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 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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

Impacts related to the following Performance Standards were not identified during IFC’s review: PS5: Land Acquisition and Involuntary Resettlement: the Company facilities are limited to the ownership and or/lease of warehouse facilities located in industrial areas of towns and cities. As noted above the Company is planning on increasing its warehousing capacity; these additional buildings, however, will only be undertaken in land demarcated for such uses (e.g. within industrial zones for the large warehouse addition) or for those small satellite structures (mini-warehouses) on land that is for sale or available for lease in a willing-buyer/lessee, willing-seller/lessor scenario. In addition, land will only be chosen that is not used for economic activity or that accommodates any residents; PS7: Indigenous Peoples: No Indigenous People are impacted by any of the existing locations of the Company’s operations (e.g., existing warehouses are predominantly found in industrial areas, and future locations will be similarly located); and, PS8: Cultural Heritage: No sites of cultural heritage have been impacted by the location of any of the existing operations; future sites will be similarly chosen.

This investment is classified as a Category B project in accordance with IFC’s Policy on Environment and Social Sustainability. Based on information reviewed by IFC, this investment will have limited adverse E&S impacts that are few in number, are generally site specific, largely reversible and readily addressed through mitigation measures, as outlined in the Environmental and Social Action Plan (ESAP) attached to this ESRS. The main E&S issues include the development and implementation of an integrated environmental and social management system (ESMS), commensurate to risks, that makes references to all appropriate regulations and requirements including those related to occupational health and safety of workers and contractors performing duties in Company operations, including warehouses and transportation. Wienco will ensure commercialized agrochemical products follow: (i) WHO recommendations of use, handling and disposal; (ii) WHO Class 1a and 1b formulations are banned; (iii) WHO Class 2 formulations are only used with appropriate controls; and (iv) farmers are trained on basic OHS aspects of agrochemicals commercialized. In addition, further development of formal community interactions with those living in proximity to operations will be required.

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. The Company does not have a formal assessment process to identify, assess and ultimately manage E&S risks within its core business operations (receipt and storage of crop protection products and fertilizers). A third party assessment of Wienco has been undertaken in the past as a pre-requisite to obtain other financing. This assessment used IFC’s Performance Standards as applicable E&S requirements and generated an E&S Action Plan for the Company to address specific E&S issues. Key findings centered on the need to conduct assessment of operations, formalize an E&S management system (including specific issues related to waste management.) These issues were reviewed and discussed with Wienco senior management in Ghana who stated that the Company is working to address them commensurate to the risks identified and continue implementation in Ghana;



Wienco does apply for, and has received, relevant permits and operating licenses for its premises and activities (such as from the Ghana EPA and Liberia EPA for crop protection chemicals and from the Ghana Fire Protection Service for those related to fire protection measures in its warehouses). Wienco senior management confirmed that they have all relevant environmental permits for their operations in Liberia. Whereas there are limited E&S risks associated with the receipt, storage and distribution of fertilizers and crop protection products to customers, the Company will ensure an understanding of risks and impacts (such as those identified in previous assessments, this review and those contained within recognized international industry codes of conduct, such as the FAO Code of Conduct on the Distribution and use of Pesticides, the Safe Warehousing of Crop Protection Products, etc) inform assessment and management actions. At set forth in the ESAP, the proposed development of a quality management system within Wienco Ghana and Liberia, may integrate as appropriate criteria from the above sources so as to provide for enhancements in warehousing and related infrastructure, good product management and overall management of risk, including those of an E&S nature.



The grower associations, that were set up in large part by Wienco utilize criteria within recognized certification schemes to assess E&S risks. For example, a majority of members (organized as groups and totaling approximately 8,500 farmers) within Cocoa Abrabopa are currently certified to the Rainforest Alliance and UTZ schemes, the certification process being managed by the association itself (i.e. members are covered by an association-wide certification). In Liberia, a majority of Cocoa Lela 1,500 members are scheduled to be UTZ certified and Rainforest Alliance by 2015. Combining these certification standards into a manual that is provided to and used by farmers has resulted in a comprehensive approach to E&S risk identification and management covering such aspects as protection of biodiversity, crop
protection chemical management and social and community issues such as child labor.



Management Program, Organization and Training. Wienco Liberia is a small scale operation with a total of 27employees. The Company does not have an E&S manager per se; E&S duties as currently identified are integrated into the responsibilities of individuals in management and supervisory positions throughout the organization. For example, warehouse managers are responsible for the proper management of fumigation of products. Individuals met during the 2012 Ghana appraisal working at the Ghana operations attested to having received appropriate training on the correct application of chemicals in the fumigation process.



