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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The operations do not have any impacts in relations to Biodiversity Conservation and Sustainable Management of Living Natural Resources (PS6), Indigenous Peoples (PS7), or Cultural Heritage (PS8).

This project has been given a B categorization as it is based on capacity expansion within existing facilities; the existing operations already, and those of the expansion will, use modern technologies and following international standards that are well respected and fully comply with the applicable Performance Standards. The operations have limited environmental impacts of which none are irreversible. All expansions are carried out within the existing project footprint except for the construction of a wastewater treatment plant (WWTP) at Gisenyi.

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.

Bralirwa is an integral part of the international Heineken Group. Heineken’s global standards; including food safety, environmental, health and safety, labor, alcohol policy and corporate social responsibility are all governed by centrally set principles, well defined in policies and procedures that are then implemented at the local country level. IFC’s due diligence looked into the Gisenyi application and found the standards applied at the two facilities to be consistent with the standards expected based on the definitions at the Heineken Group level and as explained during a visit to the Heineken Headquarters in Amsterdam. For example, the alcohol policy is predicated on the promotion of the responsible consumption of alcohol, aims to help prevent misuse and abuse of alcohol and strives to ensure that responsible consumption of beer is socially acceptable so as to help Heineken be a truly sustainable business. This is translated into actions on the ground in Rwanda, such as advertisement on how alcoholic beverage should be used responsibly and posters warning against drinking and driving. Bralirwa is also an active participant in advocating responsible consumption patterns as part of the Corporate Social Responsibility initiatives of the company. As such, Heineken’s alcohol policy, and such local actions, are judged to be in accordance with the intent of the WBG note on alcohol beverages (2000) and the included IFC conditions and criteria for supporting alcohol-related projects that relate to matters of health, private sector development, product safety and government revenues, etc.



Bralirwa has well established internal capacities managing the organizational aspects of the organization, this includes a human resource department, a strong health and safety organization, environmental officers, a medical organization, as well as strong organizational links to the Heineken organization ensuring all aspects of the organization are operated in line with the Heineken principles.



Bralirwa is preparing yearly Sustainability Reports and IFC has received and reviewed the 2013 report as the 2014 report is not yet ready for publishing. The 2013 report document Bralirwa’s commitment to moving from international raw material sourcing to local sourcing where possible, protecting water resources by reducing water consumption per unit produced and reducing impacts of discharges (the current project will compliment this to full compliance with WBG guidelines), reducing CO2 emissions per unit produced throughout the production and delivery to customer chain, and advocating responsible consumption. More details on the actual achievement are given in the PS3 section.



Bralirwa has certified their food safety systems at both facilities according to ISO 22000 and this certification ensures that both facilities also has full HACCP (Hazard Assessment and Critical Control Point) systems in place to ensure the safety of their products.

The facilities in Kiga
li and Gisenyi are using identical OH&S management systems based on Heineken’s internally developed standards. These are also consistent with the stringent global requirement of Coca Cola and has for the Kigali facility been certified according to OHSAS 18000.



The facilities are also using more or less identical criteria in their environmental management systems, although the Gisenyi facility is falling short on the current implementation in the wastewater treatment part of the system and this project will correct that. Based on the current performance the Kigali facility has achieved ISO 14000 certification and once the Gisenyi wastewater treatment facility has been implemented and full documentation prepared that facility will be following the same standard of environmental management.



Bralirwa’s beer production facilities were established in Gisenyi in 1959 at the current site, and have since then undergone numerous technological upgrades over the years to result in a modern production facility. Additional items that remain to be completed, including the replacement of older fermenting tanks, as well as modernization of the bottling lines are internal projects that will result in increased production capacities and are part of the upgrade projects to be carried out as part of this IFC project. None of these upgrades have external environmental implications and therefore only requiring normal industrial change approvals as per local regulations. The beer production plant’s greatest need is to install wastewater treatment so as to comply with both local regulation and World Bank Group (WBG) guideline standards. A project has therefore been developed to ensure the construction of a waste water treatment facility.



Bralirwa’s soft drink production facilities in Kigali were established in 1974 and include modern Coca Cola soft drink production lines. The planned expansions at these facilities includes the installation of a PET-bottling line within the existing bottling hall, and will, as for the Gisenyi facility, not have any external environmental impacts and therefore only require similar normal industrial change approvals.

Bralirwa is strictly adhering to Heineken’s international standards for labor standards. These standards have well developed policies in all relevant areas, including Employees and Human Rights Policies, Global Occupational Health and Safety Policy and are in compliance with all of IFC’s Performance Standard requirements under PS2. All employees have written standard employment contracts, there are standard procedures for the hiring process to ensure fairness in hiring and promotion, discrimination is strictly prohibited for all reasons, grievance mechanisms are incorporated, and contractor’s conditions and accidents/incidents are reported as if they were for direct employees to ensure the safety of the total workforce. Nobody can enter the premises without a safety briefing and receiving and using the appropriate personal protective equipment is required. Strict adherence to these principles and practices were observed at both sites.



