This proposed investment is anticipated to have limited environmental and social impacts which are expected to be site-specific and insignificant. These impacts can be avoided or mitigated by adhering to recognized 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 (January 1st, 2012). The project is designed to avoid, minimize and manage E&S risks and impacts in compliance with Vietnamese legal and regulatory requirements, IFC’s PSs’ and applicable World Bank Group (WBG) General and sector-specific (Perennial Crop Production (2016), Annual Crop Production (2016), and Environmental, Health and Safety (EHS) Guidelines.

Key E&S issues associated with this investment are: (i) provision of safe and fair working conditions, compliant with Vietnamese labor law and PS2, for permanent employees, contractors and supply chain labor; (ii) water and energy efficiency and consumption; (iii) solid and liquid waste treatment and disposal; (iv) emissions to air or combustion products (including GHGs) and odor; (v) food safety; (vi) natural resources such as water; and (vii) development, implementation and effectiveness of management systems to ensure of all the above issues are appropriately managed.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s 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 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

Policy: Pan Group (the holder of Pan Farm) is committed through its existing Environmental, Social and Governance (ESG) policy to the promotion of sustainable development for its subsidiaries, in particular its farming practices. It seeks to optimize ESG attributes within the scope of its investments through resource efficiency, environmental stewardship and certification of management practices defined in Vietnamese legal and regulatory requirements and voluntary agro-commodities standards. This ongoing policy commitment is reflected in the Pan Group public policy commitments to sustainable development, compliance to national laws, international guidelines and standards, as well as continual improvement in governance. Pan Farm is a wholly owned subsidiary of Pan Group.

Pan Farm is committed to adhering to the requirements of agricultural best practices for agricultural production, and shall develop its agriculture, harvesting and sales practices in accordance with those requirements for Pan Saladbowl. Pan Saladbowl plan to apply a credible voluntary agro-commodity standard to both its flowers and vegetable production operations. Pan Saladbowl currently has no written EHS policy, annual targets or EHS competency to achieve its stated sustainability objectives.

As set forth in the ESAP Pan Saladbowl shall develop an overarching policy defining its environmental and social objectives and targets to cover the scope of Pan Saladbowl and its operations, including its commitment to apply agricultural best practices such as Global GAP.

NSC and SSC have a publically available Commitment to Sustainability (see Sustainability Report (2015)); Pan Group has developed and implemented an overarching Environmental, Occupational Health and Safety, and Social (EHS) policy defining the EHS objectives and principles that guide Pan Group to achieve sound and continuous improvement of its EHS performance. This action was completed in accordance with ESAP schedule for investment #34305.

Identification of Risks and Impacts: Pan Saladbowl has used the requirements contained in applicable Vietnamese regulation to aid in the identification of its social and environmental risks and impacts, and likewise, to obtain an Environmental Protection Permit (EPP). The scope of the EPP includes the 8 hectares of greenhouse construction, and 27 hectares for future planned agricultural development at Lam Ha farm. The document (approved by the Provincial Department of The Ministry of Natural Resources and the Environment (DoNRE) (dated 11th November 2015),) included the requirements for: (i) effective implementation of the EPP during operational phase; (ii) preparation of quarterly and bi-annual report on EHS performance, including compliance with Vietnamese regulations on effluents, air emissions, and noise; (iii) notifying authorities about occurrences of unforeseen events; and, (iv) requirements for internal and external environmental audits. It was stated to IFC that any new locations purchased by Pan Saladbowl will be integrated in to the scope of this EPP.

The laws governing environmental protection in Vietnam include: Law on Environmental Protection No. 29/2005/L-CTN implemented 2006; Providing Strategic Environmental Assessment, Environmental Impact Assessment and Environmental Protection and Commitment No. 29/2011/ND-CP; and, Law on Environmental Protection No. 55/2014/QH13, implemented 2015. Combined, these laws specify the rights and responsibilities for all groups to monitor and mitigate impacts to the environment. Requirements specific to crop production include protection of agricultural resources such as water and soils and the proper management of waste.