Grower associations in Ghana are well organized and resourced. The association partnering with Wienco Liberia, Cocoa Lela Association (CLA), has a governing structure setting strategy and a network of business promoters interfacing with farmer groups. In between lie supervisors, inspectors and auditors who ensure requirements related to the certifications schemes (e.g. UTZ certified) continue to be met. Wienco Liberia supports CLA on technical assistance to farmers who receive training on organizational and business matters (the need to open a bank account, how to create and maintain records, keeping minutes of group meetings, etc) as well as those of a technical nature (such as appropriate cultivation techniques, proper storage and application of crop protection products, yield prediction and integrated pest management techniques). CLA provides the association’s technical training to its members.



Monitoring and Reporting. The Company does not monitor or report on EHS issues within the warehouse operations in a formal manner. Senior management interviewed as part of the appraisal process, however, were aware of E&S issues as were individuals in positions of authority in the Ghana warehouse operations. For example, contractors used in the warehouse reported to these managers on OHS issues. Wienco is not featured on the Akoben website (an environmental performance rating and disclosure initiative of the Ghana EPA). Grower associations in Ghana and Liberia (e.g. CLA) use scalable geo referenced database programs (which now include GIS maps of cocoa farms as required under Rainforest Alliance and UTZ certification schemes) to receive, collate, monitor and evaluate operations. Data managed includes that pertaining to amounts of agricultural inputs, expected yields, repayment records, etc.

Human Resources Policy and Terms of Employment. The Company complies with the labor laws of Liberia. They have a Human Resources manual designed to inform staff about the Company and provide them with information about Company working conditions and terms of employment, including wages, employee benefits, working hours, leave and other policies affecting employment. Finalizing the document, and addressing observed gaps as described below, is addressed in the attached ESAP.



Wienco corporate HR is responsible for human resource matters for employees within the Ghana cotton grower association (which currently employs 170 individuals). Other associations have become autonomous in this respect. The grower associations strive to offer benefits to their members beyond those strictly related to increased productivity; for example, cocoa farmers will be eligible to join a pension scheme in the coming months.



Employee Organizations. Whereas no labor unions exist within the Wienco Liberia corporate operations, they are not precluded from doing so. Management at the Ghana cotton growing association has recently invited the union (General Agricultural Workers Union) to meet with them to discuss freedom of association. Farmers within that association are already organized under the same union. No similar initiative has been done with the growing associations in Liberia.



Grievance Mechanism and Non Discrimination and Equal Opportunity. The Wienco Liberia Conditions of Service manual does not contain specific provision for, or a description of, a grievance mechanism or a non discrimination and/or equal opportunity statement or procedure. The requirement to develop and implement both is addressed in the ESAP.



Retrenchment. It is not expected that major retrenchment will occur; termination procedures (on an individual basis) are included in the Liberia Conditions of Service manual.



Occupational Health and Safety. Hazards and risks associated with warehousing include those attributable to moving equipment (e.g. fork lift trucks) and inherent risks of the products themselves (particularly crop protection products). Wienco Liberia contracts out much of the movement of products (receipt and stacking of crop protection products and export of commodities, etc.) to a third party. These company workers operate forklifts and other equipment, the provision of which is included in the contract arrangement. As a practice, Wienco Liberia appoints service providers who have demonstrable and clear track records with other international companies. The contractor or service provider is required to provide to Wienco all applicable licenses and to prove that their staff is well trained and properly equipped. Regardless of who is conducting the work, there is a need for Wienco to provide adequate facilities within their premises; for example, provision of wash stations (required in the event of accidental spills or splashes on workers) was seen to be lacking at the
Ghana operations. Similar issues are also prevalent in the Liberia operations and are addressed in the ESAP.



Given the proposed construction of 6 warehouses in Liberia, Wienco must ensure that the occupational health and safety of those involved in the construction process is provided for and appropriately managed. For example, contracts issued to those building the structures must include requirements related to OHS of the contractors, their employees and any sub-contractors that may be required. Wienco should consider who within their management structure will oversee construction operations, what reporting on OHS performance must be undertaken, etc. in order to demonstrate compliance with applicable Liberian regulations and this Performance Standard. Measures to promote and provide adequate health and safety practices, procedures and equipment (such as that described in the WBG/IFC General EH&S Guidelines and internationally recognized codes of conduct regarding storage and distribution of pesticides) is addressed in the ESAP.



Of special interest at the supply chain level is the possible existence of worst forms of child labor and therefore the need to eradicate such. This has been identified and is the subject of several initiatives. For example, Cocoa Lela follows the Ascot Child Labor Framework which provides details of worst forms of child labor and permissible work for children of various ages, as defined by ILO conventions, in addition to helping stakeholders distinguish between the two. Farmers associated are also audited against the above criteria.

