PS5: Land Acquisition and Involuntary Resettlement is not applicable to the scope of this project; however, if in the future the company may look for a new site for the expansion of its operations, the parcel of land would be secured on a willing-buyer, willing-seller commercial basis for which the company will pay prevalent market rates. Issues related to PS7: Indigenous Peoples and PS8: Cultural Heritage are not applicable due to this investment as there as there are no indigenous peoples nor cultural sites within the company’s operational footprint. In the event that issues anticipated by these PSs arise including any additional company expansions, such as a fruit juice production line, Cediam will promptly inform IFC. Screening and assessment of these issues against the PSs requirements will be done through the company’s E&S management system (ESMS).

This proposed investment is expected to have limited environmental and social impacts, which are expected to be site-specific. Those impacts can be avoided or mitigated by adhering to recognized Good International Industry Practices (GIIPs) as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. The project is designed to avoid, minimize and manage E&S risks and impacts of the company’s operations in compliance with Malian legal and regulatory requirements, IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines.

Key E&S risks associated with this investment are: (i) improving of the management system, which does not currently encompass environmental and worker health and safety aspects of company’s processing operations; (ii) up-grade and decentralized monitoring process to assess the effectiveness of management activities related to environmental, food safety, and occupational health and safety issues; and (iii) encompass the HR policy and procedures manual to manage HR practices.

E&S Assessment and Management System. Cediam has developed elements of an integrated strategy and framework for addressing environmental, health and security, food safety and quality (EHSQ) issues across its operations. This approach is reflected in various documents (in French and English) including the Quality Management System Manual (dated 27 March 2020), which cross references a number of different procedures related to different aspects of Cediam operations (mango farmers, fresh fruit packing, and the processing facility). The specific elements of the framework are described in further detail in each of the sections below. Moving forward, the framework can be expected to be in compliance with this Performance Standard after addressing the action items as outlined in ESAP action #1.

Furthermore, Cediam has received the following certifications: 1) ISO 22000:2005 for food safety in the production of mango puree and concentrate (valid until 23 July 2021); 2) Certificate for organic production of concentrate, and puree under both the US National Organic Program and European and North America organic standard (last inspected on 19 May 2020) and valid until 31 March 2021; 3) Star-K certificate (valid until 30 April 2021).

Policy. Cediam has established an: 1) environmental policy, which reflects the company’s commitment to minimize its impact on the environment (specifically related to the management of waste) and comply with national legislation; and 2) food safety and quality policy, which reflects the company’s commitment to implement practices that ensure food safety (specifically related to monitoring water microbiology, pesticide residue testing, worker hygiene and sanitation procedures, and product traceability). Cediam also has an overarching environmental and social responsibility policy, which is posted at the facility and focuses on worker welfare, safety and labor rights, ethical behavior, protecting the environment, promoting local employment, and supporting the livelihood of local farmers and local communities. All policies have been signed by senior management. Per ESAP action #1, Cediam will consolidate and revise its policies into one overarching statement on the company’s commitment to environmental, health and security, food safety and quality issues.

Identification of Risks and Impacts. In accordance with Malian law, Cediam completed an Environmental and Social Impact Assessment (ESIA) for the processing facility in Yanfolila, which was approved on 28 May 2012 by the Ministry of Energy, Water, and Environment. As part of the approval for the existing processing facility, Cediam is engaged to implement the mitigation measures stipulated in the ESIA and undertake an environmental audit every 5 years to ensure the renewal of the environmental permit. This is pending and the company recently hired a local environmental consulting firm to undertake the audit. The company will submit the summary of the audit to IFC per ESAP action #2. Under Malian law, Cediam is not required to obtain water extraction permits (3 boreholes already at the existing processing facility) and the company is also engaged to report on a regular basis (for billing purposes) to the municipal authorities in Bougouni on the volume of water extracted. In the context of the ESIA of the processing facility, the company was required to obtain a separate wastewater discharge permit (from the Agence Nationale de Gestion des Stations d'Epuration, ANGESEM), which is responsible for oversight of wastewater treatment in Mali) for the processing facility, this point in under process. Cediam plans to do so and will submit the discharge permit to IFC per ESAP action #2.

Although not addressed in the ESIA, Cediam undertook additional implementation with identification of risks and impacts with a focus on food safety and quality as part of the process for obtaining various certifications as well as the types of incidents and emergencies to which the processing plant is exposed; the company is also aware of the potential risk of child labor and risk of conversion of Natural and Critical Habitats in the mango supply chain, which is already being partially addressed through Global GAP certification (see section below). The company completed a job risk analysis for mango farmers and is engaged to do so for workers at the processing plant, which it will be required to do per ESAP action #11.

