While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This proposed project is classified as Category B according to IFC’s Environmental and Social Review Procedure as the environmental and social impacts of the project are limited, site-specific and can be minimized, avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. Key environmental and social issues associated with this project include: i) managing key environmental impacts including that related to air pollution from the furnace and industrial waste water discharged to the sewage system; ii) ensuring compliance with applicable national laws and regulations; iii) managing Occupational Health and Safety (OHS) risks; iv) adopting energy efficiency measures to ensure alignment with industry benchmarks; v) management of life and fire safety and emergency response; and v) ensuring adequate handling of hazardous substances and appropriate waste management.

The facility is located in the vicinity of an industrial area and land for the facility was acquired on a willing seller willing buyer basis. Thus PS 5: Land Acquisition and Involuntary Resettlement does not apply and neither does PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources. There are no indigenous people in the area thus PS 7: Indigenous People does not apply and neither does PS 8: Cultural Heritage given the project location.

The information about how these potential impacts will be addressed is summarized in this Environmental and Social Review Summary (ESRS) and in the attached Environmental and Social Action Plan (ESAP) agreed upon with the company.

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

Environmental and Social Assessment and Management System

Sphinx has prepared an Environmental Impact Assessment (EIA) that was approved by the Egyptian Environmental Affairs Agency (EEAA) as part of the process of acquiring the license. As per national regulations, prior to expansion of the facility, an EIA for the expansion activities is required as is approval by the EEAA.



Sphinx operations are certified against ISO 9001, a quality management system. Plans are underway to obtain certification against ISO 14001, an environmental management system, and OHSAS 18001, an occupational health and safety management system; these are to be completed by end of 2015. Further, as set forth in the ESAP, the company will develop and implement management systems aligned with these certifiable systems allied to the Performance Standards and the World Bank Group (WBG) EHS Guidelines.



Sphinx has an EHS committee chaired by the CEO and the head of each individual department is a member thereof. The HSE Section Head is the committee coordinator and the committee convenes every month, and in the event of an emergency. During the committee meetings monthly OHS statistics are presented and discussed. The committee discusses EHS observations reported by the employees and compiled by the HSE department, as well as planned HSE projects and activities.



Identification of Risks and Impacts

The company identifies risks for each of its operations based on the severity of the impacts and the likelihood of its occurrence. As part of the ISO 14001 preparation the company plans to develop a detailed risk assessment to identify all relevant environmental and social risks and impacts associated with all operational activities.



In addition to the risks associated with Sphinx activities, there are also risks related to the air separation unit located within the company premises, but owned and operated by the Air Product company. This facility supplies nitrogen and hydrogen to Sphinx. This plant is considered an associated facility in accordance with the Performance Standards given it is focused specifically on supplying Sphinx. Sphinx ensures that the risks associated with Air Product’s processes are mitigated through application of their policies and procedures.



Organizational Capacity and Competency

The company has an HSE Section Head who manages a team consisting of one supervisor and four technicians. The HSE Section Head reports to the HR and Administration Senior Manager, who in turn report to the CEO. The HSE Section Head is responsible for developing and implementing HSE policies and procedures and supervises all activities related to HSE within the company. The HSE team has dedicated representatives available throughout the three shifts to address any HSE issue that may arise.



The HSE Section head and his team are also responsible for HSE training of all staff members, such as general EHS induction training, as well specific training for each wo
rker based on the nature of the activities they are involved with, e.g. working at heights, operating mobile equipment, handling of glass sheets and so on. There is a system whereby staff can report any HSE risks identified and all issues reported are recorded with reports compiled monthly confirming how the issues has been addressed.



The training plan for workers is developed by the HR department and there is a training needs assessment for all workers. HSE training is part of induction training and there is specific HSE training based on the type of work undertaken and the associated risks.



