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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The proposed equipment modernization is within the existing Promasidor facilities, therefore PS5 – Land Acquisition and Involuntary Resettlement is not applicable to the project. As the plant is located in an existing industrial estate, PS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources is also not applicable. PS7 – Indigenous Peoples and PS8 – Cultural Heritage have also not been identified at the project site and are therefore not applicable either. In the event that issues anticipated by these Performance Standards arise, Promasidor will promptly inform IFC.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. The environmental and social risks and impacts associated with this project are limited, site-specific and can be readily addressed through generally accepted mitigation measures as described in this document and the attached Environmental and Social Action Plan (ESAP).
The main environmental and social risks and impacts associated with this project include food safety management; the management of solid and liquid wastes and air emissions; resource efficiency; assurance of fair, safe and healthy working conditions for all workers; and management of community health and safety.

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

Environmental and Social Assessment and Management System: Although Promasidor does not have a formal integrated ESMS, the company has a Health, Safety and Environment (HSE) Manual, a Good Manufacturing Practice (GMP) Manual and a Food Safety Management System (FSMS). These documents broadly cover the environmental, health and safety aspects of Promasidor’s operations including occupational health and safety (OHS), food safety and emergency preparedness. The plant is also certified under ISO 2200 for quality and food safety respectively. The following paragraphs under this Performance Standard further describe the aspects related to the identification and management of environmental and social impacts in relation to Promasidor’s operations as well as the gaps identified by IFC. As indicated in ESAP action item #1, Promasidor shall develop and implement an integrated Environmental and Social Management System (ESMS) which shall systematically identify, prioritize and manage the company’s E&S risks and develop corrective action plans in line with the requirements of Performance Standard 1.



Policy: Promasidor has in place a Health, Safety and Environment Policy through which the company undertakes to protect the health and safety of its employees and service providers; and to preserve the environment through prudent management of its waste, pollution control and selection of work processes and equipment that support sustainable environmental practices. The policy commits Promasidor to compliance with the statutory laws and is communicated to all employees. The policy is consistent with the principles of the Performance Standards.



Identification of Risks and Impacts: The main E&S risks and impacts associated with Promasidor’s current operations are identified in the existing HSE and FSMS procedures. These include the need to maintain good food safety practices, ensure resources are used as efficiently as possible, managing air emissions stemming from production and also liquid and solid waste management, ensure appropriate and safe working conditions, and the need to ensure readiness with regards to possible emergencies and in general protecting community health and safety. A more systematic process of identification, assessment and prioritization of the E&S risks and impacts (according to their probability and severity of negative impacts) is required so as to enable continuous, monitoring, periodic review and continual improvement. This will be required as part of the ESMS development as stipulated in ESAP item #1.



Management Programs: Promasidor has developed management programs to address the risks and impacts associated with its current operations. These management programs are covered in the HSE and GMP manuals and the FSMS. The FSMS comprehensively covers hazard analysis and critical control points for food safety. Promasidor needs enhance their HSE management programs such as effluent treatment, energy efficiency, water conse
rvation and integrated waste management by ensuring that all risks are identified and corrective action plans put in place. As indicated above (ESAP item #1), Promasidor shall develop an integrated ESMS which includes detailed procedures aligned with this Performance Standard.



Organizational Capacity and Competency: Promasidor has a number of personnel responsible for HSE matters; however, the roles need to be better coordinated. The HSE Manager, Compliance Manager and Quality Assurance Manager play different roles in the implementation of the HSE procedures. The HSE Manager has the overall responsibility for HSE matters including emergency preparedness and response, fire safety and waste management. The Quality Assurance Manager is responsible for implementing the FSMS and the Compliance Manager is responsible for ensuring E&S legal compliance. Furthermore, the company has a Risk Management Committee that oversees all HSE-related activities. As indicated in ESAP action item #3, Promasidor shall develop an organogram and use this framework to better clarify the roles and responsibilities of these key E&S positions within the company, including selecting an E&S team leader to coordinate all the activities.



Training: Promasidor provides HSE training to all workers as part of its induction program. This training includes company specific safety information; safety regulations; first aid; fire prevention and firefighting; emergency response procedures; and the use of protective equipment. In addition, other specific trainings are provided on a need basis, such as training for fire marshals, accident and incident reporting procedures, basic safety rules and regulations. Following development of the ESMS, Promasidor shall provide training to the ESMS team and overall awareness program to all staff on the overview of the system; (ESAP item #2).