Pan Saladbowl commitment to apply Global GAP based approaches will guide compliance to regulations as well as support the company in raising its performance to be more aligned to PS1 needs. The requirements of Global GAP include: (i) risk based approach to identification, assessment and mitigation of environment, social and Occupational Health and Safety (OHS),  risks and impacts; (ii) environment and OHS related policy, procedures, monitoring, data collection, evaluation and continual EHS improvement; (iii) sustainable management of natural resource usage and avoidance of negative impacts to biodiversity including in application and disposal of agro-chemical inputs; (iv) promotion of Integrated Pest Management (IPM) approaches; (v) food safety, testing and hazard control points; and, (vi) best practice in design, care and maintenance of facility infrastructure and equipment’s to mitigate and reduce additional risks to product and worker safety and ensure effective use of resources. Pan Saladbowl stated to IFC that future out-grower contracts will include a requirement for compliance to Pan Saladbowl environment and social standards. Currently, Pan Saladbowl out-grower management is conducted on an ad-hoc basis with contractual agreements based on capacity of the identified farmer to comply with technical specification issued by Pan Saladbowl for cultivation of products. No risk assessment for environment, social, OHS, or labor compliance issues or standard EHS clauses are included in the present out-grower contract arrangement.

The application of Global GAP based approaches would address key aspects of PS1 requirements, such as the application of a risk based approach to operations and focusing on continual improvement in EHS performance. This would be supported by an Environment and Social Management System (ESMS) that shall enable all procedures, data, and monitoring to be systemized ensuring compliance to PS1. Therefore, as set forth in the ESAP Pan Saladbowl shall develop a PS1-compliant ESMS that includes the scope of all operations of Pan Saladbowl and its contracted out-growers based on a risk based approach, and is also aligned with the international best practice approaches included in standards such as ISO14001 and OHSAS18001.

NSC and SSC operations were referenced in the ESAP #34305 for Pan Group (i.e. that ESAP referenced all of Pan Groups subsidiaries at that time); as such, they will update and finalize their integrated ESMS. The action item was expected to be closed out in December 2016.

Management Programs: Pan Saladbowl operational procedures describe a systemized approach for document creation and control with dates of development, version numbering and approval for issuing final versions; a key requirement of any management system. Pan Saladbowl plans to adopt approaches consistent Global GAP and target eventual certification against this standard for its core operations, defined as locations owned, leased and under direct management control of Pan Saladbowl. Pan Saladbowl currently have no documentation, or action plans to guide this management program. To support this process and show compliance to the elements of PS 1 and PS 6 (that pertain to certification of primary production), it is required that a pre-assessment be conducted on Pan Saladbowl operations to identify a road map to implementing Global GAP requirements. As set forth in the ESAP Pan Saladbowl shall conduct this pre-assessment against IFC PS1 and the Global GAP requirements to identify needs for compliance to these standards.

Organizational Capacity and Competency: Pan Group has in place a Sustainability Coordinator responsible for group entities which includes Pan Farm and its subsidiaries. Pan Farm has not yet assigned an EHS/Sustainability Coordinator, nor assigned EHS responsibilities for reporting and maintaining systems at the subsidiary level.  Pan Saladbowl has assigned a suitably qualified operations manager with the task of developing and implementing Global GAP requirements at the Lam Ha farm. Implementation of the ESMS, and the application of Global GAP shall require dedicated roles, not only to link information needs in to the existing sustainability framework of Pan Group, but also support development of policies, procedures and data capture for Pan Saladbowl and its out-growers. These actions will also confirm support to compliance to PS 1 monitoring and reporting needs. As set forth in the ESAP Pan Saladbowl shall identify the capacity needs to implement an ESMS (based on its scope), and shall assign roles and responsibilities for implementing the system.

NSC and SSC were included within the ESAP for investment #34305 with regards to this requirement. The framework for such implementation has been completed; the action item is still to be fully implemented. (To be closed out in December 2016.).

Emergency Preparedness and Response: Pan Saladbowl has risks associated with storage of, and use of fuels, agro-chemicals, pesticides, fertilizers, mechanical processing equipment’s, equipment involved in transportation activities, and the manual handling of heavy loads.

