various third party certifications (previously summarized in this report) are further audited as part of the certification renewal process. Going forward, and as set forth in the ESAP, the Company will, for its direct operations (e.g. plantations and processing facilities), review and expand its existing Key Performance Indicators (KPIs) to mainstream EHSS parameters, including a) Safety – Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (kiloliters/ton) and Efficiency - Consumed versus tons produced; Energy Usage (kWh/ton) - Energy consumed/tons produced; Wastewater monitoring effluents and air emissions parameters (including VOC); c) Staff - Retention - Number of full time equivalents leaving in the period /Avg. full time equivalents - and Training days - Number of training days provided to new and existing employees.
Noble will further prepare an integrated annual EHSS report format based on critical EHSS key performance indicators (e.g. compliance with legal and regulatory requirements, EHSS management system progress report covering aspects such as facility and commodity certification initiatives; energy and water consumption and efficiency; air emissions (NOx, SOx, particulates), including GHG emissions; noise levels and management, solid and ha
zardous waste management and disposal, effluent discharges from WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers complaints, supplier performance and community engagement activities). A summary of the EHSS report shall be publicly disclosed annually following a format equivalent to the Global Reporting Initiative (GRI).
Human Resource Policy: At the holding corporate level, as mentioned above, Noble is a signatory to the UN Global Compact which includes public commitments to manage its activities in according with the principles of Human Rights, Freedom of Association including workers right to collectively bargaining, and eradication of child and forced labor, etc.
However, implementation of these and other aspects related to Noble’s management of human resource (HR) labor matters is defined by locally applicable requirements. For example, in Brazil Noble has a formal General HR policy with key core objectives and further details according to Brazilian labor regulations. The core objectives include a commitment to promote a fair and safe workplace; to follow the labor laws and best sector practices; to recognize the workers’ rights of freedom of association; to avoid any form of forced and child labor; to stand against sexual or other forms of harassment. The HR Policy further defines terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity, vacation or holiday are established by national labor regulations and applicable sector specific collective bargaining agreements. Although Brazilian workers in general are familiar with the national terms of employment, the Company also informs them during the induction phase about the specific terms of the job position and additional benefits.
In Brazil, Noble has further adopted a range of HR operational procedures to guide the work of the HR department, such as a recruiting and hiring, termination, performance assessment and promotion, payment of wages and salaries and induction.
Going forward, and as set forth in the ESAP, Noble will develop and implement a global corporate human resources policy consistent with IFC Performance Standard 2 with further reference to local labor laws. Noble will review country-level operations Human Resources policies and procedures to ensure consistency with PS2 requirements and national law. The corporate and the local HR policies will make explicit reference to the Company’s commitments to non-discrimination and equal opportunity; minimum work age requirements; workers’ rights to freedom of association; respect for collective agreements, if these are present; maximum working hours; and working conditions and terms of employment. As part of the deployment of the global HR policy, the Company will develop and disseminate a corporate worker grievance policy and procedure applicable to its workers and contractors according to IFC PS2 and ensure implementation at the local level.
Non discrimination and equal opportunity: In addition to the commitment of its current parent company to the UN Global Compact, Noble’s management of non-discrimination matters is defined by locally applicable requirements. For example, as any form of discrimination is considered a crime in Brazil, Noble ha
s set up local procedures to avoid discriminatory practices (including sexual or moral harassment) in hiring and every day operations. Brazilian law also requires companies to investigate any complaints of misconduct and take corrective actions, as appropriate. Medical exams are requested as part of the hiring process and according to the function the worker will perform. In Brazil no HIV or pregnancy testing is performed as part of the hiring process or regular medical screening. Women employees are allowed to work in administrative or operational functions. Noble has also established recruiting and hiring procedures to meet Brazilian requirements and quotas for the hiring of disabled persons.
Retrenchment: Although the prospects for retrenchment in Noble’s current operations are unlikely given the Company’s future expansion plans, going forward, and as set forth in the ESAP, Noble will develop a retrenchment policy and procedure that complies with local requirements and IFC Performance Standards to be applied in the event that the Company’s business plans lead to retrenchment at any of Noble’s current operations.
Protecting the Work force: In addition to the commitment of its current parent company to the UN Global Compact, Noble’s management of non-discrimination matters is defined by locally applicable requirements. For example, in Brazil Noble ensures that no Child Labor or Forced Labor is used at their operations through their hiring and selection procedure. Child labor is illegal in Brazil and there is a task force from Ministry of Labor that inspects and enforces the law. In the recent years, sugar industry has agreed in a progressive approach to eradicate manual harvesting of sugarcane in the State of São Paulo, which significantly reduced the cases of forced labor in the region. Regarding their supply chain in Brazil, Noble is in constant dialogue with suppliers providing technical assistance and monitoring compliance regarding labor (and environmental) issues. A list of identified cases of child/forced labor are publically available at MTE (Ministério Trabalho e Emprego, in Portuguese) website (sistemasiti.mte.gov.br/ and portal.mte.gov.br/trab_escravo/resultados-das-operacoes-de-fiscalizacao-para-erradicacao-do-trabalho-escravo.htm ) and no cases of child/forced labor in sugarcane industry were identified in the region of Noble’s sugar mills.
As set forth in ESAP (Supply Chain Risk Assessment and Management), Noble will periodically check if suppliers are enrolled in the lists for Child/forced labor in Brazil. Going forward, Noble will develop and implement a chain of custody verification system, in accordance with Bonsucro Standards, to verify the existence of child/forced labor across supply chain, and will also periodically check if suppliers are enrolled in the Child/forced labor lists.
In the soy sector in Brazil, child/forced labor is not common owing to the high rate of mechanization of production. However, as
set forth in ESAP, the Company will develop and implement a supply chain verification system to periodically verify if their suppliers are enrolled in one of the child/forced labor lists in Brazil.
However, Noble has a high risk of exposure to harmful child labor in its supply of cocoa in Africa and has been working in this respect through local CSR initiatives aimed at improving the conditions of cocoa producers. This issue will be further address through the implementation of the Supply Chain Risk Assessment and Management described in the ESAP.
Occupational Health and Safety: Noble presently monitors trends in OHS accidents from its global operations. Nonetheless, Noble’s management of OHS matters, including the design and implementation of policies and procedures to prevent accidents, is defined by locally applicable requirements. For example, in Brazil Noble has developed well-structured team managing the OHS hazards and risks consistent with Brazilian labor requirements. Noble has mandatory OHS programs in place, such as risk prevention plans, health monitoring plans, an accident prevention committee, and emergency response plans. In Brazil, Noble has adopted policies and procedures to manage OHS, including, among others, OHS Management Program (Programa de Gestão de Segurança do Trabalho e Saúde-PGSST) that includes preventive/corrective inspections, accidents and incidents analysis, and OHS mandatory programs, such as Risk Prevention Plan (Plano de Prevenção de Riscos Ambientais – PPRA), Health Monitoring Plan (Programa de Controle Médico da Saúde Ocupacional – PCMSO), Hearing Protection Program (Programa de Conservação Auditiva), Respiratory Protection Program (Programa de Proteção Respiratória). Noble also has specific procedures for hazardous works (working at heights, working with heat, working with electrical systems, working in confined spaces, working in explosive atmospheres), which must be followed by the hazardous works permitting procedure.
