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 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
PS5: Land Acquisition and Involuntary Resettlement does not apply to the current investment as none of the companies’ Poultry operations have and/or will trigger involuntary resettlement and/or economic displacement. All of the land required for the companies’ operations is acquired through a willing buyer/ willing seller process through a negotiation process with villages’ farmer committee. Presence of Indigenous People (PS7) and Cultural Heritage (PS8) has not been identified in the existing footprint of the companies’ operations. In the event that issues anticipated by these PSs arise, the companies’ will promptly inform IFC. Screening and assessment of these issues against Performance Standards requirements will be done through each operation’s environmental and social management system (ESMS) to be developed as part of the project.

The proposed investment is expected to have limited environmental and social impacts which are site-specific, temporary and none is expected to be significant. Those impacts can be avoided or mitigated by adhering to applicable performance standards, procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. This categorization is consistent with categorization of other similar projects within this sub-sector. The project is designed to avoid, minimize and manage environmental and social risks and impacts of the Company’s operations in compliance with local legal and regulatory requirements, applicable IFC Performance Standards and World Bank Group (WBG) General and sector-specific (Poultry production) Environmental, Health and Safety (EHS) Guidelines. Key E&S issues applicable to this investment are: (i) obtaining operational licenses for the companies facilities; (ii) appropriate environmental, including bio-security and disease prevention, OHS, and social management system development and its effective implementation; (iii) adherence to Malagasy labor law, terms of employment and working/living conditions for farm workers, including at contracted farms; (iv) Life and Fire Safety (L&FS) provisions and emergency preparedness and response procedures, including those related to avian flu; (v) prudent and efficient use of public utilities (water supply and energy), optimization of water and energy use through design and resource conservation measures,; (vi) management of wastewater and solid wastes, provision of potable water, and its treatment and monitoring, appropriate hazardous material handling, management and control of pests and rodents; and, (vii) engagement with communities commensurate to their exposure to potential E&S risks.

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/Audit. In Madagascar, any public or private investment project that is likely to affect the environment issubject to an Environmental Impact Assessment in accordance with the environmental and social regulations of the country. The ESIA undertaken identified the risks and impacts of the companies’ operations on the biophysical environment. In addition, stakeholder engagement was also undertaken as part of the study. Environmental Management Plan (EMP) was proposed to manage the risks and impacts identified for the construction (Mabel) and operational phases of the project. However, issues related to supply chain assessment were not addressed in the ESIA and these have been addressed in the ESAP. In addition to the ESIA approval, the operator of the project must apply for Authorization of Operation from the Ministry of Industry who provides building permits to begin construction. As part of its licensing process, the companies is required to obtain its operational license on an ongoing basis. The underlying licensing process includes preparation of technical file, inspection visits by sector ministries, identification, and subsequent implementation of, corrective EHS actions.

