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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
Issues related to PS 3: Resource Efficiency and Pollution Prevention are not applicable as these are addressed via application of the management systems outlined in PS 1: Assessment and Management of Environmental and Social Risks and Impacts. Given the location of product loading and offloading i.e., at the terminals, allied to the transport of product by vessels at sea, PS 4: Community Health, Safety and Security is not considered applicable to the project. In addition, neither is PS5: Land Acquisition and Involuntary Resettlement given land based facilities associated with the project are already in existence. For this reason, neither does PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resource apply and PS8: Cultural Heritage. Further, there are no Indigenous Peoples located in the vicinity of the Djibouti terminal and thus PS7: Indigenous Peoples is not applicable.

This proposed investment has been categorized B according to IFC’s Policy on Environment and Social Sustainability as it involves activities with potentially limited adverse environmental or social risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures. The petroleum products will be transported by a major oil company which is well experienced in such activities and has suitable infrastructure and management systems to limit potential risks. Equally, the port infrastructure at Djibouti is considered adequate for the project activities and the port and the terminal operations have HSE management systems that are considered satisfactory to transfer and store the associated products. Key environmental and social risks and impacts are related to; i) application of effective management systems to limit the potential for environmental, health and safety impacts during product handling including effectiveness of emergency response plans and equipment and personnel to facilitate implementation; ii) provision of adequate infrastructure, including shipping vessels, during product storage and transport to limit the potential for incidents resulting in environmental and safety impacts; iii) labor and working conditions allied to occupational health and safety management; iv) management of solid and liquid wastes, and product emissions related to vessels and at the Djibouti port; v) effective security management at all operations; and vi) community safety as a result of incidents.

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

Vitol has rigorous HSE policies and procedures in place to ensure the company complies with all relevant national and international legislation and regulations. The policies and their implementation are overseen by a Compliance Committee, which reports directly to the Executive Management Committee. Subsidiaries and affiliates have specific HSE policies and procedures. Vitol’s joint venture, VTTI owns and operates terminals, storage tanks and pipelines in 14 countries. VTTI has a HSE policy covering operational auditing, emergency exercises, and safety council meetings. For country specific projects, Vitol, VTTI and their subsidiaries develop and implement comprehensive HSE procedures (emergency response, oil spill response management, occupational health and safety, etc.).

Vitol conducts on-going due diligence on a risk based approach of all its third parties using a third party supplier, this includes monitoring of internet based media and when necessary, updating all information required as part of the on-boarding process.



The shipper, one of the major international oil companies, will be responsible for the transport of the petroleum products to the Djibouti terminal, and is experienced in such activities with a clearly defined Integrity Management System (OIMS) defining relevant measures for addressing safety, security, health, environmental, and social risks. Lloyd’s Register Quality Assurance reviews ongoing performance and attests that the OIMS is consistent with the standard on environmental management systems of the International Organization for Standardization (ISO 14001:2004) and the Occupational Health and Safety Assessment Series for health and safety management systems (OHSAS 18001:2007). In doing so, such systems are aligned with this Performance Standard.



The terminal in Djibouti has a code of business conduct covering amongst other things aspects such as Team Work, Integrity, Transparency, Respect and Customer Focus, HSE standards and quality management). The terminal also has specific HSE and Personal Protective Equipment (PPE) policies that are clearly posted on the terminal premises. The HSE policy includes provisions related to risks management systems, training, emergencies, effective incident reporting, follow up and sharing of lessons learned, compliance with laws and regulations, provision of competent staff review and evaluation of operations to ensure compliance with the policies, minimization of waste and harmful emissions, energy efficiency and conservation of environmental resources; the policies are communicated to all staff.



The policies are supported by comprehensive HSE procedures related to environment management, risk assessment for tasks undertaken and use of PPE, waste management, incident management including a jetty oil response plan and an emergency plan. A full time HSE officer is employed at the terminal to ensure implementation of the policies and procedures defined above.