Consistent with Brazilian requirements, Noble has implemented appropriate collective prevention measures in place and where is necessary they also provide the appropriate Personal Protective Equipment (PPE). Noble has adopted centralized pesticides storage warehouses, where products are mixed with water into trucks that deliver to the product to spraying front. All units are in the process of implementing this system. Noble had identified all confined spaces and developed a procedure for working inside confined spaces consistent with Brazilian Safety requirements (NR33) and WBG’s EHS general guidelines. Noble mills are in different stages of making an inventory of all pressure vessels, documenting its technical specifications and developing individuals’ maintenance books, under a corporate program in accordance with Brazilian Safety Standard (NR13). Noble is also conducting an assessment of all plants to identify gaps with Brazilian Safety Standard of Electrical Systems (NR10).
Going forward, as set forth in the ESAP, Noble will conduct OHS audits of existing and newly acquired assets against local legal requirements and applicable IFC Performance Standards and will prepare a Corrective Action Plan to bring operations into compliance with these requirements. In Brazil, the audit will include specific reference to Brazilian National Standards NR10 and NR13.
However, implementation of these and other aspects related to Noble’s management of human resource (HR) labor matters is defined by locally applicable requirements. For example, in Brazil Noble has a formal General HR policy with key core objectives and further details according to Brazilian labor regulations. The core objectives include a commitment to promote a fair and safe workplace; to follow the labor laws and best sector practices; to recognize the workers’ rights of freedom of association; to avoid any form of forced and child labor; to stand against sexual or other forms of harassment. The HR Policy further defines terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity, vacation or holiday are established by national labor regulations and applicable sector specific collective bargaining agreements. Although Brazilian workers in general are familiar with the national terms of employment, the Company also informs them during the induction phase about the specific terms of the job position and additional benefits.
In Brazil, Noble has further adopted a range of HR operational procedures to guide the work of the HR department, such as a recruiting and hiring, termination, performance assessment and promotion, payment of wages and salaries and induction.
Going forward, and as set forth in the ESAP, Noble will develop and implement a global corporate human resources policy consistent with IFC Performance Standard 2 with further reference to local labor laws. Noble will review country-level operations Human Resources policies and procedures to ensure consistency with PS2 requirements and national law. The corporate and the local HR policies will make explicit reference to the Company’s commitments to non-discrimination and equal opportunity; minimum work age requirements; workers’ rights to freedom of association; respect for collective agreements, if these are present; maximum working hours; and working conditions and terms of employment. As part of the deployment of the global HR policy, the Company will develop and disseminate a corporate worker grievance policy and procedure applicable to its workers and contractors according to IFC PS2 and ensure implementation at the local level.
Non discrimination and equal opportunity: In addition to the commitment of its current parent company to the UN Global Compact, Noble’s management of non-discrimination matters is defined by locally applicable requirements. For example, as any form of discrimination is considered a crime in Brazil, Noble ha
s set up local procedures to avoid discriminatory practices (including sexual or moral harassment) in hiring and every day operations. Brazilian law also requires companies to investigate any complaints of misconduct and take corrective actions, as appropriate. Medical exams are requested as part of the hiring process and according to the function the worker will perform. In Brazil no HIV or pregnancy testing is performed as part of the hiring process or regular medical screening. Women employees are allowed to work in administrative or operational functions. Noble has also established recruiting and hiring procedures to meet Brazilian requirements and quotas for the hiring of disabled persons.
Retrenchment: Although the prospects for retrenchment in Noble’s current operations are unlikely given the Company’s future expansion plans, going forward, and as set forth in the ESAP, Noble will develop a retrenchment policy and procedure that complies with local requirements and IFC Performance Standards to be applied in the event that the Company’s business plans lead to retrenchment at any of Noble’s current operations.
Protecting the Work force: In addition to the commitment of its current parent company to the UN Global Compact, Noble’s management of non-discrimination matters is defined by locally applicable requirements. For example, in Brazil Noble ensures that no Child Labor or Forced Labor is used at their operations through their hiring and selection procedure. Child labor is illegal in Brazil and there is a task force from Ministry of Labor that inspects and enforces the law. In the recent years, sugar industry has agreed in a progressive approach to eradicate manual harvesting of sugarcane in the State of São Paulo, which significantly reduced the cases of forced labor in the region. Regarding their supply chain in Brazil, Noble is in constant dialogue with suppliers providing technical assistance and monitoring compliance regarding labor (and environmental) issues. A list of identified cases of child/forced labor are publically available at MTE (Ministério Trabalho e Emprego, in Portuguese) website (sistemasiti.mte.gov.br/ and portal.mte.gov.br/trab_escravo/resultados-das-operacoes-de-fiscalizacao-para-erradicacao-do-trabalho-escravo.htm ) and no cases of child/forced labor in sugarcane industry were identified in the region of Noble’s sugar mills.
As set forth in ESAP (Supply Chain Risk Assessment and Management), Noble will periodically check if suppliers are enrolled in the lists for Child/forced labor in Brazil. Going forward, Noble will develop and implement a chain of custody verification system, in accordance with Bonsucro Standards, to verify the existence of child/forced labor across supply chain, and will also periodically check if suppliers are enrolled in the Child/forced labor lists.
In the soy sector in Brazil, child/forced labor is not common owing to the high rate of mechanization of production. However, as
set forth in ESAP, the Company will develop and implement a supply chain verification system to periodically verify if their suppliers are enrolled in one of the child/forced labor lists in Brazil.
However, Noble has a high risk of exposure to harmful child labor in its supply of cocoa in Africa and has been working in this respect through local CSR initiatives aimed at improving the conditions of cocoa producers. This issue will be further address through the implementation of the Supply Chain Risk Assessment and Management described in the ESAP.
Occupational Health and Safety: Noble presently monitors trends in OHS accidents from its global operations. Nonetheless, Noble’s management of OHS matters, including the design and implementation of policies and procedures to prevent accidents, is defined by locally applicable requirements. For example, in Brazil Noble has developed well-structured team managing the OHS hazards and risks consistent with Brazilian labor requirements. Noble has mandatory OHS programs in place, such as risk prevention plans, health monitoring plans, an accident prevention committee, and emergency response plans. In Brazil, Noble has adopted policies and procedures to manage OHS, including, among others, OHS Management Program (Programa de Gestão de Segurança do Trabalho e Saúde-PGSST) that includes preventive/corrective inspections, accidents and incidents analysis, and OHS mandatory programs, such as Risk Prevention Plan (Plano de Prevenção de Riscos Ambientais – PPRA), Health Monitoring Plan (Programa de Controle Médico da Saúde Ocupacional – PCMSO), Hearing Protection Program (Programa de Conservação Auditiva), Respiratory Protection Program (Programa de Proteção Respiratória). Noble also has specific procedures for hazardous works (working at heights, working with heat, working with electrical systems, working in confined spaces, working in explosive atmospheres), which must be followed by the hazardous works permitting procedure.