Emergency Preparedness and Response

The company has an emergency plan covering different types of emergencies. The plan identifies the various risks and categorizes them into mechanical, electrical, physical, biological and chemical. The plan identifies the available protection measures within the plant and illustrates the procedures to be taken for managing handling emergencies. The plan also covers the procedures for investigations and analysis and conducting the necessary awareness.



The company has a fire detection system, different types of fire extinguishers, including that for carbon dioxide, foam, nitrogen and dry powder, and an automatic fire extinguishing systems in control rooms and production units. The fire extinguishers do not align with national requirements and thus the company has developed a program to replace all the extinguishers; of the 450 fire extinguishers, 150 have already been replaced and the remaining are planned to be replaced in 2015, this requirement is also defined in the ESAP. In addition, as set forth in the ESAP, the company will conduct regular drills including that related to fires given these have not been undertaken to date.



As per national requirements, 25% of the workers are trained on life and fire safety and requirements to respond in cases of an emergency. The company plans to increase the number of trained workers over the coming two years to ensure all workers are trained accordingly.



Monitoring and Review

As per national regulatory requirements the company conducts annual environmental monitoring. This includes workplace measurements related to noise, heat stress, illumination, and air pollutants. In relation to environmental aspects this includes furnace stack emissions and wastewater quality. The previous monitoring was undertaken in February 2013 by the Center for Environmental Research and Studies in Cairo University. As set forth in the ESAP, the company will conduct the overdue 2014 annual monitoring and regularize this as an annual requirement.



The company also retains an environmental register as per the national regulations and this includes information on the production process, raw materials types and consumption rate, output types and production rate, as well as waste types, generation quantities and methods of disposal and treatment. The register is updated on an an
nual basis and retained by the company to be reviewed EEAA representatives during inspection visits.



Stakeholder Engagement

Within the scope of the EIA carried out at project inception a public consultation meeting was held where representatives from regulatory bodies, the community and industrial establishments in the general vicinity attended.



The company is located in an industrial area and the nearest community is 15- 20 kilometers distant. According, continuous community engagement and consultation is not required. However, as set forth in the ESAP, the company will develop and implement a grievance mechanism to receive and investigate complains related to the environmental and social performance of the company.

Working Conditions and Management of Workers Relation

Sphinx employs 335 workers of whom 265 are directly contracted by the company and the remaining contracted via a third party. Workers recruited through a third party are typically medium skilled workers required for specific activities such as in workshops and utilities.



The plant operates continuously with three shifts per day of eight hours each. The company does not hire workers below 18 years which is in line with national regulations. All workers hired by Sphinx or by the third party have medical insurance through a private company. Also the company provides transportation and if needed accommodation for all workers. All workers receive free meals during their shifts.



Human Resources Policy and Management

Sphinx’s human resource documentation includes procedures related to housing benefits, transportation, worker injury, an incentive scheme, overtime payments, and international travel. In addition there is a procedure related to sick leave, annual leave and maternity leave.



HR procedures are applied to both direct contracted workers and those contracted through the hired party, except for contract termination. In case of those contracted through a third party, the workers are entitled of only one month notice with no compensation.



The Air Product company managing the nitrogen and hydrogen processing unit within Sphinx has HR policies covering diversity, equal opportunity and harassment, compensation and benefits, freedom of engagement, child labor and forced labor and the supply chain; these policies are considered generally aligned with this Performance Standard.



As set forth in the ESAP, the company will establish and implement an overarching HR policy in line with PS2 requirements to cover non-discrimination and equal opportunity, grievance mechanism, employee appraisals, workers organization, OHS, and training and development



Workers Organization

There are no worker unions in the company and workers have not requested to join unions. The company management does not prevent workers from joining unions though, and national legislation allows for such.



Non-Discrimination and Equal Opportunity

Hiring and appraisal of employees are carried out based on equal opportunity practices Recruitment is done through posting vacancies internally, on the company’s website and through recruitment agencies. In respect of salaries an annual appraisal is carried out and the minimum salary for all Sphinx employees is within the average industry range Given there is no formal policy on non-discrimination and equal opportunity, the company will develop and implement a documented policy for such.