Management Programs. As part of the ESIA of the processing facility, Cediam is engaged to implement general corrective measures for managing environmental and social aspects of operations in order to reduce impacts related to air emissions, water quality, and ambient noise and to monitor progress; however, Cediam did not systematically track implementation of these corrective measures in an environmental register. Based on the requirements of each of the Performance Standards described in the following sections, Cediam will implement and engaged  to develop additional management plans or further expand the scope of the plans listed in the ESIA.

Cediam’s Quality Management System Manual lists procedures that apply to its existing operations and address additionally identified risks and impacts. These include the following: complaint handling (from customers), product traceability, personnel hygiene, worker health and safety, emergency procedure, waste and pollution management, and pest management. However, the scope of these procedures varies and in some cases is duplicative as these were prepared within the specific context of certification requirements rather than being comprehensive across all of Cediam operations. Per ESAP action #1, Cediam will prepare an overarching EHSQ risk management framework, referencing the existing Quality Management System. This shall include: i) an overarching EHSQ policy including a social policy; ii) process for identifying risks and impacts across all company operations; iii) implementation of the Environmental Management Plan as identified in the ESIA, any additional aspects as contemplated under the principles of IFC’s Performance Standards (as identified in the ESAP), and any other requirements as contemplated under the certification standards; and iv) aggregated monitoring process of EHSQ parameters (such as energy and water consumption and efficiency; air emissions; solid and hazardous waste volumes and disposal; wastewater volume; injuries; community complaints, etc.) to track changes on a monthly/annual basis and assess the effectiveness of management programs in mitigating the identified EHSQ risks across overall company operations.

Organizational Capacity and Competency. Cediam has established an organizational structure that defines roles, responsibilities, and the necessary authority for implementing the company’s EHSQ framework. To this end, Cediam has designated a quality manager and an internal auditor with primary oversight for overseeing implementation of the system on a day-to-day-basis; their job responsibilities are described in the Quality Management System manual and they report to the plant manager who in turn reports to senior management (the project manager and the Managing Director, who approves all procedures and budget allocations related to EHSQ aspects of company operations). Additional responsibilities for human resources and worker welfare, outreach to farmers, and worker safety have been assigned to other staff who also directly report to the plant manager. Oversight of environmental aspects (such as water and electricity consumption, and waste disposal) related to the processing facility have been delegated to the production manager. During IFC’s site visit and based on discussions with key individuals, most staff were generally found to be knowledgeable of EHSQ aspects of operations. As per ESAP action #3, Cediam will develop an EHSQ unit and function with the company, including assigned responsibilities to staff or, as necessary, allocate additional staff for implementation of the tasks as reflected in the overarching EHSQ framework, including day-to-day oversight of activities and reporting related to the development and implementation of the EHSQ MS as well as Occupational Health and Safety officers at the processing plant.

Emergency Preparedness and Response. As part of the Quality Management System and under the oversight of the quality manager, Cediam has developed several procedures to be followed in the event of an emergency at the processing facility, which summarize the types of incidents to which the company may be exposed (ranging from power and water outages, fire, flooding to on-site intruders and suspected sabotage), the actions to be taken and by whom.

The facility is located 5 km from Yanfolila (the commune of Wassoulou Ballé) and does not have any immediate neighbors; thus, it does not pose a direct risk to communities due to these operations. The facility is built at the highest point of a sloping site such that all rain water drains downhill, away from buildings toward the main road (connecting Yanfolila to Bougouni) through a system of drainage trenches, at which point it is discharged into a ditch running parallel to the main road. This is effective to prevent the accumulation of rain water and consequent flooding of the facility; however there is a potential risk of flooding further downstream as the combined volume of rain water and waste water generated by the facility during peak production can exceed the capacity of the drainage ditch outside the facility. However, the company is aware of this potential hazard and has remedied this by further excavating the ditch outside the facility perimeter as well as a retention pond to slow down the flow of water at the onset of the rainy season.

Electrical faults in equipment (office and in the production lines) could pose a potential fire risk at the processing facility; however, equipment is regularly serviced and material (which would burn easily) is stored separately. The facility is equipped with fire extinguishers (approximately 20) at strategic locations, which undergo regular servicing through an external service provider as well as a network of 3 fire hydrants that are connected to a raw water storage tank (with a capacity of 50 m3). The nearest fire station is 75 km away in Bougouni. The company has prepared a map of the site showing the locations of all extinguishers and fire hydrants; however, there is possibility to implement signage to indicate emergency exits and meeting point in case of an evacuation nor are fire drills undertaken on a regular basis.