Consistent with Brazilian requirements, Noble has implemented appropriate collective prevention measures in place and where is necessary they also provide the appropriate Personal Protective Equipment (PPE). Noble has adopted centralized pesticides storage warehouses, where products are mixed with water into trucks that deliver to the product to spraying front. All units are in the process of implementing this system. Noble had identified all confined spaces and developed a procedure for working inside confined spaces consistent with Brazilian Safety requirements (NR33) and WBG’s EHS general guidelines. Noble mills are in different stages of making an inventory of all pressure vessels, documenting its technical specifications and developing individuals’ maintenance books, under a corporate program in accordance with Brazilian Safety Standard (NR13). Noble is also conducting an assessment of all plants to identify gaps with Brazilian Safety Standard of Electrical Systems (NR10).
Going forward, as set forth in the ESAP, Noble will conduct OHS audits of existing and newly acquired assets against local legal requirements and applicable IFC Performance Standards and will prepare a Corrective Action Plan to bring operations into compliance with these requirements. In Brazil, the audit will include specific reference to Brazilian National Standards NR10 and NR13.
Air emissions: Noble’s management of atmospheric emissions is defined by locally applicable requirements. For example, in Brazil, Noble monitors emissions from all boilers every year, seeking compliance with CONAMA Res 357/06 and 436/11 requirements. In some cases and per CETESB request, air dispersion models were conducted and more restricted emissions thresholds were defined for Particulate Matter emissions.
Effluents: Noble’s management of effluents from its operations is defined by locally applicable requirements. In Brazil, for example, wastewater from sugar/ethanol mills in the State of Sao Paulo include: (i) process wastewater from ethanol production (vinasse), (ii) wastewater from cane washing, (iii) wet scrubber blow down from stack gas scrubbing, and (iv) miscellaneous wastewaters. Noble’s mills do not discharge wastewater to rivers or surface water bodies and all waste water is used as a fertilizer in the sugarcane plantations under a ferti-irrigation system. At the mills, effluents are used in irrigating fields within a radius of 30 kilometers by trucks. Noble has a formal management plan for vinasse application in the field and follows the CETESB standards of wastewater used in sugarcane plantations. The amount of wastewater applied in the plantations is determined by the soil characteristics and the nutrient needs of the crop. At least one of the mills, Potirendaba, has vinasse concentration process, which recovers 60% of the water that is re-used in the mill.
Vegetable oil and Biodiesel plants generate significant amounts of wastewater from the oil extraction process, and Noble plants relies on wastewater treatment facilities that includes physical chemical treatment unit and a sequence of aeration and polishing lagoons. Wastewater treatment is designed to meet local regulatory requirements, and typically COD, BOD, Suspended solids, temperature, PH, oil and grease are monitored.
Solid Wastes: Noble’s management of solid wastes is defined by locally applicable requirements. For example, its Brazilian sugar mills produce significant amount of organic wastes (filter cake, ashes from boilers and sand from sugar production tanks). These are taken to a composting area where they are piled and mixed up allowing composting process. This mixture is left to rest for 30 days and then applied to the fields. Metal scrap, is segregated, stored outdoors and sold for recycling. The solid waste from administrative area and dining-hall is collected and disposed to the local public waste system. Noble collects back all empty containers of pesticides and sends it to certified recycling companies. Going forward, as set forth in ESAP, Noble will evaluate, as part of the E&S monitoring of existing facilities and assessment of future acquisitions, the atmospheric emissions, wastewater effluents, and solid waste management practices of agricultural and industrial operations. The Company will ensure that emissions from sources, such as boilers
, effluents from oil pressing and sugar processing facilities, and wastes from all facilities are managed according to applicable WBG EHS Guidelines for existing facilities at a minimum complying with local regulatory requirements if it is not technically and/or economically feasible to achieve the IFC Performance Standards and WBG EHS Guidelines.
Sustainability of Water Resource: Noble’s management of water resources is defined by locally applicable requirements. In Brazil, for example, sugarcane cultivation in Noble’s operation relies exclusively on natural rainfall. Extraction of water from surface or groundwater sources for process operations is done at the sugar mills in Sao Paulo State where Noble indicates that it has obtained all required permits from the state government to extract the water. Water usage at the mills vary from 0.7 to 1.0 m3/ton-cane and is consistent the WBG’s EHS sugar production Guidelines reference and benchmark in the sector.
Greenhouse Gas Emissions: Noble’s management of greenhouse gas emissions is defined by locally applicable requirements. In Brazil, for example, Noble’s mills generate their energy from sustainable resources through co-generation of electricity from burning bagasse. Soy crushing and processing facilities in Brazil depend on a mix of woodchips, natural gas and crude oil to generate steam and energy from the boilers. Noble deployed new modern boilers (high volume and high pressure) to achieve high efficiency in energy production. Woodchips are sourced exclusively from planted forests to reduce total GHG emissions.
Integrated Pest Management: Noble’s pest management approach is defined by locally applicable requirements. For example, in Brazil the Company applies the principles of Integrated Pest Management (IPM) in its plantations. IPM practices include the use biological techniques to control sugar cane borer population with Cotesia flavipes parasite and Drury larvae control with Metharizium Bacteria. Approved chemicals and fertilizers are used, and application rates and methods are adapted to optimize consumption.
As set forth in ESAP, the Company will review its list of pesticides and will phase out all products that follow under WHO Class 1a and 1b, over time. As mentioned before, Noble is adopting a centralized system of storing and, handling and mixing pesticides that goes to the field ready to use. Noble uses exclusively tractors with cabinets for spraying operations, and handling, storage and use agricultural chemicals follow national regulations and can be considered best practices.
Hazardous Materials: Noble’s management of hazardous materials is defined by locally applicable requirements. Hazardous materials used and stored in Noble’s Brazilian sugar mills include significant amounts of chemicals, such as soda, sulfur acid, chlorine, cyclohexane and pesticides. New greenfield mills (Meridian and Potirandaba) have very good bulk chemical storage areas, with secondary c
ontainment, risk identification, warning signs, access control and emergency kits and showers. In Votuporanga, Noble is investing in a new plant aligned with Brazilian and World Bank EHS guideline requirements. Noble Bioenergia is also investing in chemical containers warehouses that have been storage outdoor for a while. Noble will also improve gas cylinders storage area following Brazilian standard requirements.