Management Program. The companies (Agrival, Agrifarm and Mabel) have not yet adopted all the elements of an environmental, OHS, food safety and social management system as are required by PS1. However, the companies have taken tangible and positive steps in order to establish solid foundations for such a system. In particular, despite there being no formal slaughterhouse in the country, Agrifarm is currently in the process of implementing ISO 9001: 2015 and Mabel has made a commitment to ensure that the abattoir will be ISO 22000 and HACCP certified once operational. Though there is no integrated EHS system in place, Agrifarm’s current operation includes a quality control and biosecurity protocol, which defines sanitary and hygiene management procedures for ensuring quality of inputs, working areas, staff, and the overall production process. No third-party audit has yet taken place for certification based on the above mentioned procedures. Specifically, preventive vaccination programs, for among others, Newcastle and bronchitis for one day chick, training of personnel and traceability system are conducted. With the expansion of the hatching unit under the proposed Project, Agrifarm is committed to achieve ISO 22000 certifications by end of 2018. In October 2014, the Agrival feed mill production obtained its ISO9001-2008 certification. Agrival and Agrifarm have also established a laboratory for analysis and quality control. Going forward, as set forth in the attached Environmental and Social Action Plan (ESAP), the companies’ management has agreed to further develop and integrate these Environmental, Occupational Health and Safety (EHS) and food safety management system elements – in line with ISO 14001, OHSAS 18001 and HACCP/ISO 2200
1 – into an Integrated Management System which will therefore comply with IFC’s PS1 requirements including applicable WBG General and Sector-Specific Environmental, Health and Safety (EHS) Guidelines. The SEMS will encompass all the companies’ poultry facilities and will include an overarching policy as well as detailed procedures that will be implemented to ensure practices comply with the aforementioned requirements. In particular, certification of ISO 22000 provides assurance that food products placed into commerce are safe and, in the event of a report of adulterated food products, the Company can identify affected lot numbers and remove the products quickly. Completion of the Integrated EHS Management and certification of Mabel facilities with HACCP expected by end of 2016 and ISO 22000 is expected by end of 2017. Organization. The companies’ have not yet assigned an EHS officer or established a corporate E&S unit with managerial responsibilities, accountable to senior management, and with assigned responsibilities to support supervisors in all the companies facilities. For the time being, the General Manager of Agrival, Agrifarm and Mabel, assisted by quality officers are jointly contributing to EHS responsibilities but corporate coordination and accountabilities are deficient. As part of its expansion plan, and as spelt out in the ESAP, the companies will establish a corporate E&S unit and strengthen its EHS compliance through the recruitment of a full-time and qualified E&S officer whose key responsibilities will encompass the coordination of the preparation and implementation of the Integrated EHS management systems, and supportive procedures manual. This officer will ensure the preparation of the technical file for obtaining the annual operational license at all facilities, including retail outlets, implementation of related corrective actions plans, continuous training of the companies’ employees on EHS issues, coordination of technical and financial proposals for required cleaner production measures at all plants (e.g. wastewater treatment plant in Mabel), support the coordination of the companies’ Occupational Health and Safety Committee, and ensure the monitoring and reporting on resource efficiency, through EHS key performance indicators (KPI)s for continuous improvement of E&S performance. This EHS officer will report to the companies’ Managing Director and will closely coordinate his/her works with the companies’ operational directors and quality officers. Training. The companies adopted a corporate training procedure to ensure continuous OHS and biosecurity trainings for its existing poultry operations, to staff at all levels in the business entities in order to improve operational efficiencies. As it relates specifically to EHS issues, specialized training has been provided over the last two years for Agrival and Agrifarm staff on good hygiene practices and food safety, including independent review of current cleaning prac
tices and deficiencies. In 2016, the main focus of the staff training in Mabel will be concentrated on HACCP and ISO 22000 requirements to support the companies’ commitment to achieve certification in 2016 and 2017 respectively. In addition, the companies are required by regulation to train their employees on L&FS, including 1st and 2nd level intervention and first aid. The objectives of this training are to prevent fire hazards and to learn how to control fire event should that be necessary. As set forth in the ESAP, as part of the Integrated EHS management system, the HR Director and the EHS officer will undertake a comprehensive training needs assessment of the companies’ employees to complement this existing training program. The companies already recognize the importance of strengthening the technical capacities of its employees in order to improve regulatory compliance and E&S performance and, ultimately, increase career mobility. This was reiterated by senior management and contained in staff training policy. The HR Director will be responsible to coordinate the effective delivery of the training plan. Monitoring and reporting. The companies are presently not comprehensively monitoring or reporting on its EHS performance. Currently, each technical manager responsible for the companies’ operations, assisted by quality officers, and the Director of Human Resources for OHS issues, collect and maintain statistics on key EHS indicators (resource consumption, OHS incidents, etc.). These, however, are not centrally compiled or used to their fullest in order to inform the license renewal process, investment strategy and/or the above mentioned training program. Efforts related to the operational license process, are centered on technical inspectors from sector departments investigating EHS performance of the companies’ operations and providing corrective action plans. In addition, commercial customers are also undertaking their own independent assessment of the companies’ operations and products. These assessments and market competition recognize the continuous and positive improvement of the companies’ management in its production process. Key recommendations proposed include the need to develop a Quality/HACCP manual. As set forth in the ESAP, the companies’ EHS officer will report on key EHS performance indicators, including food safety, energy and water consumption and efficiency; air emissions (NOx, SOx, particulates and GHG emissions); noise; solid and hazardous waste management and disposal; effluent discharges from the wastewater treatment plant; compliance with OHS mitigation measures; accident rates (lost-time incidents); customer complaints; supplier performance; and community engagement activities. The companies will report annually to Malagasy authorities and to IFC as part of the Annual Monitoring Report (AMR). Community engagement. For biosafety reasons, the proposed Mabel facility is isolated from communities, located in a rura
l area. The Agrival and the Agrifarm hatchery located in the SMTP Groupe head office is surrounded by commercial and residential areas with proper biosecurity measures. The Ambohimahavelona and Ambarimakaka farms are located in peri-urban farm land.