Emergency Preparedness and Response: The Company’s emergency preparedness and response plan is included in the HSE manual. Promasidor also has a fire safety procedure in place and there are trained fire marshals. Regular inspections and testing of fire equipment are carried out by the HSE Manager, and there are monthly fire drills. Promasidor’s current emergency preparedness and response plan focusses on fire emergencies. In addition to fire emergencies, typical emergencies that may occur in this facility include chemical leakages, hazardous material spillages and food contamination. As indicated in ESAP item #1, Promasidor shall identify all areas where accidents and emergency situations may occur in which the community or individual may be impacted; develop response procedures for each identified emergency situation; provide the necessary equipment and resources to effectively implement response plans, assign responsibility and provide the necessary awareness and training.



Monitoring and Review: Environmental parameters such as noise and air emissions, wastes, effluent quality and OHS inc
idents are monitored by Promasidor. Environmental audits are also conducted every three years in compliance with the local regulatory requirements and reports are submitted to local authorities. In addition, the company conducts periodic ISO 22000 audits. The last external environmental audit indicated that Promasidor had achieved high compliance levels in the managing their air emissions, noise levels, water quality. During appraisal, Promasidor indicated that the effluent treatment plant (ETP) was to be redesigned and improved. The audit recommended that Promasidor explore ways of managing their water use and for the company to introduce more robust waste minimization programs (as required by the ESAP items #7&9).

Promasidor currently employs 1,026 permanent workers and an average of 750 contract workers. The number of contract workers fluctuates depending production. Promasidor operates a 24-hour shift system for factory workers; for non-factory workers, the company operates a nine-hour day, inclusive of 1-hour break; this is compliant with Nigerian labor laws. The Company complies with the minimum employment age requirements in Nigeria, which is 18 years.



Human Resources Policies and Procedures: Promasidor has a Human Resources Manual, which was last updated in 2012 and is currently under review. The HR Manual is provided to all employees as part of the induction process and includes terms and conditions of employment; working hours, salaries and allowances; leave policies; retirement and redundancy policies; disciplinary procedures and a grievance procedure.



Workers’ Organization: Promasidor employees are free to form or join workers’ organizations. The employees are affiliated to two unions – The Food, Beverage and Tobacco Senior Staff Association (FOBTOB) and the National Union of Union of Food, Beverage and Tobacco (NUFBTE). The company signed a collective agreement on salaries and allowance with both unions in 2002; in July 2015, the company, together with the two unions concluded a new cycle of benefits negotiations. Management indicated that Promasidor has had strikes in the past, mainly due to lack of proper communication channels between management and labor. In 2012, Promasidor set up a forum for management and labor to communicate and also signed collective bargaining agreements with the unions. Trust was built over time such that there have been no strikes in the last three years; and the company management has maintained a good relationship with the unions.



Non-discrimination and Equal Opportunity: The HR Manual includes a summary policy which is not in full compliance with this Performance Standard 2. The policy does not specify how the Company will achieve non-discrimination or ensure equal job opportunities. As set forth in the ESAP action item #3, as part of the HR Manual review, Promasidor shall enhance the existing policy on non-discrimination and equal opportunity and clearly convey how; the basis of their decisions will be nondiscriminatory (not based on personal characteristics such as gender, race ethnicity etc.), and; how they will base the employment relationship on principle of equal opportunity and fair treatment (in hiring, compensation, working conditions, terms of employment, access to training, job assignment and access to training) in accordance with Performance Standard 2.



Retrenchment: The Company does not envisage any retrenchment in the near future. Should retrenchment be necessary, the company will ensure early consultation with all stakeholders and the company will comply with the requirements of local labor laws as well as obligations of its collective bargaining agreement.



Grievance Mechanism:
The HR Manual includes a procedure for reporting and resolving grievances. The grievance mechanism is accessible to all staff members as well as third party workers. No grievances have been reported in the last three years.



Occupational Health and Safety: Promasidor’s OHS procedures are included in the HSE manual. The OHS procedures cover hygiene and sanitation, provision and use of protective clothing and equipment; and accident prevention. The roles and responsibilities of safety marshals and employees are clearly stipulated in the procedure. In addition, safety training is provided as part of the company’s employee induction program. As part of the OHS procedures, the company assesses OHS risks through regular inspections and periodic audits of its operations. Promasidor’s HSE Manual outlines safety guidelines and preventative steps for specific work areas and activities such as the chemical room, the boiler room, forklifting, cleaning in place, traffic safety and general office safety. However, the manual does not identify or classify specific hazards associated with the work areas. Accidents and incidents are reported, recorded and investigated; no fatalities or major injuries have been recorded at the site. It is noted however that a significant number of hours are lost due to incidents on monthly basis. The company needs to identify risks, work to avoid or eliminate them, or where risks cannot be eliminated to reduce the residual risks to acceptable levels. Promasidor will also need to identify new risks which will be introduced by moving to automation – such as increased exposure to belts and other moving parts; need for lock-out tag out procedures to de-energize equipment prior to maintenance or repairs or where new confined spaces are being introduced. As indicated in ESAP item #5, Promasidor shall revise their OHS procedures to address the above shortcomings in order to meet the requirements of Performance Standard 2.