Effluents: Noble’s management of effluents from its operations is defined by locally applicable requirements. In Brazil, for example, wastewater from sugar/ethanol mills in the State of Sao Paulo include: (i) process wastewater from ethanol production (vinasse), (ii) wastewater from cane washing, (iii) wet scrubber blow down from stack gas scrubbing, and (iv) miscellaneous wastewaters. Noble’s mills do not discharge wastewater to rivers or surface water bodies and all waste water is used as a fertilizer in the sugarcane plantations under a ferti-irrigation system. At the mills, effluents are used in irrigating fields within a radius of 30 kilometers by trucks. Noble has a formal management plan for vinasse application in the field and follows the CETESB standards of wastewater used in sugarcane plantations. The amount of wastewater applied in the plantations is determined by the soil characteristics and the nutrient needs of the crop. At least one of the mills, Potirendaba, has vinasse concentration process, which recovers 60% of the water that is re-used in the mill.
Vegetable oil and Biodiesel plants generate significant amounts of wastewater from the oil extraction process, and Noble plants relies on wastewater treatment facilities that includes physical chemical treatment unit and a sequence of aeration and polishing lagoons. Wastewater treatment is designed to meet local regulatory requirements, and typically COD, BOD, Suspended solids, temperature, PH, oil and grease are monitored.
Solid Wastes: Noble’s management of solid wastes is defined by locally applicable requirements. For example, its Brazilian sugar mills produce significant amount of organic wastes (filter cake, ashes from boilers and sand from sugar production tanks). These are taken to a composting area where they are piled and mixed up allowing composting process. This mixture is left to rest for 30 days and then applied to the fields. Metal scrap, is segregated, stored outdoors and sold for recycling. The solid waste from administrative area and dining-hall is collected and disposed to the local public waste system. Noble collects back all empty containers of pesticides and sends it to certified recycling companies. Going forward, as set forth in ESAP, Noble will evaluate, as part of the E&S monitoring of existing facilities and assessment of future acquisitions, the atmospheric emissions, wastewater effluents, and solid waste management practices of agricultural and industrial operations. The Company will ensure that emissions from sources, such as boilers
, effluents from oil pressing and sugar processing facilities, and wastes from all facilities are managed according to applicable WBG EHS Guidelines for existing facilities at a minimum complying with local regulatory requirements if it is not technically and/or economically feasible to achieve the IFC Performance Standards and WBG EHS Guidelines.
Sustainability of Water Resource: Noble’s management of water resources is defined by locally applicable requirements. In Brazil, for example, sugarcane cultivation in Noble’s operation relies exclusively on natural rainfall. Extraction of water from surface or groundwater sources for process operations is done at the sugar mills in Sao Paulo State where Noble indicates that it has obtained all required permits from the state government to extract the water. Water usage at the mills vary from 0.7 to 1.0 m3/ton-cane and is consistent the WBG’s EHS sugar production Guidelines reference and benchmark in the sector.
Greenhouse Gas Emissions: Noble’s management of greenhouse gas emissions is defined by locally applicable requirements. In Brazil, for example, Noble’s mills generate their energy from sustainable resources through co-generation of electricity from burning bagasse. Soy crushing and processing facilities in Brazil depend on a mix of woodchips, natural gas and crude oil to generate steam and energy from the boilers. Noble deployed new modern boilers (high volume and high pressure) to achieve high efficiency in energy production. Woodchips are sourced exclusively from planted forests to reduce total GHG emissions.
Integrated Pest Management: Noble’s pest management approach is defined by locally applicable requirements. For example, in Brazil the Company applies the principles of Integrated Pest Management (IPM) in its plantations. IPM practices include the use biological techniques to control sugar cane borer population with Cotesia flavipes parasite and Drury larvae control with Metharizium Bacteria. Approved chemicals and fertilizers are used, and application rates and methods are adapted to optimize consumption.
As set forth in ESAP, the Company will review its list of pesticides and will phase out all products that follow under WHO Class 1a and 1b, over time. As mentioned before, Noble is adopting a centralized system of storing and, handling and mixing pesticides that goes to the field ready to use. Noble uses exclusively tractors with cabinets for spraying operations, and handling, storage and use agricultural chemicals follow national regulations and can be considered best practices.
Hazardous Materials: Noble’s management of hazardous materials is defined by locally applicable requirements. Hazardous materials used and stored in Noble’s Brazilian sugar mills include significant amounts of chemicals, such as soda, sulfur acid, chlorine, cyclohexane and pesticides. New greenfield mills (Meridian and Potirandaba) have very good bulk chemical storage areas, with secondary c
ontainment, risk identification, warning signs, access control and emergency kits and showers. In Votuporanga, Noble is investing in a new plant aligned with Brazilian and World Bank EHS guideline requirements. Noble Bioenergia is also investing in chemical containers warehouses that have been storage outdoor for a while. Noble will also improve gas cylinders storage area following Brazilian standard requirements.
Community Health and Safety- Noble’s management of community health and safety risks is defined by locally applicable requirements. Potential risks to communities from Noble’s operations in Brazil are primarily associated with the risk of explosions of ethanol tanks or sugar storage silos, air emissions from boilers, fugitive air emissions from trucks (dust) and aerial application of herbicides (to speed the sugarcane maturation process). In Brazil, most locations use aerial spraying of crops by licensed companies using crop spraying airplanes which follow local regulatory requirements. To improve oversight of these operations and minimize risk, as set forth in ESAP, the Company will developed a procedure to avoid the risks and impacts to health and other crops associated with aerial spraying of chemicals, which entails in weather conditions monitoring during aerial spraying, previous communications with neighbors and safety exclusion buffer zones from towns, small villages or households.
Noble’s sugar mills have annual sugarcane transportation plans, in which communities are mapped and routes of trucks are designed to avoid proximity with them. Access roads safety conditions are assessed and improvements are designed to ensure overall traffic and people safety. A report with the assessment and improvements is provided to the environmental authority.
Noble’s mills assess environmental noise outside their fences following Brazilian standard NBR 10151, and sometimes noise levels (62dbA) can be higher than the threshold for rural areas (45dbA), however since there are no direct receptor close by mills’ fences, this is not a concern for the time being.
Life and fire safety: Noble’s management of life and fire safety of its operations is defined by locally applicable requirements. In Brazil, Noble is deploying required life and fire safety equipment such as fire detectors, alarm systems, hydrants, foam chambers, and portable extinguishers following São Paulo State Fire authority Standard IT 27/2004. Noble has the permits from local fire departments (Auto de Vistoria do Corpo de Bombeiros – AVCB, in Portuguese) Industrial sites are classified according its risk of explosion (following Brazilian Standard NR10) and in those areas considered with high risk (a.e. distillery, sugar storage warehouse or soy silos) Noble deploys means of access control as well as intrinsically safe electrical equipment. Per CETESB request, sugar mills develop Risk Management Plans including (i) safety records of process maintenance (ii) maintenance and assurance of critical systems integrity; (iii) Operational Procedures; (iv) training and (v) Emergency Preparedness and response plan (Plano de Ação de Emergêncais – PAE, in Portuguese).
Emergency Preparedness and Response. Noble’s approach to emergency planning is defined by locally applicable requirements. In Brazil, Noble sites have obtained the required emergency response plans covering scenarios of typically
applicable emergency situations such as fires, explosions, and leaks to the environment as well as fire brigade, evacuation and communication plan. Fire drills are conducted twice a year. Sugar mills rely on dedicated professional firemen support and very well equipped emergency units. Going forward, and as outlined in the ESAP, Noble will develop and implement, in conjunction with the Corporate EHSS MS identified above in PS1, corporate policies and procedures to address life and fire safety and emergency planning of its operations according to IFC requirements.