Pan Saladbowl has developed a suite of emergency procedures that include how: (i) to respond to accidents and injuries; (ii) prevent and, if needed, deal with fire; and, (iii) address chemical spills. Despite reference to firefighting, no firefighting equipment was sighted within Pan Saladbowl facilities. Da Nhim fire response equipment was absent from worker accommodations with no clearly marked fire exits, and a lack of emergency lighting systems. No first aid equipment was seen and no training in first aid or firefighting had been conducted. Accident log books were not available at any site. There was no organizational structure for emergency response within Pan Saladbowl.

As set forth in the ESAP Pan Saladbowl shall document its emergency response procedures, including an accident record system, accident investigation, and near miss reporting process (based on the severity of the accident) as well as defining an organization hierarchy demonstrating responsibilities for notification and persons to notify.  In addition, Pan Saladbowl shall conduct a gap analysis against national standards for fire equipment compliance and close all gaps. See PS 4 for further details.

NSC and SSC addressed this matter as part of the ESAP for the Pan Group investment. The company will confirm the implementation of an Emergency Preparedness and Response Plan for all its subsidiaries operations and seek fire certificate for all sites. Action completed in accordance with ESAP schedule.

Monitoring and Review: Monitoring of ground water, and soils for chemical residue levels is conducted by Pan Saladbowl in accordance with the terms and conditions of the above mentioned EPP. Food safety standards will require maximum residue level testing of food produce to identify any risks to the end consumer from excessive chemical applications. Global GAP does require recall procedures for produce in the event of chemical or bacterial contamination being identified. Pan Saladbowl has no monitoring management system in place to systemize current and future planned actions, and no system to currently review, evaluate and continually improve the quality of the management system. See ESAP Identification of Risks and Impacts which addressed the need for these practices to be put in place and Global Gap certification to be achieved.

Stakeholders are present within the sphere of influence of Pan Saladbowl; operations may have environmental and social impacts on these groups. The risks identified for communities are: (i) water contamination due to chemical usage, residues, spills and drift; (ii) product contamination and risks to the consumer from chemical residues or bacteria; (iii) road transport risks to local communities due to product shipment; and, (iv) risks to local communities within urban areas from water storage ponds. Initial engagements with stakeholders has been conducted on an informal basis, however risks are present from Pan Saladbowl actions and a systematic approach to stakeholder engagement needs to be established. A formal process will be established that enables open communication with communities to forewarn of any specific actions to be conducted by Pan Saladbowl that may impact their rights of access or pose a potential risk to their property, wellbeing or livelihood, as well as enable emergency situations to be effectively communicated to at risk groups. See ESAP Identification of Risks and Impacts whereupon this requirement is addressed as part of the overall management system to be developed and implemented.

NSC and SSC included in the ESAP #34305 Pan Group and its subsidiaries will prepare and implement an EHS management system procedures addressing stakeholder mapping, stakeholder and community engagement, including a community grievance mechanism complying with PS1. Aspects of the action remain such as community grievance process and finalization of public dissemination plan.

Pan Farm employs 763 staff (including NSC and its subsidiaries), with Pan Saladbowl currently employing 49 with a plan to expand this to 436 staffs by 2020.  Pan Farm is committed to applying the labor law No. 10/2012/QH13 in accordance with Vietnamese regulations. 

Human Resources Policies and Procedures: Pan Farm, and its subsidiary Pan Saladbowl have in place a dedicated Human Resources (HR) team and a full suite of procedures and an employment manual that indicates their intention to comply to the requirements of Vietnamese Labor Law No. 10/2010. The HR manual includes the lists of employee benefits and entitlements including: (i) recruitment process and selection; (ii) staff evaluation; (iii) training; (iv) discipline; (v) grievance; (vi) general terms and conditions of employment; and, (vii) termination. Interviews with workers at Pan Saladbowl confirmed their understanding of the employment provisions and knowledge of their rights under national labor law. The HR policies (although compliant to national regulation) did not specifically reference core International Labor Organization (ILO) conventions as included within PS 2. Specifically, those include (i) freedom of association; (ii) right to collective bargaining; (iii) commitment to avoid use of forced or child labor; (iv) equal rights and equal pay; (v) nondiscrimination based on gender, age, or sexual orientation; (vi) protection of rights of migrant workers; and, (vii) retrenchment, including the process for selection of workers

As set forth in the ESAP Pan Saladbowl shall conduct a review of its employment policies and include in its core HR policy requirements: (i) freedom of association; (ii) right to collective bargaining; (iii) commitment to avoid use of forced or child labor; (iv) equal rights and equal pay; (v) nondiscrimination based on gender, age, or sexual orientation; (vi) protection of rights of migrant workers; and, (vii) retrenchment, including the process for selection of workers.