Workers Engaged by Third Parties: Promasidor has an average of 750 workers contracted through third parties. The company has signed contracts with the third party contractors to ensure that the companies meet Promasidor’s requirements in relation to the management of the third party workers. Promasidor oversees fair contractual terms for the third party workers and the workers are subjected to the same working conditions as permanent workers, including access to the grievance mechanism. The OHS hazard and risk review process shall take into cognizance jobs undertaken 3rd party workers and that this forms part of the OHS enhancement program (as required by the ESAP item #5).



Supply Chain: Supply chain issues are not considered significant for this project; Promasidor does not have direct links to primary commodity producers. Milk powder is imported from European/New Zealand suppliers and dried tea leaves are imported from Kenya. Some materials for seasoning and flavored milk are sourced locally.

Resource Efficiency: Energy is used for the production processes as well as the running of the administrative offices and auxiliary facilities. The total annual energy consumption is approximately 9,557,456 kWh. Promasidor is currently implementing various measures aimed at improving efficiencies in the consumption of energy such as the use of natural gas generators and solar lighting. Due to the unreliability of grid power in Nigeria, Promasidor primarily runs on generator power. Approximately 96% of the total energy consumed at Promasidor is powered by natural gas generators, with the remainder covered by diesel generators. The introduction of gas generators has led to a 50% reduction in energy costs.



Water: Promasidor currently runs a primarily dry production process; water is used for steam generation, cleaning of factory equipment, domestic purposes and fire services. Promasidor has three functional boreholes within its premises from which it sources its water. The water is treated on-site by filtration and stored inside four surface tanks with a total capacity of 122m3. In addition, there are two firewater tanks, each with a capacity of 77m3. The factory use accounts for 98.5% at approximately 136m3/day of the total water consumption. With the expansion of dairy product portfolio, water consumption is expected to increase. The external environmental audit conducted at Promasidor recommended measures to be put in place to minimize water consumption including, but not limited to reuse of CIP water, education and awareness on water saving initiatives for staff, retrofitting of taps and ensuring early leak detection and fixing of leakages. As indicated in ESAP action item #7, Promasidor shall conduct a water efficiency study to quantify water use per activity so as to identify areas with high consumption and come up with measures for minimizing water consumption.



Pollution Prevention: Air emissions and noise emissions are generated primarily from the generators and factory equipment. Emissions are monitored as part of Promasidor’s monitoring and review process. The external environmental audit concluded that Promasidor has high level of compliance to noise and air standards. The recorded noise and dust levels are generally within the NESREA standard except in a few areas which exceed NESREA limits low margins. The audit recommended for the improvement in control of noise and dust in identified areas where the standards were breached.



Wastewater Treatment: The treatment of effluent is conducted at an onsite effluent treatment Plant (ETP). The effluent stream consists mainly of a mixture of powder waste, food grade cleaning agents and sanitizing agents. The treatment process involves screening, equalization, biological and chemical treatment and filtration. The ETP has a capacity to treat 64m3 volume of effluent; currently 34,2m3 of effluent is generated per day which represents 24% of the total water consumed (this excludes effl
uent from sanitary facilities which goes into sewage system). The results from the last environmental audit undertaken by Promasidor indicates that some of the treated effluent parameters are not compliant with National Environmental Standards and Regulations Enforcement Agency (NESREA) limits. Specifically, biological oxygen demand and the chemical oxygen demand measured at 315mg/l and 640 mg/l do not meet the NESREA requirements of 50mg/l and 90mg/l. These parameters also do not meet the WBG EHS Guideline limits, which are 50mg/l and 250mg/l respectively. During appraisal, Promasidor indicated that the ETP was to be redesigned; as indicated in ESAP action item #8, the redesign of the plant shall ensure that when it is operational it will meet the more stringent of the local regulatory requirements or those contained within the WBG EHS Guidelines.