Security Personnel: Noble’s approach to site security management is defined by locally applicable requirements. In the case of Brazil, Noble has access protocols for its operations which include checkpoints prior to entry into company facilities. Also in Brazil, security personnel are unarmed and are trained to respond to potential treats to company facilities and infrastructure, including procurement of public safety officials to address criminal activities. Going forward, and as outlined in the ESAP, the Company will develop and implement, in conjunction with the Corporate EHSS MS identified above in PS1, corporate policies and procedures to address security arrangements and the use of security forces according to IFC PS4 requirements.
Noble’s sugar mills have annual sugarcane transportation plans, in which communities are mapped and routes of trucks are designed to avoid proximity with them. Access roads safety conditions are assessed and improvements are designed to ensure overall traffic and people safety. A report with the assessment and improvements is provided to the environmental authority.
Noble’s mills assess environmental noise outside their fences following Brazilian standard NBR 10151, and sometimes noise levels (62dbA) can be higher than the threshold for rural areas (45dbA), however since there are no direct receptor close by mills’ fences, this is not a concern for the time being.
Life and fire safety: Noble’s management of life and fire safety of its operations is defined by locally applicable requirements. In Brazil, Noble is deploying required life and fire safety equipment such as fire detectors, alarm systems, hydrants, foam chambers, and portable extinguishers following São Paulo State Fire authority Standard IT 27/2004. Noble has the permits from local fire departments (Auto de Vistoria do Corpo de Bombeiros – AVCB, in Portuguese) Industrial sites are classified according its risk of explosion (following Brazilian Standard NR10) and in those areas considered with high risk (a.e. distillery, sugar storage warehouse or soy silos) Noble deploys means of access control as well as intrinsically safe electrical equipment. Per CETESB request, sugar mills develop Risk Management Plans including (i) safety records of process maintenance (ii) maintenance and assurance of critical systems integrity; (iii) Operational Procedures; (iv) training and (v) Emergency Preparedness and response plan (Plano de Ação de Emergêncais – PAE, in Portuguese).
Emergency Preparedness and Response. Noble’s approach to emergency planning is defined by locally applicable requirements. In Brazil, Noble sites have obtained the required emergency response plans covering scenarios of typically
applicable emergency situations such as fires, explosions, and leaks to the environment as well as fire brigade, evacuation and communication plan. Fire drills are conducted twice a year. Sugar mills rely on dedicated professional firemen support and very well equipped emergency units. Going forward, and as outlined in the ESAP, Noble will develop and implement, in conjunction with the Corporate EHSS MS identified above in PS1, corporate policies and procedures to address life and fire safety and emergency planning of its operations according to IFC requirements.
Security Personnel: Noble’s approach to site security management is defined by locally applicable requirements. In the case of Brazil, Noble has access protocols for its operations which include checkpoints prior to entry into company facilities. Also in Brazil, security personnel are unarmed and are trained to respond to potential treats to company facilities and infrastructure, including procurement of public safety officials to address criminal activities. Going forward, and as outlined in the ESAP, the Company will develop and implement, in conjunction with the Corporate EHSS MS identified above in PS1, corporate policies and procedures to address security arrangements and the use of security forces according to IFC PS4 requirements.
Noble’s management of biodiversity conservation is defined by locally applicable requirements and by voluntary commitments associated with various commodities certifications programs used by local operations.
Protection and Conservation of Habitats: In Brazil, sugarcane plantations are located exclusively on traditional areas of agriculture in Sao Paulo State, and no direct conversion of natural habitats to croplands or significant loss of biodiversity is expected from this project. However main concerns related to land conversion in critical habits are linked soy supply chain in both Amazon and Chacco biomes, as described below. In Brazil farmers are required to set-aside 20% to 80% of their lands as biodiversity conservation areas and also protect a buffer zone along rivers and water bodies. Noble sugar mills have a program to protect and reforest riparian areas at leased farms and implement ecological corridors following CETESB requirements. Noble has a program to educate and help land owners to move forward into compliance with Brazilian Forest Code which cover the gaps with biodiversity set asides requirements.
Sustainable Management of Living Natural Resources: As previously mentioned regarding Brazilian operations, sugarcane plantations take place in already converted land and consolidated areas of crop plantations in São Paulo state. As set forth in the ESAP, Noble will manage plantations in a sustainable manner following agribusiness/food industry good management practices. In Brazil, the Company’s owned sugar plantations will be managed as defined in Bonsucro standard of production.
Supply Chain: Noble reports that its Supplier Code of Conduct is implemented at the divisional or local levels. For example, in cocoa and coffee in West Africa, Noble informs its suppliers on its Supplier’s Code of Conduct and invites them to report on their social and environmental practices. This is an ongoing process to engage suppliers and provide impetus to make progress on their E&S performance. In addition, Noble looks for ways to ensure its products are grown in a responsible way and works to improve the labor standards in the agriculture community. In soybean sourcing, Noble reports that it has integrated certification schemes into Noble’s supply chain – such as the Biomass Biofuels and Sustainability Voluntary Scheme (2BSvs) – to help ensure greater supply chain transparency and integrity on the suppliers EHS performance.
Noble purchases soy from regions with significant conversion of natural and critical habitats, such as Amazon forest and Chaco region in both Argentina and Paraguay, and also has plans to possibly expand operations into Brazilian Savanna (Cerrado). In Brazil, Noble has one large crushing plant and combined biodiesel processing in Rondonópolis, and additional 3 storage units in Nova Maringá, Sorriso and Campo Verde in the North region of Mato Grosso State (Amazon region), where they originates approximately 20% of
its soybean needs from producers with whom they have direct contract (pre-finance). Noble provides the inputs and some working capital and producers are committed to sell the crops under predefined conditions. On the other hand, eighty percent (80%) of the total soy originates from spot market suppliers, which can be either from other small traders or farmers who sell their crops in the market without any contract agreement and from whom Noble has limited leverage and information such as their tax registry number, farm name, and region (municipality).
In Argentina Noble has one dedicated port with crushing plant and combined biodiesel processing in Timbues and additional warehouses in Salta, Córdoba, S. D. Estero and Chaco. In Paraguay, they have logistic warehouses in Katuete, La Paloma, Troncal, Magagnin and Corpus Christi. In both countries, the Grand Chaco is the target area for soy expansion.
Noble has engaged into Amazon Soy Moratorium, in which Soy industry has agreed with civil society in not purchasing soy from Amazon Biome deforested after 2006. Monitoring and verification is conducted by a third party, coordinated by soy industry association ABIOVE that provides annually a list of farms that must be banned from soy crushers and traders suppliers.