NSC and SSC were required by the ESAP associated with IFC’s investment (#34305 Pan Group) along with all Pan Group subsidiaries to review HR policies, Internal Labor Rules (ILRs), and supporting procedures to ensure full compliance with Vietnamese’s new labor Code, and IFC PS 2 requirements. The policy was to be communicated to employees at all levels of Pan Group and/or subsidiaries level and to be clearly displayed in visible and accessible areas at all sites. Documentation provided to IFC since then is pending review and finalization; the action item is progressing.

Working Conditions and Terms of Employment: Pan Saladbowl benefits to workers include: (i)  compliance to minimum wage for the province of Lam Dong; (ii) 12 paid annual days leave; (iii) all national holidays including lunar new year, mid-autumn festival, labor day and liberation day; (iv) medical and social insurance; (v) annual medical checks; (vi) breaks every 2 hours, with lunch and an average working day of 8 hours; and, (vii) 1 day a week off, with a total working hours per week of 6 days at 8 hours or 48 hour week. Accommodation and meals are provided free. A review of employment contracts provided at the Lam Ha farm location highlighted that terms and conditions are stated within employment contracts. Details within contracts of employment included: (i) name of worker; (ii) date of birth and home address; (iii) location of work; (iv) job title and duty; (v) salary and allowances entitlement; (vi) social and health benefits; (vii) Annual health checks; (viii) medical insurance; (ix) annual bonuses; (x) annual leave entitlements; and, (xi) national and other holiday entitlements. Interviews conducted with workers showed that they were all aware of the key provisions in the employment manual and their employment rights.  Minimum wage in Lam Dong Province is 2.4000.000 Viet Nam Dong (VND) or ~110 USD equ. Workers highlighted in discussions that average salaries were 2.700.000 (VND) in Pan Saladbowl.

Pan Saladbowl working conditions were considered reasonable with the one exception of worker accommodation. Accommodation visited at Da Nhim highlighted the following: (i) location of living accommodation is within the flood plain of a small river; (ii) living space for workers did not comply with minimum area requirements; (iii) inadequate shower and sanitation facilities with no separate location for workers by gender; (iv) no life and fire safety infrastructure; (v) kitchen and communal areas not meeting minimum standard for hygiene; (vi) window and natural light penetration was inadequate; (vii) and, no emergency exits, nor emergency lighting systems in place. Kitchens, waste storage and communal relaxation areas were not enclosed. As stated in the PS, accommodation for workers must adhere to the requirements of basic services, these being: (i) minimum space; (ii) supply of water; (iii) adequate sewage and garbage disposal; (iv) protection against heat, cold, damp, noise, fire and disease carrying animals; (v) adequate sanitary and washing facilities; (vi) adequate ventilation; (vii) adequate cooking and storage facilities; (viii) adequate lighting, both natural and artificial.

As set forth in the ESAP Pan Farm shall upgrade worker accommodations so as to ensure compliance to the requirements of PS 2.  

Pan Saladbowl has implemented no EHS training in the previous 12 months. Ongoing operational training is conducted with staffs to ensure quality control on production. See PS1 ESRS Identification of Risks and Impacts and the need to include this in the overall ESMS.

Workers’ Organization: Pan Saladbowl fully support the workers right to collective bargaining and workers’ unions. See ESAP Human Resources Policies and Procedures.

Non-discrimination and Equal Opportunity: See ESAP Human Resources Policies and Procedures.

Retrenchment: Pan Saladbowl has no current retrenchment plans. It is a requirement that a policy, and a transparent procedure for the identification and selection of workers to be retrenched be stated in the employment policy. See ESAP section Human Resources Policies and Procedures.