Grievance Mechanism

The company’s grievance mechanism policy is not documented. In the event of grievances workers engage directly with the HR and Administration Manager, or their direct manager. If the grievance cannot be addressed by these individuals, it is escalated to the CE
O. Given the above system is not formalized a grievance mechanism will be developed as part of the HR polices in line with the requirements of this Performance Standard and include a mechanism for anonymous reporting; this is defined in the ESAP.



Occupational Health and Safety

The company has a draft OHS policy that has recently been developed and pending management approval. Existing procedures related to OHS include providing work permits for occupational hazard activities such as working at height or in confined spaces, conducting OHS training, and monitoring and reporting OHS performance of the company. Oversight for OHS is provided by the EHS Section head and the team supporting him.



Annual monitoring of workplace conditions is carried out on an annul basis in 17 different locations in the production areas and utilities. The monitoring include that related to workplace air quality measurements i.e., that related to particulates, nitrogen oxide, nitrogen dioxide, carbon monoxide, sulphur dioxide and hydrogen sulfide. As per the February 2013 monitoring results the measurements are found to be within national regulatory limits.



Measurements of light intensity, heat stress and noise levels are also carried out at the same locations as defined above and as per the February 2013 measurements. Aside from illumination in some instances, the results indicate compliance with national regulations and those of the Word Bank Group (WBG) EHS Guidelines; the company has taken the necessary measures to increase the light intensity in these locations. As per the ESAP, the company will conduct the overdue annual monitoring measurements and analysis, as the last measurement was carried out in February 2013. The company will review the work place air pollutants being measured to reflect emissions to include that associate with tin, selenium and cobalt, as opposed to just combustion emissions.



The HSE Section Head compiles data on accidents, injuries, near misses, and lost time and this data is reported to management on a monthly basis. The company will however start compiling data on man hours worked to allow calculating the Lost Time Injury frequency Rate and comparing this to the industry average.



It has been reported that in the last two years there have been no eye injuries, a common risk in the glass manufacturing industry. This is a result of worker training and enforcement of the wearing of protective glasses.



For all accidents a report is prepared including a description of the accident, the injuries, causes of the accident, and recommendation and corrective actions to be taken.



Workers Engaged by Third Parties

Contractor workers receive general HSE training as well as specific safety training based on their type of job. In the contractual agreement with contractors, the contractors are obliged to provide their workers with personal protective equipment. As set forth in the ESAP, contractors will be required to compl
y with the company’s OHS procedures and practices (including training requirements) and will have access to either the company’s grievance mechanism to be developed, or that associated with the contracting company.

Resources Efficiency

Waste glass resulting from glass cutting and defected products is recycled in the process and is known as cullet; this results in a reduction in energy consumption in the furnace. The company plans to increase the percentage use of cullet, though external cullet of good quality is not readily available.



Energy and Material Efficiency Projects

Energy used in the production is mainly natural gas and electricity. Natural gas is used in the melting furnace, while electricity is used in operating all other production equipment including the batch unit, bath unit, annealing lehr and cold end cutting.



In 2014 the company implemented a number of energy efficiency activities including fine tuning fuel distribution in furnaces and reduction of raw material moisture content The slight reduction in specific natural gas consumption from 2013 to 2014 can be attributed to these activities.



In addition, Sphinx is part of IFC Advisory cleaner production for companies’ project. As part of the project an energy audit was completed in October 2014 and opportunities to improve efficiency included implementation of an Energy Management System (EMS), recovery of flue gases waste heat, insulation of furnace walls, increase of cullet use, minimizing excess air and reducing the furnace air leakage and reducing the batch wetting. Based on 2013 figures, these measures are estimated to result in 30% electricity savings and 11% natural gas savings. The company has already started implementing some of these measures including reducing the batch wetting and insulation of the furnace walls, and is investigating the feasibility of implementing the other measures. As set forth in the ESAP, the company will develop and energy efficiency plan to reduce its specific energy consumption and agree on such with IFC.