In Argentina, as part of previous commitment with IFC, Noble has agreed to develop and implement a policy to ensure responsible soy purchasing and pilot program to develop a suppliers’ database and monitoring of illegal clearings in Chaco region. Noble has engaged with Round Table of Responsible Soy (RTRS) and, during 2012, Noble´s supply chain management has been certified by 2BSVS Voluntary Scheme, which allows the company to export soybean oil and biodiesel to Europe; during 2014, provided and audited by independent body an individual private scheme to meet the requirements of EPA''s RFS2 program to export biodiesel to the U.S.
Noble is also sourcing crude palm oil which it refined in its refineries in India and China. As it does not management control over its CPO suppliers, Noble has not yet established any specific E&S requirements for its CPO suppliers.
Going forward and as set forth in the ESAP, Noble will develop and implement a comprehensive Supply Chain Risk Assessment and Management System. The system will be comprised of several discrete aspects, including a policy; supplier database and monitoring procedures; training program; and management monitoring and guidance. Given the significant current sourcing of soy from Brazil, Argentina and Paraguay and cocoa in West Africa, the Supply Chain Risk Assessment and Management System will include specific requirements for soy and cocoa sustainability purchasing plan from these countries, including monitoring and verifying land use and land use change.
Protection and Conservation of Habitats: In Brazil, sugarcane plantations are located exclusively on traditional areas of agriculture in Sao Paulo State, and no direct conversion of natural habitats to croplands or significant loss of biodiversity is expected from this project. However main concerns related to land conversion in critical habits are linked soy supply chain in both Amazon and Chacco biomes, as described below. In Brazil farmers are required to set-aside 20% to 80% of their lands as biodiversity conservation areas and also protect a buffer zone along rivers and water bodies. Noble sugar mills have a program to protect and reforest riparian areas at leased farms and implement ecological corridors following CETESB requirements. Noble has a program to educate and help land owners to move forward into compliance with Brazilian Forest Code which cover the gaps with biodiversity set asides requirements.
Sustainable Management of Living Natural Resources: As previously mentioned regarding Brazilian operations, sugarcane plantations take place in already converted land and consolidated areas of crop plantations in São Paulo state. As set forth in the ESAP, Noble will manage plantations in a sustainable manner following agribusiness/food industry good management practices. In Brazil, the Company’s owned sugar plantations will be managed as defined in Bonsucro standard of production.
Supply Chain: Noble reports that its Supplier Code of Conduct is implemented at the divisional or local levels. For example, in cocoa and coffee in West Africa, Noble informs its suppliers on its Supplier’s Code of Conduct and invites them to report on their social and environmental practices. This is an ongoing process to engage suppliers and provide impetus to make progress on their E&S performance. In addition, Noble looks for ways to ensure its products are grown in a responsible way and works to improve the labor standards in the agriculture community. In soybean sourcing, Noble reports that it has integrated certification schemes into Noble’s supply chain – such as the Biomass Biofuels and Sustainability Voluntary Scheme (2BSvs) – to help ensure greater supply chain transparency and integrity on the suppliers EHS performance.
Noble purchases soy from regions with significant conversion of natural and critical habitats, such as Amazon forest and Chaco region in both Argentina and Paraguay, and also has plans to possibly expand operations into Brazilian Savanna (Cerrado). In Brazil, Noble has one large crushing plant and combined biodiesel processing in Rondonópolis, and additional 3 storage units in Nova Maringá, Sorriso and Campo Verde in the North region of Mato Grosso State (Amazon region), where they originates approximately 20% of
its soybean needs from producers with whom they have direct contract (pre-finance). Noble provides the inputs and some working capital and producers are committed to sell the crops under predefined conditions. On the other hand, eighty percent (80%) of the total soy originates from spot market suppliers, which can be either from other small traders or farmers who sell their crops in the market without any contract agreement and from whom Noble has limited leverage and information such as their tax registry number, farm name, and region (municipality).
In Argentina Noble has one dedicated port with crushing plant and combined biodiesel processing in Timbues and additional warehouses in Salta, Córdoba, S. D. Estero and Chaco. In Paraguay, they have logistic warehouses in Katuete, La Paloma, Troncal, Magagnin and Corpus Christi. In both countries, the Grand Chaco is the target area for soy expansion.
Noble has engaged into Amazon Soy Moratorium, in which Soy industry has agreed with civil society in not purchasing soy from Amazon Biome deforested after 2006. Monitoring and verification is conducted by a third party, coordinated by soy industry association ABIOVE that provides annually a list of farms that must be banned from soy crushers and traders suppliers.
In Argentina, as part of previous commitment with IFC, Noble has agreed to develop and implement a policy to ensure responsible soy purchasing and pilot program to develop a suppliers’ database and monitoring of illegal clearings in Chaco region. Noble has engaged with Round Table of Responsible Soy (RTRS) and, during 2012, Noble´s supply chain management has been certified by 2BSVS Voluntary Scheme, which allows the company to export soybean oil and biodiesel to Europe; during 2014, provided and audited by independent body an individual private scheme to meet the requirements of EPA''s RFS2 program to export biodiesel to the U.S.
Noble is also sourcing crude palm oil which it refined in its refineries in India and China. As it does not management control over its CPO suppliers, Noble has not yet established any specific E&S requirements for its CPO suppliers.
Going forward and as set forth in the ESAP, Noble will develop and implement a comprehensive Supply Chain Risk Assessment and Management System. The system will be comprised of several discrete aspects, including a policy; supplier database and monitoring procedures; training program; and management monitoring and guidance. Given the significant current sourcing of soy from Brazil, Argentina and Paraguay and cocoa in West Africa, the Supply Chain Risk Assessment and Management System will include specific requirements for soy and cocoa sustainability purchasing plan from these countries, including monitoring and verifying land use and land use change.
Stakeholder Engagement
Noble’s approach to community engagement is defined by local needs and, where applicable, local legal requirements. In Brazil and Argentina, for example, Noble has a communication program that includes community communication of company’s activities such as, pesticides spraying and waiting period, sugarcane transport, and harvesting. New project developments have to be disclosed in public hearings and ESIA report, following Brazilian and Argentinean licensing procedures.
As part of Noble’s corporate social responsibility (CSR) initiatives Noble reports that it has trained over 15,000 smallholders cocoa farmers in West Africa on best practices and product diversification since 2009. The training aims to advance labor standards, food security and promote gender equality in the cocoa growing regions. Elsewhere, Noble indicates that it is transferring agricultural and business skills to raise the incomes and protect the biodiversity of coffee farmers in Brazil, Colombia and Vietnam. CSR initiatives originate at the local Noble operations which usually fund them as well. A CSR oversight committee reviews proposals which require funding from corporate sources.
As part of Noble’s corporate social responsibility (CSR) initiatives Noble reports that it has trained over 15,000 smallholders cocoa farmers in West Africa on best practices and product diversification since 2009. The training aims to advance labor standards, food security and promote gender equality in the cocoa growing regions. Elsewhere, Noble indicates that it is transferring agricultural and business skills to raise the incomes and protect the biodiversity of coffee farmers in Brazil, Colombia and Vietnam. CSR initiatives originate at the local Noble operations which usually fund them as well. A CSR oversight committee reviews proposals which require funding from corporate sources.