Based on the ESIA main E&S concerns from surrounding communities include traffic, solid waste management and disposal, odor, noise and air emissions. The companies will define a Stakeholder Engagement Plan, manage external communications through the use of a community grievance mechanism, and where necessary, report on performance commensurate to the issues raised. as indicated in the attached ESAP

PS2: Labor and Working ConditionsHuman Resources (HR) Policy and Management. As of April 2015, SMTP reports a total of 1200 permanent employees; employment is split 75/25 male and female. In addition, during the maize harvest season, day laborers are utilized. Of the 1200 employees, more than 80% are assigned to production, technical support, processing and logistical activities while the remainder is dedicated to administrative functions (e.g. managerial, commercial, marketing, transit, procurement). With the proposed expansion of the poultry production, it is estimated that 200 permanent jobs will be added to the payroll. The Human Resource Department comprises a Manager and three assistants. This Department is responsible for the development and implementation of a standard set of labor procedures (Internal Regulation), that govern the following actions: recruitment and selection; admissions process and documentation; planning and approval of holidays and time off; attendance and working hours; payment processing, including health insurance and benefits; performance evaluation; training; access to the employee grievance mechanism; and, disciplinary measures and cessation of employment. The Internal Regulations are communicated to all new employees during the induction process and a signed acknowledgement of receipt from each employee is requested. The Internal Regulation will be reviewed and updated in order to meet all the necessary requirements as spelled out in IFC’s Performance Standard 2, especially at it relates to formalizing the training plan, including OHS provision based on job risk assessment, freedom of association, and the grievance mechanism. The Internal Regulation is in compliance with Malagasy Labor Code (“Code du Travail”), including non-discrimination and equal opportunity. The minimum age of employment in the companies is 18 years old and no forced labor is undertaken in the companies.



The companies do not currently undertake a process of assessing their supply chain and the related labour practices in this area. Farming practices in Madagascar essentially involve manual labor supplemented with very limited and rudimentary farming equipment (spades, pitchforks etc.). Publicly available literature (ILO; UNICEF; US department of Labour; and other advocacy groups) and evidence on ground shows that there is growing concern in the country about harmful/worst forms of child labour in the agricultural industry, particularly associated with growing rice and maize. As set forth in the ESAP, the companies will therefore introduce pertinent sections in contracts to address this and other issues; provisions will specify expected behaviors and will contribute to contractors and sub-contractors being in compliance with payment of workers’ legal benefits, timely payment of wages, OHS regulations, including use of personal protective equipment (PPE) and ILO Conventions 138 on Minimum Age. Further, the companies will contractually en
sure and monitor the compliance of service providers, cooperatives and suppliers to ensure minimum age employment requirements are met. Through its EHS officer, the companies will develop and provide suppliers with an OHS manual reflecting its own OHS requirements and will include reference to such requirements in contract documents. In addition to salaries, other benefits are provided, including: health coverage, performance and sale bonuses. The companies’ salary scale is above the minimum threshold in Madagascar. Changing rooms, toilets and showers facilities are available for workers and respect gender sensitivities. As set forth in the ESAP, the companies will develop and implement a structured grievance procedure for its workers, in accordance with PS2 requirements, including steps to be taken for workers to manifest any concern, engage in a mediation process, contact responsible persons at each facility, and provide feedback. Employees’ awareness raising on grievance mechanism procedure will take place during the worker’s induction session. Workers’ Organization. The companies’ labor hiring practices are conducted in accordance with the Malagasy labor law. The recruiting process at the companies involves a background check of qualifications, professional experience and a medical test (general health tests – eyes; weight; blood pressure; Staff age id validated though a birth certificate and national identification card. The companies’ supports the freedom of association of its workers and with 6 of its staff as members of the SEKRIMA labour union.Occupational Health and Safety. Numerous operations sites at the companies require a robust and active occupational health and safety management system to be developed and implemented. This is noted above and the need to develop and implement an OH&S management system based upon OHSAS 18001 addressed in the ESAP under PS 1, Management Programs.