The emergency procedure specifies the implementation for training, posting emergency phone numbers in accessible and key locations, and first aid kits. Implement First Aid and emergency preparedness training is provided to some of the facility staff (6-7 permanent staff) for which records/certificates do exist; in turn, these staff provide training to daily workers (every Saturday) using visual training material and it was reported that a list of attendance is kept. The company will review and revise its emergency procedures to address gaps, per ESAP action #4. In the context of emergency scenarios for the processing plant, Cediam will ensure that adequate measures are taken and put in place to address potential flooding outside the facility perimeter wall and to address possible spills and contamination from above-ground fuel storage tanks as well as recruit an independent fire consultant to perform a Life and Fire Safety (LFS) Audit against the Malian fire safety code.

Monitoring and Review. Cediam has established procedures for monitoring EHSQ aspects of operations as required under its various certifications. This includes a clearly defined plan for regular monitoring and inspection of hygiene conditions at critical control points of the processing facility as well as overall conditions of the buildings and equipment.

Water and energy consumption are tracked separately as part of the production manager’s responsibilities and for accounting purposes rather than to set consumption reduction targets. The company also assesses water quality (both raw and treated water), which is done both by an external laboratory on an annual basis and also more frequently through the company’s on-site quality laboratory.

However, will be conducted an implementation process for monitoring and reviewing environmental, health and safety parameters to assess the effectiveness of efforts to manage identified environmental, health and safety risks across overall company operations; this is therefore required as per ESAP action #1.

Stakeholder Engagement. Cediam is well known in the region through its relationship with and support of local farmers through technical assistance, support for organic certification, and finance. The local radio is used to inform the communities about the harvesting season and crop information. While there is general support for the project, Cediam willing to continue its close engagement with surrounding communities throughout the project development and implementation phase to ensure that concerns are identified and addressed. Specific concerns and priorities for the communities include: (i) availability of water (see PS3 and PS4 for further information); (ii) expectations for youth employment; (iii) timely dissemination of information about the project; and (iv) health services and facilities. Youth employment is a key expectation from the surrounding communities, especially in the context of males migrating to other areas in search for better economic opportunities, in particular, in gold mining. With respect to the processing plant, surrounding communities identified a concern related to wastewater discharge and the potential risk of flooding (especially during the rainy season), potentially affecting the surrounding areas and damaging community farms and crops. Cediam willing to ensure that any risks related to overflow and flooding are appropriately managed (see the section above on Emergency Preparedness and Response).

Cediam will establish a structured program based on stakeholder mapping and informed consultation and participation as part of the Stakeholder Engagement and Communication Plan (SECP) as indicated in ESAP action #5. The SECP shall include the following key aspects: i) identify all key stakeholders (surrounding communities, local government, small farmers) in relation to the processing plant; ii) establish the method, frequency, and purpose for engagement in relation to each stakeholder group; and iii) provide a clear implementation and monitoring arrangement for the SECP. The SECP shall include steps to further engage with communities on particular issues of concern such as water, flooding, and employment opportunities. In addition, employment expectations are high from the communities and systematic engagement throughout the project implementation will be needed. Based on the stakeholder mapping, a differentiated engagement will focus on the traditional authorities, the surrounding villages, women’s and youth associations at the village level, and in close coordination with the regional and local governments. 

Grievance Mechanisms. To date and in the context of its existing processing facility, direct interaction between Cediam and nearby communities or the public has been limited to interacting with farmers who supply the company with mangoes. As the only major employer in the area, Cediam is well known and is easily approached by local communities if there are issues affecting them so they can be discussed collectively and agree on a common solution. Additionally, community grievances are communicated to Cediam through the local authorities (Circle Council of Yanfolila and Bougouni, including the Chamber of Commerce of Yanfolila) and through the traditional leadership when they are visited by Cediam. While there is a complaint procedure as part of the quality management system, the target audience of that is the customer of the company’s products. Cediam needs to provide for complaints from the villages and the general public to be received and for them to be reviewed and addressed. Relevant stakeholder groups and local communities will need to be informed about the updates and enhancements to the grievance mechanism. As per ESAP action #6, the mechanism shall also include the following: i) a tracking system for receiving, processing, documenting and addressing external grievances in a timely manner; and ii) assigned responsibilities for screening and assessing issues raised. The objectives and functions of the grievance mechanism shall be communicated to all stakeholder groups.