The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. Noble will also be requested to place an advertisement on its website (http://www.thisisnoble.com) to inform the public from IFC’s environmental and social review (ESRS) findings. For inquiries or concerns about the environmental and social impacts of this project please contact: Mauro Barbieri
Av. das Nações Unidas
8501, 22° andar
Pinheiros, São Paulo
SP, CEP 05424-020
Brazil
T: +55 11 35668771
mailto:maurobarbieri@thisisnoble.com
Av. das Nações Unidas
8501, 22° andar
Pinheiros, São Paulo
SP, CEP 05424-020
Brazil
T: +55 11 35668771
mailto:maurobarbieri@thisisnoble.com
Broad Community Support
Broad Community Support is not applicable for this project
Environmental & Social Action Plan
| Title | Anticipated completion Date |
|---|---|
| Global Corporate Environmental and Social Policy. Noble Agri will develop and publish its own Environmental, Occupational Health and Safety and Social Policy to be adopted by the new Board of Directors of the Company. | 12/31/2014 |
| Global Corporate E&S Management System. Noble Agri will develop and implement a corporate Environmental, Health and Safety, and Social (EHSS) Management System in accordance with IFC PS1, applicable to the development, construction and operational phases of business activities globally. The EHSS Management System shall include programs, plans and procedures applicable to the Company’s business activities in order to comply with applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and Safety Guidelines. The new global E&S plans and procedures shall be communicated to all Noble Agri operations, including employees and contractors. Copies of the EHSS policies will be shared with every new employee at the time of hiring and induction training. | 11/30/2015 |
| Noble Agri shall make available evidence of complete and effective implementation of the EHSS Management System (MS) at the regional and local operational level (e.g. final documentation of the EHSS MS, including policies, plans, manual procedures and programs, e.g. training logs, monitoring records, minutes of progress reviews). | 11/30/2016 |
| Assessment of Environmental and Social Impacts. As part of the development and implementation of the Global Corporate E&S Management Plans and Procedures, Noble Agri will develop and implement a corporate level procedure for the assessment of environmental and social impacts, applicable to any future expansion of commodity sourcing, own plantations, processing plants, and logistics activities, making reference to local regulations and the IFC Performance Standards. For existing assets, the assessment process will consist of an audit of operations against applicable national laws and regulations, and to the extent technically and financially feasible and cost effective, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and Safety Guidelines. For new assets acquired or any new brownfield or greenfield projects approved after the closing date, the assessment process will consist of an audit of operations against applicable national laws and regulations, and IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and Safety Guidelines. IFC will initially assist Noble Agri by reviewing draft terms of reference (ToRs) for contracting of ESIAs and EHS audits applicable to new projects and acquisitions to ensure consistency with IFC requirements. | 01/30/2015 |
| Organizational Competency. Noble Agri will appoint an experienced and qualified Global Corporate EHSS Director as well as ensure that the Company has adequate regional management to oversee EHSS compliance matters at the global and regional level. This includes the hiring of a Social Sustainability Manager for Latin America. | 05/30/2015 |
| Training. Noble Agri will develop and implement a management system procedure and evidence of the implementation of the staff training, at corporate, regional and country level, including mainstreaming into corporate/country-level training manual, addressing the Company’s EHSS Management System and Sustainability Sourcing policies, and to the extent IFC’s PS requirements (direct operations and supply chain) and WBG’s EHS Guidelines (for direct operations) as defined elsewhere in this ESAP | 11/30/2015 |
| Monitoring. For its direct operations (e.g. plantations and processing facilities), Noble Agri shall review and expand its existing Key Performance Indicators (KPIs) to mainstream EHSS parameters, including: a) Safety – Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (kiloliters/ton) and Efficiency - Consumed versus tons produced; Energy Usage (kWh/ton) - Energy consumed/tons produced; Wastewater monitoring effluents and air emissions parameters (including VOC); c) Staff - Retention - Number of full time equivalents leaving in the period /Avg. full time equivalents - and Training days - Number of training days provided to new and existing employees. | 08/30/2015 |
| Reporting. Noble Agri will prepare an integrated annual EHSS report format based on critical EHSS key performance indicators (e.g. compliance with legal and regulatory requirements, EHSS management system progress report and certification, including food safety management systems, energy and water consumption and efficiency; air emissions (NOx, SOx, particulates), including GHG emissions; noise levels and management, solid and hazardous waste management and disposal, effluent discharges from WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers complaints, supplier performance and community engagement activities) and publicly disclose annually following a format equivalent to the Global Reporting Initiative (GRI). | 12/31/2015 |
| Stakeholder Engagement and Community Grievance Mechanism. Noble Agri will develop a corporate level stakeholder engagement and community grievance policy, requiring all local operations to develop and implement stakeholder engagement plans which define engagement and disclosure levels appropriate to the level of adverse environmental impacts of the local operations, as well as stakeholder grievance redress mechanism consistent with IFC stakeholder engagement and grievance requirements. | 05/30/2015 |
| Project level stakeholder engagement and grievance processes will be applied in individual projects as part of the Environmental and Social Impact Assessment (ESIA) process. | 11/30/2015 |
| IFC will initially assist Noble Agri by reviewing project specific stakeholder engagement and grievance plans applicable to new projects to ensure consistency with IFC requirements. | 11/30/2015 |
| Supply Chain Risk Assessment and Management – Policy. As part of the supply chain component of its corporate EHSS Management System, Noble Agri will develop and implement a Sustainability Sourcing Policy. As a minimum, the Company’s pre financed suppliers (approximately 20% of total global supply) located in environmental sensitive regions (Amazon, Chaco, and Cerrado) must be consistent with sector specific cut off dates for land conversion (May 2009) and High Value Conservation Areas mapping (where it does exist), Amazon Soy Moratorium cut of date (June 2006) requirements in Brazil as well as legal requirements such as Rural Environmental Cadaster (Cadastro Ambiental Rural, CAR, in Portuguese), respect of Indigenous People Land and verification of embargoed areas as identified by the Brazilian Environmental Agency IBAMA. The Sustainability Sourcing Policy will similarly address other commodities such as the avoidance of child labor from cocoa in West Africa. | 06/30/2015 |
| Should the aforementioned Amazon Moratorium cease to be extended, IFC and Noble will explore and agree on alternative sustainability criteria that are applicable to pre-financed suppliers. The criteria will, at a minimum, achieve IFC's Performance Standards requirements (in the effective version as at signing of this ESAP) applicable to supply chains and will not contravene local laws. | 11/30/2015 |