Pollution Prevention, Resource Conservation and Energy Efficiency. Warehouses are provided power from the national grid. When the power fails, backup generators are used to provide electricity (for offices and lighting). Such generators are very small in size (given the small power needs at the warehouses) and incorporate their own fuel supply. The Company is exploring options to install solar panels on the roofs of its warehouses to supply electrical power to the operations. Wienco Ghana is piloting the use of solar panels in one of their warehouses, if successful they plan to roll this initiative to Liberia.



Wastes and hazardous materials. The disposal of empty crop protection packaging is one of the main reputational risks associated with the Company operations. Whereas this is largely a result of customer behavior, and therefore beyond the direct control of the Company, Wienco Ghana and Liberia have initiated a management program to collect empty containers at locations close to their use and have them transported to Monrovia for proper disposal. The empty bottles will be transported to a company owned and operated incinerator in Côte d’Ivoire. This incinerator is licensed and operated according to relevant government regulations and is inspected annually by the appropriate government authorities; the company reports that all permits and licenses for transport and incineration are therefore in place and that the trans-boundary movement of the empty bottles is consistent with national, regional and international law, including, where appropriate, the Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and their Disposal. Solid wastes generated at main warehouses are very limited in nature and type; such wastes are disposed of through available municipal channels.



Emergency Preparedness. Emergencies that may arise are limited in scope and nature but may result in impacts to human health and the environment under certain circumstances, e.g. water from fire fighting activities containing pesticide wastes can enter surface waters. The Company has taken steps with regards to those that could occur, such as posting notices prohibiting smoking, regularly conducting fire drills (e.g. every quarter), provision of extinguishers and piping from on-site water storage, use of warehouses that are not adjacent to water bodies, etc.



Pesticide Use and Management. All Wienco crop protection products are quality products, supplied by recognized international companies. They have to be approved by relevant Liberian government agencies before been sold to farmers/customers. For example, the pesticides used for cocoa have to be approved by the Cocoa Research Institute of Liberia. A major pre-requisite to obtaining certification under UTZ and Rainforest Alliance is the proper application and management of crop protection products. Training on this aspect of farming is provided, and re-iterated by Wienco and Cocoa Lela promo
ters on a regular basis. Controls are in place; amongst other items, the records of amounts used must be kept, a proper knapsack sprayer must be used (the design of which makes it very difficult to be used by children), mist blowers must be well maintained so as to prevent improper spraying, waste containers must be brought to the warehouses and information on the prohibition of reuse and improper disposal is disseminated, proper storage must be utilized (the association provides agro-storage boxes to farmers), the requirement to wear protective equipment (provided to farmers) during application is emphasized as is its washing afterwards, and the requirement to use signs warning that application is taking place is made clear.



In addition to the above, Integrated Pest Management Program techniques are highlighted in the Wienco Liberia farmer manual (e.g. farm maintenance is promoted to include proper physical weeding and pruning (to reduce blackpod disease), cutting of mistletoe, twigs to be used against stem borers as well as having the proper number of shade trees (which can promote ant species to exist that can control capsids), etc.) so as promote only the minimum application of crop protection products as is necessary.

Security. Warehouse premises are secured (perimeter walls surround the buildings and guard booths are located at the gates and individual warehouse doors are locked when not in use) to prevent inadvertent or improper access. Wienco uses the services of recognized international security firms. Security guards in the Liberia operation are armed.



UTZ and Rainforest Alliance certification criteria include several requirements designed to protect community health from crop protection chemicals. As noted above, Wienco is planning to implement the same requirements as for their Ghana operations and ensure empty agro-chemical packages to be returned to the warehouses and that reuse of such is strictly prohibited. It is also required that chemicals are stored in a secure and locked place; unauthorized chemicals that farmers have come by (i.e. not supplied by Wienco) will be collected by promoters who are required to ensure appropriate disposal.



Consultation and Grievance Mechanism. Promoters act as the point of contact for members of Cocoa Lela regarding raising an issue or a complaint. The association conducts regular meetings and also convenes annual general meetings for all the associations’ members.

Sustainable Management of Living Natural Resources. Wienco supplies fertilizers and crop protection products (e.g., insecticides, fungicides and pesticides) to farmers and farmer organizations that grow cocoa. At present there is limited information on the areas Weinco will expand its operations. However, at present its key partner in Liberia is the farmer association Cocoa Lela. This association is implementing an environmental conservation plan aligned with the one implemented by Cocoa Abrabopa in Ghana. The first step under this conservation plan is to undertake a baseline assessment of biodiversity in the cocoa farmer area and design appropriate mitigation measures to address impacts. Cocoa Lela is in the process of drafting an environmental conservation plan for their farmers in Liberia. Cocoa Lela aims that all their farmers are both UTZ and Rainforest Alliance certified by their third year of membership. Farmers need to adopt and implement specific criteria required for these certification schemes including a prohibition on hunting or collecting of plants, animals and flowers, the requirement to plan and maintain sufficient setbacks from water courses (to prevent overspray of agro-chemicals or soil erosion) and a prohibition of farm encroachment upon forest reserves. As such farming activities taking place within Cocoa Lela have limited impacts with regards to living natural resources, at least as they pertain at present to cocoa farming. Working with Cocoa Lela can provide IFC greater assurance that Weinco activities are managed according to the objectives of this Performance Standard.