Solid Waste Management: The solid waste streams generated at Promasidor include powder waste generated from spillages of raw materials including milk, tea and seasoning; primary and secondary packaging waste; office waste; wooden pallets; scrap metals; tyres; clinical waste and sludge. Wastes are collected and segregated in waste bins and skips. General office waste is collected by the state waste management authority and scrap metal, wooden pallets, tyres, and packaging materials are sold to third parties for reuse/recycling. Product wastes are sold for use as animal feed. Clinical waste is collected and disposed of separately at a licensed incineration facility. A recent refurbishment of the facilities resulted in the generation e-wastes – computers and air conditioning units – which are being stored on site until a suitable disposal option is identified.



Hazardous Materials: Diesel is stored on site in nine above-ground storage tanks with a combined capacity of 90,000 liters. All storage tanks are fitted with adequate containment bunds. Gas supply is via a gas pipeline. Used oil and spent grease are stored in drums and sold for reuse/recycling. As mentioned above, clinical waste generated on site is disposed of by incineration by through licensed contractors.

Community Health and Safety: The potential community health and safety impacts associated with Promasidor’s operations include food safety, emergency preparedness and traffic management. Aspects related to food safety management have been discussed under Performance Standard 1. Promasidor has an emergency response and preparedness plan and periodically conducts emergency drills with tenants from adjacent industries. As indicated under Performance Standard 1, the emergency response plan needs to be enhanced.



Security Personnel: Promasidor employs and will continue to employ private security personnel from specialized firms. Promasidor implements security policies and procedures commensurate to the operations’ risks. Security personnel are screened for criminal records and are provided with appropriate training for execution of their duties.

External Communications and Grievance Mechanisms
Promasidor has yet to develop a grievance mechanism for communities, for collecting or addressing concerns or complaints from local or directly affected communities. As part of the ESAP item# 1, the company shall develop and implement a grievance mechanism commensurate to the risks and adverse impacts of its operations to receive, record and when appropriate facilitate resolution of affected communities’ concerns and grievances.

Contact Person: Anders Einarsson
Company Name: Promasidor Nigeria Limited
Address: Plot 3A&B Cowbell Way, Isolo Industrial Estate, Lagos, Nigeria
Email: mailto:aeinarsson@promasidor-ng.com
Phone: +234 (0) 803 402 00 22

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Environmental and Social Management System (ESMS): Promasidor shall develop and implement an integrated Environmental and Social Management System consistent with IFC Performance Standard 1 which shall be submitted to IFC for review. The ESMS shall define roles and responsibilities and applicable policies, plans and procedures to enable all operations to comply with Nigerian laws and regulations, IFC Performance Standards and the applicable WBG EHS Guidelines. Amongst other elements, the ESMS shall: -Systematically identify, assess, prioritize and document the company’s E&S risks and impacts and develop corrective action plans in line with the requirements of Performance Standard 1. - Enhance the emergency preparedness and response plan by identifying all areas where accidents and emergency situations may occur in which the community or individuals may be impacted; developing response procedures for each identified emergency situation; providing the necessary equipment and resources to effectively implement response plans; assigning responsibility and providing the necessary awareness and training. - Develop and implement a grievance mechanism commensurate to the risks and adverse impacts of its operations to receive, record and when appropriate facilitate resolution of affected communities’ concerns and grievances.	04/15/2016
Organizational Capacity: Develop an E&S organogram to better clarify the E&S roles and responsibilities within the company; select/ designate an E&S team leader to coordinate all the activities; provide training for the ESMS team and overall awareness program to all staff on the new ESMS.	04/15/2016
Human Resources Policies and Procedures: As part of the proposed revision of the HR Manual, Promasidor shall ensure that the labor and working conditions are in accordance with Performance Standard 2 including policies on Non-Discrimination and Equal Opportunities Policy; forced labor and forced child labor.	06/30/2016
Occupation Health and Safety: Promasidor shall enhance OHS procedures to meet the requirements of Performance Standard 2 by: Identifying and classifying specific hazards associated with all the work areas including jobs undertaken by 3rd party workers; Identifying ways to avoid or eliminate the risks, or where risks cannot be eliminated to reduce the residual risks acceptable levels; Identifying and mitigating against new risks which will be introduced by moving towards automation	08/31/2016
Water Consumption: Promasidor shall conduct a water efficiency study to quantify water use per activity so as to ascertain areas with high consumption and come up with measures for minimizing water consumption.	03/03/2018
Effluent Treatment Promasidor shall modify the effluent treatment plant to meet local regulatory requirements and the WBG EHS Guidelines	03/03/2018
Waste Minimization: Promasidor shall introduce more robust waste minimization programs in line with recommendations made in the specialist Environmental Audit dated November 2013.	03/03/2018