| Supply Chain Risk Assessment and Management – Supplier Database and Monitoring. In order to implement its Supply Chain Policy as defined in this action item above (#9), Noble Agri will include in their existing credit review process/requirements for pre-financed agro-commodity suppliers, the following E&S verification points: - Absence from Amazon Soy Moratorium list of banned farmers - Absence from Brazilian official Forced Labor list (from Ministry of Labor) - Farmers must have a valid Registry number in the Environmental and Rural Cadaster (CAR, in Portuguese) or valid Environmental License. - Farms are not enrolled in IBAMA's embargoed list (Brazil) - Farms Should not be encroaching Indigenous People Lands (verifiable through CAR Website, in Case of Brazil) - Farms were not converted to agriculture prior to May 2009 and High Value Conservation Areas Mapping (where it does exist, Using CAR information and/or land use change information where available). a) Provision of copy of ESMS’s supply chain management procedure, detailing purchasing procedure, screening, monitoring and verification system. b) Provision of documentary evidence of the development/implementation of the supply chain monitoring and verification system. | 11/30/2015 |
| Supply Chain Risk Assessment and Management - Training in E&S Policies and Accurate Supplier Database Information. Noble will implement a training program for their field staff to: - Raise internal awareness of the Company’s enhanced supply chain policy as outlined above; -Raise external awareness of pre-financed suppliers on sustainable agricultural practices to help farmers improve yields,quality, and achieve third party certification of commodities from widely accepted bodies. a) Provide IFC with an overview of the top level work plan and materials for the implementation of the training program on Environmental and Social data collection for field staff; b) Provide IFC with evidence for the implementation of the training program on sustainable agricultural practices for pre-financed agro-commodity suppliers as appropriate. | 11/30/2015 |
| Supply Chain Risk Assessment and Management - Senior Management Monitoring and Guidance. Noble Agri will implement a management procedure for periodic reporting and monitoring of Supply Chain’s E&S risks and sustainability initiatives to senior management, to allow monitoring of progress of the dynamics of supplier’s classification, keep track of emerging environmental and social issues, determine E&S capacity building needs of field staff and suppliers, and ensure a proactive response and periodical realignment of the Company’s sustainability priorities and mitigation of potential Company exposure to commodity business risks in the short and long term. | 12/31/2015 |
| Company’s senior management will identify any needed changes in the corporate's ESMS for the management of suppliers to reduce risks in the supply chain. | 12/31/2015 |
| Supply Chain Risk Assessment and Management – Brazilian Sugar Operations. Complementing the aforementioned Supply Chain Management System, Noble Agri will develop and implement a chain-of-custody verification system, in accordance with Bonsucro Standards, to verify the existence of child/forced labor across supply chain, and will also periodically check if any of its suppliers appear in the child/forced labor lists, selectively purchasing from suppliers that meet the Company’s Supplier Code of Conduct. | 11/30/2016 |
| Human Resource Policy. Noble Agri will develop and implement a global corporate human resources policy consistent with IFC Performance Standard 2 with further reference to local labor laws. | 06/30/2015 |
| Company will review country level operations Human Resources policies and procedures to ensure consistency with PS2 requirements and national law. | 05/30/2015 |
| The corporate and the local HR policies will make explicit reference to the Company’s commitments to non-discrimination and equal opportunity; minimum work age requirements; workers’ rights to freedom of association; respect for collective agreements, if these are present; maximum working hours; and working conditions and terms of employment and local labor laws. | 11/30/2016 |
| Employee Grievance Mechanism. As part of the deployment of the global HR policy, develop and disseminate a corporate worker grievance policy and procedure according to IFC PS2 and ensure implementation at the local level. | 11/30/2015 |
| Occupational Health and Safety. Noble Agri will conduct OHS audits of existing and newly acquired assets against local legal requirements and applicable IFC Performance Standards and will prepare a Corrective Action Plan to bring operations into compliance with these requirements | 05/30/2015 |
| In Brazil, the audit will include specific reference to Brazilian National Standards NR10 and NR13. | 11/30/2015 |
| Pollution Management. Noble Agri will evaluate as part of the E&S assessment of existing facilities and future acquisitions the atmospheric emissions, wastewater effluents, and solid waste management practices of agricultural and industrial operations. The Company will ensure that emissions from sources, such as boilers, effluents from oil pressing and sugar processing facilities, and wastes from all facilities are managed according to applicable WBG EHS Guidelines for existing facilities at a minimum complying with local regulatory requirements if it is not technically and/or economically feasible to achieve the IFC Performance Standards and WBG EHS Guidelines. | 11/30/2015 |
| Pesticides. Noble Agri will review its list of pesticides and will phase out all products that follow under WHO Class 1a and 1b, over time. | 02/28/2015 |
| Pesticides Spraying. On all Noble Agri owned or leased plantations, in order to improve oversight of these operations and minimize risk, the Company will developed a procedure to avoid the risks and impacts to health and other crops associated with aerial spraying of chemicals, which entails in weather conditions monitoring during aerial spraying, previous communications with neighbors and safety exclusion buffer zones from towns, small villages or households | 11/30/2015 |
| Life and Fire Safety and Emergency Planning. Noble Agri will develop in conjunction with the Corporate EHSS MS identified above in PS1, corporate policies and procedures to address life and fire safety and emergency planning of its operations according to IFC requirements. | 11/30/2015 |
| Life and Fire Safety and Emergency Planning. Noble Agri will implement, in conjunction with the Corporate EHSS MS identified above in PS1, corporate policies and procedures to address life and fire safety and emergency planning of its operations according to IFC requirements. | 11/30/2016 |
| Security Personnel. Noble Agri will develop, in conjunction with the Corporate EHSS MS identified above in PS1, corporate policies and procedures to address security arrangements and the use of security forces according to IFC PS4 requirements. | 11/30/2015 |
| Security Personnel. Noble Agri will implement, in conjunction with the Corporate EHSS MS identified above in PS1, corporate policies and procedures to address security arrangements and the use of security forces according to IFC PS4 requirements. | 11/30/2016 |
| Noble Agri will develop a land acquisition/leasing policy and procedure which will be included into a management system procedure for addressing any future land/leasing acquisitions in accordance with IFC’s Performance Standards, and include in the corporate EHSSS MS as outlined under PS1. IFC will initially assist Noble Agri with the preparation of an land acquisition protocol to ensure consistency with IFC requirements. | 11/30/2014 |
| Noble Agri will implement a land acquisition/leasing policy and procedure which will be included into a management system procedure for addressing any future land/leasing acquisitions in accordance with IFC’s Performance Standards, and include in the corporate EHSSS MS as outlined under PS1. IFC will initially assist Noble Agri with the preparation of an land acquisition protocol to ensure consistency with IFC requirements. | 11/30/2016 |
| As part of the development of its Corporate EHSS MS, the Company will develop policies and procedures to manage any owned plantations in a sustainable manner following agribusiness/food industry good management practices. In Brazil, the Company’s owned sugar plantations will be managed as defined in Bonsucro standard of production. | 11/30/2015 |
| As part of the development of its Corporate EHSS MS, the Company will implement policies and procedures to manage any owned plantations in a sustainable manner following agribusiness/food industry good management practices. In Brazil, the Company’s owned sugar plantations will be managed as defined in Bonsucro standard of production. | 11/30/2016 |
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**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.