Biosafety and avian influenza preparedness and response. As part of its operational procedures in Agrifarm, a bio-safety protocol has been adopted which includes strict measures to (i) improve and monitor poultry hygiene and health according to the risk and occurrence of diseases during the production process, (ii) establish a traceability system, (iii) ensure poultry products quality for customers. Standardized sanitation and disinfection procedures exist and their use is systematically enforced at all the companies own poultry rearing units, and at associated poultry producers. Bio-safety procedures include limited controlled site access and suitable infrastructures (e.g. high fences); entrance gate with vehicle disinfection area, cleaning and disinfection procedures for visitors, materials and tools (e.g. foot disinfection at the entrance to sites/houses), control of pathogen vectors (rodents, insects), and organic waste management. Workers’ clothes are kept clean, shoes are scrubbed with disinfectant, and hands are washed. As part of its bio-sa
fety procedures, any sick or dead bird is removed and reported to the veterinarian. Given the potential magnitude and unprecedented nature of the threat posed by avian influenza and to protect its workforce, the companies will develop and implement a management system procedure for the avian influenza preparedness and response, including a training plan to ensure that employees are knowledgeable of the preparedness plan for avian influenza and emergency contingency plans. The plan will include: (i) preparedness and prevention, (ii) outbreak response, and (iii) recovery.



Life and fire safety. The companies’ poultry operations are associated with fire and explosion risks. During the establishment of the poultry facilities, fire/explosion hazard is addressed during the EIA process. Extinguishers are installed in every warehouse at farm level. Life and fire response teams are being established at all sites and training provided to all workers. The due diligence has identified additional areas where some aspects of the fire protection are deficient (e.g. visible means of egress, emergency lighting and exit signs, fire detection and alarm systems). In order to consolidate measures to prevent fires and protect life and company assets, as indicated in the ESAP, the companies will develop and implement a measures in accordance with WBG EHS requirements.

As part of the development and implementation of its integrated EHS management system and program under PS1, the companies will prepare plans and procedures for the management of energy, potable water, liquid and solid waste, greenhouse gases (GHG) emissions and any other key environmental aspects. The plans will include production’s reduction targets for resource use to be monitored annually and proposed recommendations (e.g. installment of water meters, re-use of chicken litter as boiler fuel, generation of methane by anaerobic bio-digesters from slaughtering wastes, etc.).Hatchery facility (Agrifarm). This facility, situated in Ambohibao, includes a combination of incubator and hatchery equipment which are equipped with measures to ensure optimum temperature range and under pathogen free conditions.Once hatched, one-day old chick are vaccinated and sent to the poultry rearing facilities in temperature regulated transport. Wastes from hatchery include broken eggs, chick embryo and eggs shell. These are stored in specific container and transported to a landfill while unhatched eggs are donated to a crocodile farm. Poultry parent-stock farms. These facilities are as isolated as possible for bio-security reasons. E&S impacts from these facilities are minor. The companies have developed SOPs, including standard production and bio-security measures, to avoid or mitigate adverse impacts. Technology package dissemination is under the supervision of a veterinarian, and is supported by farm managers and workers. The companies will ensure that poultry rearing practices aligns with IFC’s Good Practice Note (GPN) on Animal Welfare. Broiler chickens of 35-42 days are transported to Ambarimakaka. The companies will need to ensure that bird transportation is undertaken under a distressed-free environment in compliance with IFC’s GPN on Animal Welfare. Water analysis and consumption from wells is not monitored at associated farm level. As set forth in the ESAP, the companies will conduct a full chemical, physical and microbiological assessment of groundwater in all wells and establish quality and consumption baseline for on-going monitoring purposes. If annual assessment indicates deterioration, the companies will take mitigation action. Feed mill facility (Agrival). The feed mill plant has a capacity of 50,000 tons/year. Key processes include storage silos, conveyors and elevators, screening, sorting, batching machines, milling machines, mixer, dryers and packaging machine. Water consumption is 4m³/day and sourced from boreholes.