Grievance Mechanism: Pan Saladbowl maintain an employee grievance mechanism that enables complaints to be brought directly to senior management. At the time of the appraisal no employee grievance had been made since the inception of the company. The grievance mechanism, although included within the employment policy and procedures, does not allow for the posting of anonymous grievances. As such the policy and approach needs to be amended to assure anonymity of the complainant. See ESAP section Human Resources Policies and Procedures.

NSC and SSC included in the ESAP #34305 Pan Group and its subsidiaries will develop and implement a corporate / subsidiary level employee grievance mechanism, including steps to be taken, mediation process, assigned responsible persons, publicizes the procedure, response time, record keeping, and how feedback will be given. The employee grievance mechanism will be disseminated to employees as part of the induction process, will be accessible to seasonal and contractual workers, and will be posted on Pan Group and each subsidiary’ internal website.  Draft document received pending finalization.

Protecting the Work Force: Pan Saladbowl protects its work force through the application of prevailing labor and OHS laws and regulations.There are no specific policies for avoidance of engagement of child nor forced labor. See ESAP Human Resources Policies and Procedures.

Occupational Health and Safety: Pan Saladbowl is required to provide a bi-annual report to the Provincial Public Health and Labor Authority in Lost Time Incident Reports (LTIR). Pan Saladbowl highlighted no accidents (since operations are beginning).  Sighting of Accident Record Logs, or Post Accident Report procedures was not possible. See PS1 ESAP Identification of Risks and Impacts.

NSC and SSC included in the ESAP #34305 Pan Group and all its subsidiaries will provide to IFC, for review, workplace OHS risk assessment for processing and aquaculture/farming operations, set of SOPs applicable to OHS measures (including extensions officers and contractors), organizational structure, annual OHS training, including centers of responsibilities, budgetary allocations and schedule of delivery, findings of external and internal OHS audits which have taken place, including CAP, and consolidated annual OHS performance reports. Procedures have been received but implementation validation pending. OHS policies, procedures and hazardous assessment have been received. Pending verification on implementation.

Workers Engaged by Third Parties: The third parties engaged by Pan Farm are the out-growers. See Supply Chain.

Supply Chain: Pan Group has implemented a supply chain procedure to ensure traceability of its supply chains and that they screen for harmful child and forced labor therein. As such the process for supplier auditing is already established at the Pan Group level but has not been applied to Pan Farm and or Pan Saladbowl. Pan Farm supply chain are the out-growers engaged to cultivate products under contract.

Pan Saladbowl outsources cultivation of seeds and flowers (and in future vegetables) to farmers with a selection process based on operational criteria and performance benchmarks. See PS1 ESAP Identification of Risks and Impacts.

Resource Efficiency: Pan Saladbowl has not established targets, commitments or systems in place to be able to fulfill any steps to demonstrate resource use efficiency. Moving forwards in the commitment to apply Global GAP based approaches, tracking and recording of resource use will be required to demonstrate efficient consumption of resources in its production process. This will include resources such as water, chemical inputs and energy. See PS1 ESAP Management Programs.

Energy and Material Efficiency Projects: Pan Saladbowl has no energy and material efficiency projects in place. Existing systems for crop production are based on technical specifications supplied by Japanese partners that state quantities and types of chemicals and water to be applied during the growth cycle of the product. There is a system in place to measure and track use of resources and inputs based on operational needs. Adoption of Global GAP based approaches will enable resource efficiency measures to be developed particularly for water consumption and energy used through application of best practice in equipment, facility and infrastructure design, maintenance and usage. See PS1 ESAP Management Programs.

Water: Water is an essential component of the Pan Saladbowl business. Lam Dong Province, where the commercial farming operations are located has a clearly defined dry and rainy season with an annual rainfall of 1400mm spread over 8 months. Lam Ha farm sources water from a 70m deep borehole while Da Nhim farm sources water from local water courses. Both facilities maintain rain fed water storage ponds. No monitoring of water volume usage is made and no method for calculation of water storage pond capacity was available. Water irrigation systems are drip irrigation within greenhouses/poly tunnels. Pan Saladbowl shall have to demonstrate that use of water resources is done efficiently and in accordance with best practices. as per the application of Global GAP requirements. See PS1 ESAP Management Programs.