Mana
gement Programs

The tanks at the terminal were constructed in 2005 and the terminal aligns with the Aboveground Storage Tank Inspector Program of the American Petroleum Institute (API) that promotes safe storage and material handling of petroleum products in a manner that protects employees, the public, and the environment. This Program includes the specific requirement for an independent external inspection of the tanks by a qualified inspector every 5 years.



The terminal also has internal management programs to review tank structural safety, spill prevention precautions, fire safety and emergency preparedness and response, and occupational health and safety (OHS) at terminal operations. The inspection program for tanks include mechanical integrity, piping system, relief and vent valves, containment, emergency shutdown, etc. Standard operating procedures are also in place for filling tanks and for management of secondary containment.



Oil tankers are inspected according to the International Safety Guide for Oil Tankers and Terminals (ISGOTT) which includes inspection at the terminal where loading/offloading occurs. In addition, the oil tankers are required to comply with all applicable environmental standards of the International Maritime Organization (IMO). The characteristics of the oil tankers must be certified to the standards by an independent control specialist in the field and approved by the terminal manager. There are also routine inspections for spill/fire prevention at each jetty during unloading periods, including pipe connections, water pump readiness, fire source inspection, etc.



As with all terminals, the terminal in Djibouti also implements the Ship Inspection Report Program (SIRE). The SIRE system is a very large database of up-to-date information about tankers and barges. It focuses on tanker industry awareness on the importance of meeting satisfactory tanker quality and ship safety standards. The SIRE program requires a uniform inspection protocol that is applied to all operations.





Emergency Preparedness and Response



The terminal has emergency preparedness and response plans in place which are supported by the local fire department. In addition, there is sufficient equipment to support fire prevention and associated emergency response plans at the terminal complies with the United States National Fire Protection Association (NFPA) standards.



The Marine Environmental, Safety, and Quality Assurance Criteria for Industry Vessels of the oil company transporting the petroleum products has provisions for emergency procedures in all vessels that address differing emergency scenarios (negative stability, chemical spill and pollution, escape of cargo, vessel casualty, collision, grounding, fire and explosion, gas releases). It also contains considerations related to personnel assignments in case of emergency.

Human Resources Policies and Procedures



Vitol has some 1,200 employees located in the 4 core offices (Geneva, Houston, London and Singapore) with 34% being women. While the company does not have a Social Policy Statement, human resource (HR) objectives are addressed in the HSE Policy Statement. Based on discussions with Vitol’s Head of HR, there are procedures related to collective bargaining, workers’ rights to join unions, and election of workers representatives; these procedures appear to be in line with best practice.



There are some 100 employees at the terminal and there is a HR Manual which defines entitlement to leave for holidays, vacation, illness and maternity, which is in compliance with the national laws. Employees have the right to form and join employee organizations of their choosing and to bargain collectively with the company. Based on the information made available to IFC, the approach to working conditions is generally aligned with this PS.



The shipper transporting the petroleum products applies best practice to human resource management and associated working conditions.



Occupational Health and Safety



The terminal has management programs for occupational health and safety (OHS) of terminal operations with a clearly defined organization structure to support such along with training requirements. There are also adequate facilities to provide medical support to employees.



The shipper applies Marine Environmental, Safety, and Quality Assurance Criteria for Industry Vessels transporting the petroleum products, and has provisions on crew and safety management and procedures to manage specific tasks and associated OHS requirements.

There has been no specific stakeholder engagement undertaken as part of this project and given the nature thereof.

For further information contact the following Vitol representative:
Vitol Bahrain E.C. (“Vitol”)
Bahrain World Trade Centre
West Tower
Building 1B, Isa Al Kabeer Avenue
Manama Centre
Bahrain
email : mailto:enquiry@Vitol.com
Tel:
In any correspondence pleas quote: IFC EAF

Broad Community Support is not applicable for this project