Poultry processing plant (Mabel). The meat processing and slaughterhouse is currently not yet in operation. Processing operations will be required to be conducted within good OHS and food safety practices, respecting animal welfare. In addition training will be provided to employees on food safety and quality management practices. All equipment is expected to be automated, except for few manually assisted operations, such as
evisceration, packing and storing. Proposed Mabel’s processing capacity is 100,000 chickens/ week. Water will be sourced from river Ikopa and will be treated through clarification and disinfection before use. Wastewater will be treated before being discharges into the river; treatment will ensure compliance with Malagasy treated effluent maximum levels and the WBG EHS guidelines for poultry processing. 

Mabel will commission appropriately qualified experts to study opportunities to reduce effluent loading through cleaner production techniques, and also to minimize water consumption and hence discharge. Effluent volume and contamination will be minimized. Mabel will recruit an expert consultancy firm to conduct an engineering design study for the construction and operation of a wastewater treatment plant whose performance shall meet all effluents parameters found in Table 1 of the WBG EHS Guidelines for poultry processing. As indicated in the ESAP, this study is required to be completed within a few months of commitment or prior to commitment while the commissioning of the WWT plant will be required prior to the commencement of slaughtering operations.

Energy use and greenhouse emissions. As set forth in the ESAP, the companies will implement an energy management plan to improve use efficiency, through data collection, energy consumption/management reports and reduction targets. Specifically, Mabel will ensure design measures maximize energy efficiency in the slaughter house operation.



Odor. As part of its ESMS, the companies will implement measures to manage odour from its poultry facilities.Air emissions monitoring. The main source of air emissions are from the boilers at Agrival. Both boilers with combined heat input of approximately 2 million Btu/hr and generators undergo regular maintenance inspection to optimize efficiency. The combined heat input is a lower threshold for the applicability of the WBG EHS guidelines. . Management of solid & hazardous waste. Waste characterization of the companies’ operations are composed of the following: 1) Agrifarm - 90% of broken eggs, chicken embryo and egg shell which are donated and disposed-off to the Tana landfill site; deep bedding materials at rearing facilities composed of wood chips, rice husks, saw dust and chicken droppings which are either given or sold as fertilizer in horticulture and banana; empty vaccine bottles which are disinfected and then burnt; and plastic bottles which are recycled. Dead chicken carcass are daily buried at site in a covered earth as authorized in the ESIA; 2) Agrival has limited process waste. The waste stream (paper, cardboard, on-site food services and maintenance waste) are resold for recycling; 3) Mabel: waste characterized by birds intestines/feather and dead birds or rotten meats. According to the Mabel ESIA, proposed practices for carcass handling involves processing in a rendering plant and cooking under high temperature and pressure (164°C and 0.7
MPa) until it is decomposed into powder meat and bone meal to be incorporated in a feed mill for fish feed. The companies will be required to implement carcass management and disposal arrangements such that bird carcasses are first categorized into either low risk or high risk materials and not simply recycled into animal feed as proposed in the Mabel ESIA. Low risk and high risk bird carcasses will ensure compliance with the WBG EHS guidelines for Poultry processing. Hazardous materials present in the companies’ facilities are limited and include cleaning/disinfection products, veterinarian products for prevention and control of poultry disease. As set forth in the ESAP, the companies will develop a management system procedure to ensure that all solid and hazardous wastes are collected and disposed in accordance with Malagasy and WBG waste management guidelines and the mammalian livestock production EHS guidelines. Pest management and control. A legally registered company conducts rodent control in all the companies’ operations, including poultry rearing units and feed mill plant. This will also be applied to the slaughter plant too. Activities include inspection and maintenance; and rodent and pest are controlled and monitored constantly. Products for rodent control used are listed under WHO Class 1a and 1b chemical formulations. The companies will prepare a management system procedure to implement pest and rodent management. The procedure will eliminate the use of WHO Class 1a and 1b chemical formulations in their premises. The companies will modify service contracts to require contractors and suppliers for mandatory training to workers and ensure provision of adequate PPE based upon MSDS and/or ICSCs for the materials used. This consideration will be added in employee’s OHS training programs

Community Health and Safety. As Agrifarm’s farming operations are isolated from human settlements for bio-security measures, traffic does not represent a significant risk for the local population. However, as poultry operations will be ongoing during construction of Mabel site, Mabel will be required to manage traffic during construction. The companies will be required to implement Operator Safety Training Program for its drivers and contractors. As set forth in the ESAP, Transport sub-contractors will be requested to produce a validated driver license, insurance and vehicle maintenance report.