GHG Emissions: Pan Saladbowl utilizes cold storage rooms, water pumps, transportation and mechanical farm equipment’s. General power consumption is supplied through a local electricity grid with backup generators available at site as required. Pan Saladbowl has not considered its GHG emissions. As an agricultural producer it is calculated that net GHG emissions from its operations will not exceed 25,000 tCO₂e per annum.

Pollution Prevention: Pan Saladbowl has detailed approach to the application of pesticides and operational procedures that includes: (i) selection of chemical to address identified need; (ii) adequate training and use of PPE for workers applying chemical; and, (iii) disposal of chemical containers and left over chemicals from operations. Composting shall be applied for organic waste. Hazardous storage spill and capture requirements were sited at Lam Ha farm, but absent from Da Nhim farm.  

As set forth in the ESAP Pan Saladbowl shall review all hazardous storage locations and install at a minimum adequate spill and capture upgrades, and ensure that all stored hazardous materials have Material Safety Data Sheets (MSDS) displayed at entrance to storage location.

NSC and SSC included in the ESAP #34305 Pan Group and all its subsidiaries will ensure that appropriate secondary containment structures are installed at all sites. Construction of spill and capture in key locations conducted. Storage needs for small scale storage remains subject to review.

Air Emissions and Ambient Air Quality: The main energy supply for the Pan Saladbowl is derived from the national electricity grid which is metered. Supplemental use of generators is only applied in the situations of power loss. Emissions from farming equipment is considered minimal.

Wastewater Treatment: Pan Saladbowl generate waste water from cleaning of produce prior to packaging and distribution; this water shall be returned to the cultivation area as additional irrigation water. Pan Saladbowl stated that both water entering their production system as well as water leaving the production system will be tested to ensure all residual chemical risks are identified and addressed. This will be conducted on produce prior to shipment to ensure compliance to maximum residue levels. In accordance with the EPP Pan Saladbowl conducts quarterly monitoring of ground water to ensure no chemical residues are entering local water supplies. See PS1 ESAP Management Programs.

Solid Waste Management: Pan Saladbowl waste separation procedures are in place for organic, landfill, and hazardous waste classifications. Organic material shall be composted and recycled in to the production process. Other wastes will be disposed of by municipal waste collection and landfilled. Packaging wastes will be managed by the end user of the material. Potting, planting, trays and other commercial farming materials will be recycled as far as possible (as part of efficiency). Plastic sheeting and piping from the greenhouses/poly tunnels will be replaced every 4 years. Verbally stated this material is planned for sale and recycling.

Hazardous Materials: Pan Saladbowl has a defined procedure and process for the disposal of hazardous wastes.  It was stated that hazardous wastes will be removed by certified disposal agents.

In respect to storage of hazardous materials, Pan Saladbowl Da Nhim storage of chemicals, fuels and oils were stored within the existing structure of a poly tunnel (within an enclosed wooden location). Chemicals (albeit in minor quantities) were stored on degraded shelving. There was no stock control system in place. No MSDS sheets were present. See ESAP Pollution Prevention.

Pesticide Use and Management: Pan Saladbowl has challenges regarding a range of pests and fungal risks due to produce and method of production (i.e. high humidity in poly tunnels). WHO listed Class II (moderately hazardous) chemicals used by Pan Saladbowl include: (i) Decis (Deltamethrin); (ii) Danitol (Fenpropathrin); (iii) Regent (Fipronil); and, (iv) Diazinon (Organophosphate). The IFC require that companies do not use pesticides listed in WHO Hazard Class II (moderately hazardous), unless the project has appropriate controls established with respect to the manufacture, procurement, or distribution and/or use of these chemicals. These chemicals should not be accessible to personnel without adequate training, equipment, and facilities in which to handle, store, apply, and dispose of these products properly. See PS1 ESAP Risks and Impacts.

Training of Pan Saladbowl staffs in chemical application and in chemical handling is conducted. This training as at the time of the appraisal had been documented.  Pan Saladbowl Da Nhim had PPE’s which included gloves, face mask and boots. Interviewed workers highlighted both knowledge and use on PPE for chemical spraying. Pan Saladbowl do not assess contracted out-growers’ approaches to PPE, nor training capacity of that group.