The health and safety documentation and statistics were reviewed for the last 6 years for both the operations in Kigali and Gisenyi and for both operations there was a clear downward trend in incident and accident rates and all years were within the expected range for brewery and soft drink operations (0-5 Lost Day Accidents per Million Man Hours (LDA/MMH)).



Supply chain for locally sourced raw materials:

Bralirwa and a local maize processor (Minimex) have partnered to establish the BraMin irrigated maize farm in Kayonza District in Eastern Rwanda.  The BraMin farm is a pioneering investment in modern agribusiness in Rwanda making use of Centre Pivot irrigation systems and mechanized production.  Currently 6 pivot systems are in operation covering an irrigated area of approximately 300 ha.  The plan is to increase the irrigated area by adding an additional three pivots bringing the total irrigated area to 450ha.  If yields can rise from current levels of around 6 MT/ha to around 9MT/ha this would mean a production potential of 4,000 MT per year (assuming a rotation with another crop during the year).

 

In 2014 Bralirwa purchased close to 3,800 MT of maize grits locally. This is equivalent to around 9,400 MT of unprocessed maize procured from farms. The BraMin Farm will therefore be able to cover around 40% of Bralirwa’s needs.  A strategic priority for Bralirwa is to secure a local source of supply for the remaining 60% of maize grits it requires – around 5,500 MT per year at current levels of demand, and raising to 10,000 MT over the next 3-5 years with the expected increase in demand for beer.   Ideally, this maize can be sourced locally from a network of smallholder and commercial farmers. Currently Bralirwa has plans to procure from 20 cooperatives in Rwamagana and Kayonza districts.

 

A planned IFC AS (Advisory Services) project intends to help Bralirwa increase the supply of maize from local smallholder farmers for processing into maize grits which are used in its brewing operations. The objective
will be achieved through interventions at two levels: (1) Improving the professionalism of farmer organizations so they can function more effectively as businesses and provide better services to their members and thereby become more reliable suppliers to Minimex/Bralirwa; and (2) Improving the productivity of over 5,000 smallholder farmers - many of whom are close to or below the poverty line.  To improve farmer productivity, the project will provide a “productivity package” comprising: pre-harvest financing, improved seed, soil testing services, fertilizer and training in Good Agricultural Practices.  In addition, there will be at least ten on-farm pilots and demonstrations of irrigation technology.  The combination of these interventions is expected to double the average smallholder yields from the current 2.2 MT/ha per season to 4.4 MT/ha per season for maize over a five year period.  These are expected to more than double local farmer cash incomes and also produce incremental production of up to 6,000 MT of maize p. a. which is sufficient for Bralirwa’s present needs.



Bralirwa will, while encouraging and supporting the development of a local supply chain, carefully implement Heineken’s international standards for supply chain screening to ensure the local supply chain for maize includes ongoing screening of raw materials cultivated in-country against issues related to child and forced labor, significant OHS situations leading to life threatening situations and impacts on biodiversity. In addition to the Code of Conduct, Heineken will further define the approach to be taken to training of those involved in the supply chain. This item is included in the agreement with IFC through the ESAP.

The production facilities of Bralirwa are of different nature at the two sites and each site is therefore described separately below.



The Kigali soft drink bottling facility is a modern soft drink bottling facility in line with international standards for Coca Cola and Heineken. It is based on a closed system that is kept clean by CIP (Clean-In-Place) installations. The support function includes an empty bottle reception and storage facilities for both the reception of the empty return bottles and the clean filled product bottles. The facility, uses municipality-provided water that is purified before use, and is also equipped with a wastewater treatment facility to treat the relatively minor amounts of process water. Domestic wastewater is treated in septic wastewater treatment systems in accordance with local norms. Power is provided by the national grid. Solid waste is handled by licensed waste contractors.



The Gisenyi beer brewing plant has over the years had more challenges than the soft drink plant in Kigali due to the plant being initiated in 1959 and thereafter undergoing many upgrades to improve its efficiency and to ensure product quality. Today it is a fully modern facility with respect to beer quality and food safety and has achieved a very high efficiency that is being continuously improved by upgrading brewing tank sizes, filter types etc. The operation is already well within the WBG guideline with respect to water consumption per unit of beer brewed, but is aiming to reach the Heineken goal of 3.7 (Bralirwa goal is 2.4hl) of water consumed per hl of beer brewed. The plant has a CO2 collection system that ensures the CO2 developed during the fermentation process is cleaned and captured for compression and export to the soft drink factory in Kigali or reinjection in the beer during the tapping process to ensure the beer’s freshness. In this way the release of CO2 from the beer brewing process itself has been eliminated.