Biosecurity: The Mabel meat processing plant will include bio-safety measures (installation of sanitation barriers upon entries and exits with non-contact hand washing, sanitizing equipment in all processing rooms, and improved refrigeration equipment). For its operations Mabel will ensure that drug residues in poultry products meet the maximum residue limits (MRLs) recommended by WHO and FAO.



Emergency Preparedness and Response. The companies have not yet adopted emergency preparedness and response protocols, procedures and plans for all its facilities. The emergency plans respond to the needs of life and fire safety. The companies will submit its consolidated plan for all its production and retail outlets to IFC in order to ensure compliance with WBG EHS requirements. It will develop and implement emergency preparedness and response plans for all its facilities. Emergency plans will respond to the needs of life and fire safety requirements and include training on emergency evacuation, use of fire equipment, and other applicable aspects identified by experienced emergency planning specialists in the planning process. It will implement a training plan to ensure that all employees are knowledgeable of existing emergency procedures and emergency contingency plans, including evacuation routes. It will perform fire drills in all operating facilities. Community Grievance Mechanism. As mentioned under PS1, Stakeholder Engagement Plan, the companies will develop a community grievance mechanism in order to strengthen its consultation and responsiveness with any potential communities’ grievances on the E&S risks associated with its operations. Security Personnel. Security personal at farm operations is part of the companies’ staff. The security officers are not armed and are trained for defensive measures. They are also trained on life and fire safety, including active involvement in regular fire drills, emergency preparedness and response, first aid, etc.

Supply Chain. Agrival raw materials are predominantly locally grown maize, soya bean, wheat bran and rice. These materials are purchased by the companies through local farmers which are predominantly family farms. Maize is locally sourced mostly from the central highlands and southern regions of Madagascar from approximately 2,000 small farmers from all over the country. The risk of deforestation and habitat modification associated with maize production is high in Madagascar. At present, the companies do not have management control over the farms from which it sources grains and are not able to ascertain that they do not encroach on areas of significance for biodiversity protection. The companies are required to map their supply chain in order to evaluate their primary suppliers. This will include identifying where the supply is coming from and the habitat type of the area; ongoing review of its primary supply chains; limit procurement to client that can demonstrate that they are not contributing to significant conversion of natural or critical habitat. The companies will be required to assess and manage the environmental and social risks of its agro-commodity supply chain using traceability and screening schemes.

Sustainable Management of Living Natural Resources. The companies will ensure commitment to applying good international industry operating principles and management practices to its animal husbandry practices. The companies will ensure that poultry rearing practices aligns with IFC’s Good Practice Note (GPN) on Animal Welfare.

The companies have not yet established a structured stakeholder engagement program with affected stakeholders. This being said, the companies, through their farms in remote rural areas, are creating positive employment opportunities for neighboring communities

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. The companies will be requested to place an advertisement in local newspapers near their facilities as well as on their website to inform of the results of IFC’s environmental and social review and ESAP’s corrective action items. Name/Address: Mr. Danilhoussen Ismael, Executive President Groupe SMTP. Lot 01 A Ambohibao
Antananarivo
Madagascar
Tel : +261 32 07 845 80; E-mail : mailto:ismaeld@groupe-smtp.comWeb site : http://www.groupe-smtp.com