Water

Water consumed is obtained from the public network. Water for industrial purposes is mainly for compensating the blow down and evaporation from the closed cycle cooling system and for compensating the evaporation from the firefighting emergency tank.



Green House Gases (GHG) Emissions

Based on 2013 figures taking into account the consumption of natural gas and electricity and diesel consumed in vehicles the total GHG emissions from Sphinx Glass equates to approximately 144.5 thousand ton CO2 equivalent per year. As set forth in the ESAP, the company will quantify annually the GHG emission in line with an international methodology.



Process emissions occur due to the decarbonisation of the carbonate raw material in the process input, mainly sodium carbonate Na2CO3, limestone CaCO3 and dolomite CaMg(CO3)2.



Air emission and ambient air quality

Air emissions are generated via two stacks i.e., the furnace stack and the coating machine stack. Flue gases emitted from the furnace stack are monitored with the measured parameters including carbon monoxide, sulfur dioxide and nitrogen oxide. Based on the latest monitoring results
of February 2013 emissions for all the parameters were determined to be within national regulatory limits and those defined in the WBG EHS Guidelines. As per the ESAP, the company will include the measurement of other pollutants such as particulates and heavy metals from the furnace stack specified in the WBG EHS guidelines, in the monitoring plan. Emissions from the coating machine stack will also be regularly monitored.



Sand storage and handling is carried out in open area with the premises of the company in an area near the entrance. Loading and uploading of the sand results in dust within the plant and outside the plant given the storage location. As per the ESAP, the company will evaluate options to enclose sand storage and handling measures to minimize dust generation associated with this source.



Nitrogen and hydrogen are used in the production process are provided through a dedicated air products manufacturing unit located in the company premises owned and operated by a separate company. The feeding, mixing and distribution system for nitrogen and hydrogen is installed outdoor and coverd for safety reasons.



Hazardous Materials

Sodium nitrate is used in the production of coated glass. Handling of sodium nitrate is carried out by the Civil Defense Authority in Sadat city which is affiliated to the Egyptian Ministry of Interior. The team from the Civil Defense Authority is responsible for transferring the material to the plant and loading it into the furnace.



Other hazardous material used in the process includes selenium and cobalt oxide, used as coloring agents. These materials are currently stored in the production units. As per the ESAP, the company will establish a chemical storage warehouse for storage of all chemicals. This storage area will be equipped with necessary firefighting equipment and safety measures and will ensure proper storage of chemicals and their compatibility.



Solid Waste Management

Hazardous waste generated from the plant includes used filters, spent oil, and used florescent lamps and empty containers of hazardous chemical substances. These wastes are collected and disposed by the Nasriya Hazardous Waste Management Facility, based on a contractual agreement between Sphinx and the organization. Non-hazardous solid waste is collected by solid waste contractor. Waste such as used spare parts and office equipment is stored in an area within the company premises in preparation of being sold to contractors. As per the ESAP, the company will develop a plan for managing and disposing the accumulated waste and will establish a dedicated waste storage collection area within the facility, including that related to hazardous waste.



Wastewater Treatment

Wastewater generated from Sphinx is mainly blowdown cooling water and condensation water from air compressors. The wastewater is mixed with domestic wastewater and discharged directly to the sewage network. Analysis of these two wastewater streams are ca
rried out prior to mixing with the sewage network and is in compliance with national regulations limits for discharge to the sewage network. Other sources of industrial wastewater would include cleaning of production lines and cleaning of spills. As set forth in the ESAP, the company will integrate wastewater measurements and analysis at the final discharge point to the monitoring plan to ensure compliance with regulatory limits in the final discharge.

Hazardous Materials Transportation and Safety

For safety and security reasons, the transportation of sodium nitrate from Alexandria port to the company, which is about 150 km, is carried out by the Civil Defense Authority in Sadat. This is to ensure that this substance, which is used in explosives, will not be used for other purposes other than raw material in the production process. Given the project location within the industrial area with no communities in proximity the risks to the public associated with the general transportation of products and services related to the company are limited.