As set forth in the ESAP Pan Saladbowl shall develop a prohibited chemicals list based on WHO Class 1a (extremely hazardous) and 1b (highly hazardous) and shall screen all stores and preferred chemicals against this list prior to purchase. Appropriate materials and regulatory compliance for chemical pest control shall be included in any agricultural outreach program given to out-growers.

Pan Saladbowl has no approach for IPM. Application of Global GAP requirements shall require adoption of IPM in support of the objectives of PS 3.

NSC and SSC included in the ESAP #34305 will provide to IFC for review, its IPM policy, procedures, strategy and plan, in accordance with WBG’s EHS guidelines for Annual Crop Production.  SSC and NSC provision of supporting evidence that all products (Crop Protection Products (CPPs) used at its own farming operations and and/or distributed by SSC and NSC are approved by the Vietnamese Ministry of Agriculture (ref. Pesticides Control Board); that they are cross-referenced with Global GAP; that none of these products purchased, stored, used, manufactured, or traded by SSC and NSC fall in WHO classified hazard Class 1a (extremely hazardous) or 1b (highly hazardous). If applicable, SSC and NSC will implement a phase-out for banned products. Provision of supporting evidence that NSC and SSC will not purchase, store, use, manufacture or trade in Class II pesticides (moderately hazardous), if NSC or SSC cannot demonstrate that they have adopted appropriate controls on manufacture, procurement, or distribution and/or use of these chemicals; and, that these chemicals should not be accessible to personnel without proper training equipment, and facilities to handle, store, apply, and dispose of these products properly. Crop Protection Products action item has been completed.

Community Health and Safety: Pan Saladbowl locations are a mixture of rural locations and semi urbanized. All locations are active consolidated agricultural landscapes. As highlighted the risks identified for communities are: (i) water contamination due to chemical usage, residues, spills and drift; (ii) product contamination and risks to the consumer from chemical residues or bacteria; (iii) road transport risks to local communities due to product shipment; and, (iv) risks to local communities within urban areas from water storage ponds. 

Pan Saladbowl shall address water contamination risks through application of its procedures, and compliance to the EPP and adoption of Global GAP based approaches. Road transport risks, and risks to local communities have not yet been considered.

As set forth in the ESAP Pan Saladbowl shall conduct a community safety risk assessment and propose operational and security measures to reduce identified risks.  

Infrastructure and Equipment Design and Safety: Water storage ponds were present at Pan Saladbowl Lam Ha farm, although this land is “off access” to non-employee’s the proximity to schools and local housing does pose risks to community safety. See ESAP Community Health and Safety.

Hazardous Materials Management and Safety: Risk of chemical drift contamination to adjoining land users’ fields and or crops shall be mitigated through the adoption of an appropriate ESMS, and Global GAP based approaches. It has to be noted that the major portion of operations for Pan Saladbowl will be within greenhouses/poly tunnels therefore risks from chemical drift is limited.

Ecosystem Services: Not applicable.

Community Exposure to Disease: See Community Health and Safety.

Emergency Preparedness and Response: Not applicable.

Security Personnel: Sites assessed contain security staffs. There is no history of violent conflicts, nor protests against any of the Pan Farm Facilities. All sites are secured with gated entrance and fences.

Company background to biodiversity conservation: Pan Saladbowl is engaged in primary production of agricultural products it is a requirement where a credible standard exists that a pre assessment to assess the level of conformity. As at the date of the field mission Pan Saladbowl has complied with the requirements of national environmental regulations, and has a commitment to adopt Global GAP. Pan Saladbowl had not conducted any pre –assessment against that standard. This is therefore addressed under the PS1 ESAP Management Programs requirements.

Stakeholder Engagement is discussed in PS1 and PS4 sections of the E&S Risks / Impacts & Mitigation tab.

Contact Person: Mr. Nguyen Viet Hung (Chief Executive Officer)

Company Name: PAN Farm JSC

Address: 15th Floor, ICON4 Tower, 243A De La Thanh Street, Hanoi, Vietnam

Email: E-mail: hungnv@thepangroup.vn

Phone: Tel: (+84-4) 3760 6190

Broad Community Support is not applicable for this project.