Broad Community Support is not applicable for this project

SMTP Madagascar(36704) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
SMTP will appoint a qualified EHS officer who will be responsible for implementing the ESMS and fulfilling the ESAP conditions. This officer will report to SMTP’s Managing Director.	31-Mar-2016	Completed	Completed	5/1/2018
SMTP will design and implement an Environmental and Social Management System (ESMS) – consistent with ISO 14001, OHSAS 18001 and HACCP/ISO 22001 - to be reviewed and approved by IFC, defining roles and responsibilities, and other necessary elements (manuals, procedures etc.) to enable it to comply with Malagasy laws and regulations, IFC Performance Standards and applicable WBG Environmental, Health and Safety Guidelines.	30-Jun-2016	Completed	Completed	6/30/2016
The ESMS will include mechanisms for the EHS officer to report monthly E&S monitoring results to SMTP’s senior management who will need to sign off on the reports.	30-Jun-2016	Completed	Completed	6/30/2018
SMTP will design and implement an Environmental and Social Management System (ESMS) – consistent with ISO 14001, OHSAS 18001 and HACCP/ISO 22001 - to be reviewed and approved by IFC, defining roles and responsibilities, and other necessary elements (manuals, procedures etc.) to enable it to comply with Malagasy laws and regulations, IFC Performance Standards and applicable WBG Environmental, Health and Safety Guidelines.	31-Dec-2016	Completed	Completed	6/30/2016
Mabel will obtain certification for HACCP and ISO 22000 will address any corrective actions that arise from the certification process.	15-Dec-2018	In progress	Due date revised as agreed with IFC Client
Mabel will obtain certification for HACCP and ISO 22000 will address any corrective actions that arise from the certification process.	31-Dec-2018	In progress	Due date revised as agreed with IFC Client
Mabel will obtain certification for HACCP and ISO 22000 will address any corrective actions that arise from the certification process.	31-Dec-2018	In progress	In progress
Agrifarm will achieve ISO 9001 certification	31-Dec-2016	In progress	Under discussion with IFC Client
Agrifarm will achieve ISO 22000 certification.	31-Dec-2018	In progress	In progress
SMTP will prepare and implement a training program for all its employees and contractors which will encompass all the key issues identified in the above mentioned ESMS, with a specific emphasis on the Integrated EHS Management system, including resource efficiency, OHS, Life and Fire Safety and Emergency Preparedness and Response Plans.	31-Dec-2016	Completed	Completed	6/30/2016
SMTP will formalize the development of its Stakeholder Engagement Plan (SEP). The SEP will include a mechanism for receiving, addressing and resolving community grievances and complaints during the operational phase at all facilities. The content of this procedure shall be guided by IFC’s Good Practice Note on Stakeholder Engagement.	30-Jun-2016	Completed	Completed	6/30/2016
SMTP to review and update its corporate Human Resource Policy and labor contracting specifications in compliance with labor laws and regulations in Madagascar and all the requirements defined in IFC’s Performance Standard 2.	30-Jun-2016	In progress	Under discussion with IFC Client
Specifically, this policy will include references to freedom of association and collective bargaining, prohibition of child and forced labor and grievance mechanisms.	31-Mar-2016	In progress	Under discussion with IFC Client
The Employee Grievance Mechanism will be disseminated to both permanent and contract employees as part of the induction process and will be posted on SMTP’s internal website	30-Jun-2016	In progress	Under discussion with IFC Client
SMTP will prepare a robust management system on OHS, including action plan detailing corrective measures (training, Personal Protection Equipment, assignment of responsibilities, recommendations from the CHSCT and the CNPS, etc.), implementation schedule and budgetary resources for effective and timely implementation.	30-Jun-2016	Completed	Completed	8/15/2016
SMTP will prepare a robust management system on OHS, including action plan detailing corrective measures (training, Personal Protection Equipment, assignment of responsibilities, recommendations from the CHSCT and the CNPS, etc.), implementation schedule and budgetary resources for effective and timely implementation.	30-Sep-2016	Completed	Completed	8/15/2016
In addition, SMTP will integrate OHS sections in contracts in order to ensure that contractors’ and sub-contractors’ employees are in compliance with all the requirements described in SMTP’s OHS Policy and IFC’s Performance Standard 2. SMTP will also develop and provide service contracting firms with a manual that includes OHS requirements of SMTP and will include reference to such requirements in the service contract documents	30-Jun-2016	In progress	Under discussion with IFC Client
In addition, SMTP will integrate OHS sections in contracts in order to ensure that contractors’ and sub-contractors’ employees are in compliance with all the requirements described in SMTP’s OHS Policy and IFC’s Performance Standard 2. SMTP will also develop and provide service contracting firms with a manual that includes OHS requirements of SMTP and will include reference to such requirements in the service contract documents	30-Sep-2016	In progress	Under discussion with IFC Client