Security Personnel

The security arrangements in the company are carried out by an outsourced company, Falcon. The guards are not armed. They are trained, and Falcon provides the company of evidence of their training. Areas surrounding the company are industrial establishments and empty plots of land. The closet community to the company is 15 -20 km away.

Sphinx Glass in coordination with Menofiya University offers training program for 15 students each year from different faculties including engineering, science, and commerce. Given the project location other than engagement associated with the EIA, no engagement is undertaken is not considered necessary.

The ESRS and the ESAP will be translated into local language and be available at the company premises allied to being published on the company website.

For more information, enquiries and comment please contact:
Mr. Mohamed Khattab
52 Corniche El-Nil, Al-Sharifain Tower, Maadi, Cairo Egypt
Tel+202 252 58 005
Fax+202 252 60 506

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Develop and implement environmental and occupational health and safety management systems that incorporate the existing procedures and are consistent with the requirements of ISO 14001, OHSAS 18001, IFC Performance Standard 1 and the World Bank Group (WBG) Environmental Health and Safety (EHS) Guidelines. These systems are to include: • Environmental objectives and targets including plans to achieve such; • Monitoring plans for wastewater analysis at the discharge point to the sewage network. Note: Following initial monitoring where parameters are not in alignment with national legislation and the World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines, Sphinx will assess alternatives options to address parameters not in alignment and agree on a time based action plan with IFC to ensure such alignment. • Monitoring plans for air emissions measurements at the two stacks (at the furnace stack in addition to the combustion emissions, particulate and heavy metals are also to be monitored). Notwithstanding anything to the contrary in this document, air emissions must comply with the requirement under Egyptian Environmental Law No. 4 of 1994 and its amendments and executive regulations. Where parameters are not in alignment with Egyptian Environmental Law No. 4 of 1994, Sphinx will assess alternatives options to address parameters not in alignment and agree on a time based action plan with IFC to ensure such alignment. • An occupational health and safety (OHS) risk assessment procedure for each activity and action plans and procedures to mitigate the identified risks; • Monitoring plans that cover all OHS aspects including workplace measurements (noise, air pollutants, heat stress, light intensity) to ensure compliance with national regulations as well as the WBG HSE Guidelines; and • KPI’s for environmental and OHS parameters and reporting requirements for such to ensure senior management are regularly informed of the status quo.	09/30/2015
Replace all fire extinguishers with those approved by the Civil Defense Authority.	12/31/2015
Train employees on the emergency response plan including evacuation and conduct regular fire drills.	06/30/2015
Update the human resource policies and procedures to align with PS2 requirements and more specifically ensure compliance in respect of requirements related to non-discrimination and equal opportunity, grievance mechanism, hiring process, and employee’ appraisals.	03/31/2015
Sphinx to ensure contracted workers are subject to the company’s OHS practices and procedures and receive training thereon. In addition, such workers will either have access to the company grievance mechanism or that applied by the contracting company.	03/31/2015
Develop and implement an energy efficiency plan to reduce energy consumption. The plan will identify the energy efficiency measures to be adopted, the timeframe for implementation and the anticipated energy savings.	09/30/2015
Undertake an assessment of options to enclose the sand storage area and handling of the material to minimize fugitive emissions.	06/30/2015
Annually quantify GHG emission in line with an international methodology; to commence in 2015.	12/31/2015
Establish a chemical storage area for all chemicals i.e., hazardous and non-hazardous, aligned with accepted industry practice. The storage area is to be equipped with necessary firefighting equipment and safety measures.	03/31/2016
Develop and implement a plan for managing and disposing accumulated waste in agreement with IFC. The plan is to include establishment of a dedicated solid waste i.e., for general and hazardous waste, storage area within the facility.	09/30/2015