The power at the beer brewing plant is provided by the national grid, which currently has significant instability problems that result in many daily power outages. The plant is therefore equipped with a generator that runs on fuel oil. The intention is to utilize the national grid to the highest possible extent and minimize the usage of the generators. The facility also has a boiler facility for production of hot water/steam that runs on heavy fuel oil.



The beer plant’s weakest element of performance, with respect to guideline compliance, is its wastewater handling system. Currently solid residues are removed and sold to farmers (to be used as animal feed or to improve soil quality) but the treatment of the remaining liquid phase is not at the level required. Bralirwa has therefore developed a project to ensure the construction of a waste water treatment facility to achieve compliance with the local discharge regulations and this project has received local approval. IFC has now requested that this pro
ject be upgraded to WBG guideline standard before implementation as the WBG guideline discharge standards are more stringent than Rwandan standards with respect to BOD, COD and ammonia. The application of more stringent discharge standards is not expected to have implications on the current project approval.



The implementation of a wastewater treatment facility at the Gisenyi plant to WBG guideline standard and upgrade of the environmental management system at the same plant has been included in the agreed ESAP.



Greenhouse gas emission cause by the Bralirwa operations are limited to those caused by their use of electricity and fuel for generators and heating purposes and has been calculated to 11,497 tons CO2 equivalent per year.

The Bralirwa operations have limited community health, safety and security risks at or around the production facilities due to the processes not being based on flammable or explosive substances, but rather being based on wet food grade substances. The logistic system which bring raw materials to the facilities and products to the distribution centers uses trucks outsourced to more than 8 transport companies. To ensure best possible performance, and limit the risk to Bralirwa’s name and reputation, Bralirwa includes a requirement for safe driver training in the contract requirements for the contractors.

The Heineken operations are both located in relatively well populated larger areas, in Kigali in an industrial area for light industries surrounded by residences, and in Gisenyi directly surrounded by residences/light farming on three sides and Lake Kivu on the fourth side. Bralirwa is very actively engaged in community outreach both locally around the operational areas, but also in broader ways as they see community outreach and engagement as a positive advertisement. Bralirwa is also active in campaigns against drunk driving.

The company’s local production manager is following local activities to see where the company can positively engage and is together with the CEO deciding what engagements to pursue.

Bralirwa will supplement their ongoing engagement with the disclosure of this ESRS / ESAP on its Rwandan webpage and at its locations in Kigali and Gisenyi at the addresses given below:

http://www.bralirwa.com

Bralirwa Ltd.
Kigali Soft Drinks Plant:
Kicukiro
Kigali City

Bralirwa Ltd.
Gisenyi Brewery
Rubavu
Western Province

Contact person: Philip Ejiofor, mailto:philip.ejiofor@heineken.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Bralirwa will expand its Environmental Management systems, as fully implemented and certified to ISO 14001 at the Kigali operations, to a similar standard at the Gisenyi operation and in compliance to the requirements of PS1.	12/31/2016
Heineken’s International Supplier Code of Conduct will be applied to the local supply chain to be developed for maize grits to ensure ongoing screening of raw materials cultivated in-country against issues related to child and forced labor, significant OHS situations leading to life threatening situations and impacts on biodiversity. In addition to the Code of Conduct, Heineken will further define the approach to be taken to training of those involved in the supply chain.	07/31/2015
Bralirwa will, ahead of initiating the tender for the Waste Water Treatment Plant (WWTP) for the Gisenyi operation provide IFC with a set of operating specifications confirming that upon commissioning of the plant the effluent quality will conform to the WBG guideline for effluent from breweries.	06/30/2015
Bralirwa will, ahead of initiating any construction activities on the land for the WWTP for the Gisenyi operations provide IFC with documentation (a “RAP audit”) confirming the land acquisition process carried out by the authorities, pre-selling of the land to Bralirwa was carried out in a form consistent with Performance Standard 5 ensuring the 8 previous land users were left in an equal or better position than before the land take.	06/30/2015
The Road Transport Development Authorities (RTDA) of Rwanda is planning a minor road realignment / expansion adjacent to the current Bralirwa Gisenyi operations. This realignment / expansion is likely to cause a minor resettlement. Although the realignment / expansion is carried out by the RTDA in accordance with Rwandan regulations and cannot be affected by Bralirwa, Bralirwa will follow this process closely and will intervene, on a best effort basis, to ensure at all times that residents or land users affected by such realignment will be compensated in accordance with Performance Standard 5. Bralirwa will, on a half yearly basis provide IFC with updates on the situation until the final solution has been implemented and verified to comply with Performance Standard 5 levels.	09/30/2015