Life and Fire Safety (LFS). SMTP will develop and implement a management system procedure and an action plan for fire prevention, detection and alarm system in all its facilities. Emergency lighting, exit signs, mean of egress will be included in the Mabel LFS design.	31-Mar-2016	In progress	Under discussion with IFC Client
SMTP will recruit a LFS specialist to perform LFS Audit of all SMTP facilities against the Malagasy life safety code and the WBG EHS guidelines.	30-Jun-2016	In progress	Under discussion with IFC Client
SMTP will have regular L&FS training and drills according to the emergency preparedness plan	30-Jun-2016	In progress	Under discussion with IFC Client
SMTP will develop and implement a management system procedure for the avian influenza preparedness and response, including a training plan to ensure that employees are knowledgeable of the preparedness plan for avian influenza and emergency contingency plans. The plan will include: (i) preparedness and prevention, (ii) outbreak response, and (iii) recovery	31-Dec-2016	In progress	Under discussion with IFC Client
SMTP will design and construct a Waste Water Treatment unit for its slaughtering processing unit (Mabel) in compliance with Malagasy and applicable WBGs effluents guidelines, especially for pH, BOD, COD, total suspended Solids, Grease, total nitrogen and total phosphorus.	31-Mar-2016	In progress	Under discussion with IFC Client
SMTP will design and construct a Waste Water Treatment unit for its slaughtering processing unit (Mabel) in compliance with Malagasy and applicable WBGs effluents guidelines, especially for pH, BOD, COD, total suspended Solids, Grease, total nitrogen and total phosphorus.	30-Jun-2016	In progress	Under discussion with IFC Client
SMTP will establish a comprehensive chemical, physical and micro-biological assessment of groundwater in all wells and establish a quality, consumption and a resource efficiency baseline. If there is any water quality deterioration, SMTP will take specific action to mitigate the situation.	31-Mar-2016	In progress	Under discussion with IFC Client
SMTP will implement an energy management plan for all its operations. In order to support development of this plan, SMTP will systematically collect key energy indicators, including electricity and diesel quantities used during the year, reductions from previous years, activities (energy audit) undertaken to reduce energy use and efforts to motivate employees, etc.	30-Jun-2016	In progress	Under discussion with IFC Client
SMTP will develop and implement a Pest and Rodent management system procedure. The procedure will to eliminate the use of WHO Class 1a and 1b chemical formulations in its facilities. SMTP will modify service contracts to require service providers mandatory training of its workers and adequate PPE based upon MSDS and/or ICSCs for the materials used.	30-Jun-2016	Completed	Completed	8/15/2016
SMTP will develop and implement a vehicle Operator Safety Training Program for its drivers and contractors emphasizing the following: safety aspects among drivers, improving driver skills, licensing of drivers, limits for trip duration, duty roster to avoid overtiredness, avoiding dangerous routes and times of day to reduce the risks of accidents, use of speed control devices on vehicles; and, remote monitoring of driver actions, behavior and performance and overall truck maintenance	30-Jun-2016	Completed	Completed	8/15/2016
SMTP will conduct studies to confirm that drug residues in poultry products meet the maximum residue limits (MRLs) recommended by WHO and FAO; and will undertake corrective actions, if needed , to comply with MRLs.	31-Mar-2016	Completed	Completed	12/28/2016
SMTP will develop and implement systems and verification practices as part of its ESMS to evaluate its primary suppliers to manage the risk of significant conversion of natural and or critical habitats for its operations. The process will ensure procurement is limited to suppliers that can demonstrate that they are not contributing to significant conversion of natural resources	15-Dec-2018	In progress	Due date revised as agreed with IFC Client
SMTP will develop and implement systems and verification practices as part of its ESMS to evaluate its primary suppliers to manage the risk of significant conversion of natural and or critical habitats for its operations. The process will ensure procurement is limited to suppliers that can demonstrate that they are not contributing to significant conversion of natural resources	15-Dec-2018	In progress	Due date revised as agreed with IFC Client
SMTP will develop and implement systems and verification practices as part of its ESMS to evaluate its primary suppliers to manage the risk of significant conversion of natural and or critical habitats for its operations. The process will ensure procurement is limited to suppliers that can demonstrate that they are not contributing to significant conversion of natural resources	15-Dec-2018	In progress	Due date revised as agreed with IFC Client