Given the nature and limited number of Company warehouses and the fact that the Company does not operate its own transport fleet, there is limited interface with communities. Regardless, the Company will develop a grievance mechanism that can receive and manage complaints from communities where it conducts business. It will publicize the existence of the mechanism. Operators of any contract transport, such as that bringing empty crop protection packaging back to Monrovia for proposer disposal, will be made aware of the grievance mechanism and that their activities will also be covered by it.

Samuel Oduro-Asare
Wienco Liberia Limited
PO Box 1998, 1000 Monrovia 10, Liberia
Cell phone: (+231)(0)880845440
mailto:s.asare@wiencoliberia.com
Website: http://www.wienco.com

Broad Community Support is not applicable for this project

Wienco Liberia(36357) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Plan, develop and implement an integrated Environmental and Social Management System (ESMS). Appoint suitably qualified person(s), or provide training to existing personnel to ensure the development, implementation and maintenance of an ESMS, commensurate with project risks, and consistent with IFC’s Performance Standard 1. The ESMS should be based upon project environmental, labor, occupational health and safety (OH&S), and community-related risks and impacts and be extended to include small holders, contractors (such as those involved in building warehouses) as appropriate. Risks and impacts can be identified from applicable regulations, permit conditions, IFC Performance Standards, WBG/IFC EHS Guidelines and recognized international industry codes of conduct, such as the FAO Code of Conduct on the Distribution and use of Pesticides, the Safe Warehousing of Crop Protection Products, etc. It may be integrated into the pending quality management system. The ESMS shall include provision of resources (qualified and competent staff, capital and operating budgets as applicable), ensure it is integrated throughout operations, and include training as needed to implement the program and its requirements, contain measures related to evaluation and monitoring of priority risks and impacts and reporting. Summary reports of annual activity should be integrated into the IFC Annual Monitoring Report (AMR).	31-Oct-2018	In progress	Due date revised as agreed with IFC Client
Finalize the Conditions of Service - HR Manual. Ensure that labor and working conditions, as included in the Conditions of Service manual meet Liberia local and national labor law as applicable (including for seasonal and temporary workers are provided for under law) and are responsive to all the requirements of IFC’s PS 2; publicize the existence of the manual and make it available to all those governed by its contents.	31-Jul-2018	In progress	Due date revised as agreed with IFC Client
Health and safety of workers handling agrochemicals. Wienco will provide evidence of the training of employees handling pesticides specifically in the use of adequate Personal Protection Equipment (PPE) based upon MSDS and/or ICSCs, and will fully integrate pest management procedures into the ESMS procedures manual.	31-Mar-2016	Completed	Completed	3/31/2015
Product safety and prevention of potential pollution due to accidental leakage throughout transportation and storage. Wieco will revise the OHS requirements for contractors (transport companies, warehouses) and distributors; incorporate requirements into the documents, where applicable, including availability of MSDSs for distributors.	31-Jul-2018	In progress	Due date revised as agreed with IFC Client
WHO Ia/Ib pesticide chemical formulations. As part of the ESMS, Wienco will provide to IFC a policy statement committing to no distribution of WHO Class Ia/Ib chemical formulations in Liberia.	31-Jul-2018	In progress	Due date revised as agreed with IFC Client
Formulate an integrated pest/disease management (IPM/IDM) program for pest management activities. Wienco will identify ways to promote the use of Integrated Pest/Disease Control Programs amongst its clients by developing and implementing integrated pest/disease management programs, making use of the Company’s own technical team or through the involvement of third party advisers. Wienco will ensure compliance with the Food and Agriculture Organization’s International Code of Conduct on the Distribution and Use of Pesticides, or to other good industry practice.	31-Jul-2018	In progress	Due date revised as agreed with IFC Client
Community Engagement/Grievance Mechanism Wienco will establish a formal community engagement /grievance mechanism; inform the community of this mechanism and the policies/procedures to address any community complaints going forward.	30-Jan-2015	Completed	Completed	1/31/2017
Adapt and adopt all relevant biodiversity and sustainable management elements of the Ghana Cocoa Abrabopa manual to the Liberia operation and audit against them Continue the implementation of all aspects of the Cocoa Abrabopa manual to the Liberia operations and audit against the criteria therein	31-Jul-2018	In progress	Due date revised as agreed with IFC Client