Cediam employed (via the external service Company SAER Société Africaine d'Etudes et de Réalisations) an average of 50 people at the processing plant (15 permanent employees and 35 who have a terms contract). Cediam also employs 4 people in Bamako. as well as 11 expatriates (10 at the processing plant and 1 in Bamako). In addition, an average of 350 seasonal workers are employed each processing season (April to June) with about 40-50 workers with term contracts covering the harvest season and about 300 employed as daily workers; about 85% of the workers are women. Cediam employs skilled workers on seasonal contracts as truck drivers processing plant/equipment operators, maintenance/electricians, and for tasks regarding procurement/logistics/shipping. These are renewed from one year to the next in the agriculture sector, which is allowable in the agricultural sector under Malian labor law (Law n°92-020 of 1992, article 20). Otherwise term contracts are only renewed twice. In addition, seasonal workers are employed largely during the harvest season for unloading mangoes from trucks (with mostly men undertaking the heavy lifting of creates management) and sorting and washing fruit (undertaken largely by women). 

All recruitment is managed by the administrative & HR manager in liaison with traditional leadership and local government. Per ESAP action #8, Cediam will develop an employment and capacity building plan to give employment priority to the surrounding villagers, and recruitment will be seasonal. Cediam will invest in training of local workers and support women in its workforce while enforcing strict control to avoid child labor.

Human Resources Policies and Procedures. Cediam has an internal regulation on human resources, which describes basic rules for employment, prohibitions, code of conduct including rules against sexual harassment and respectful workplace environment. This has been signed by Cediam’s executives and is displayed on boards around the facility. In addition, Cediam has a human resources management procedure describing steps to: (i) identify needed human resources based on the expected production for the season; (ii) allocate relevant tasks and assignments by training new staff on hygiene and safety measures; (iii) complete the relevant training through Cediam’s training and qualification program; and, (iv) verify the effectiveness of such trainings through interviews and audits. Cediam ensures equal opportunity employment and no hiring of people under the age of 18, but this is not clearly included as a specific policy or procedure. Cediam will update and strengthen its existing HR practices and internal regulation and develop a comprehensive HR procedures manual to apply to all categories of employment (permanent, temporary and seasonal) per ESAP action #7. The policy and procedures need to include the following: terms and conditions of employment; staff responsibilities, rights and benefits including working hours and rest time; over time, annual and sick leave and holidays; minimum wages; equality of treatment; freedom of association; prohibition of forced and child labor; termination of contract and dismissal; right for collective bargaining; workers representation; and mechanism for workers’ grievances accessible to all workers (permanent, temporary, and seasonal). The HR policy and procedures are to be accessible and clearly communicated to all workers (in French and local language as necessary) to ensure that employees understand their rights under national labor and employment law.

For permanent staff, Cediam has also outsourced the human resources responsibilities to SAER (Société Africaine d'Etudes et de Réalisations), an external employment agency, in charge of the recruitment process (following a preferential local hiring policy), which provides written contracts, handles pay, and registers workers with relevant authorities (for social benefits) for permanent (term and open-ended) staff only, including expatriate staff, who perform the company’s core functions. Cediam pays SAER a fee for the provision of the human resources administration and contract management. Cediam is also directly involved in the recruitment and selection of staff, and Cediam’s human resources policies and procedures are applicable to staff employed through SAER. For daily workers hired seasonally, Cediam manages until now the recruitment and contracts directly largely during the harvest season as most workers come from the surrounding areas and communities.

Cediam will formalize (with SAER) its human resources policy and procedures to also include seasonal daily workers as per ESAP action #7 to clearly inform all staff on the human resources policy and procedures, and to extend the same rights and responsibilities to the seasonal workers. Specific measures need to be considered for recruiting and training female workers as well as extending benefits in terms of sick and family leave, flexible working hours, access to health facilities. Women in the communities are mostly found in the low socio-economic status and they carry the domestic burden, in particular as husbands leave the communities searching for economic opportunities elsewhere. Clear rules around working hours and overtime, and guidelines regarding payment of overtime premiums need to be spelled out. As per ESAP action #8, a clear, accessible and transparent recruitment process, especially of seasonal daily workers, needs to be in place, including clear prioritization criteria for recruiting from the surrounding communities, especially youth. In addition, systematic and formal communication between human resources and the community relations officer should be established to ensure community employment expectations are managed in the surrounding communities.

Working Conditions and Terms of Employment. Written contracts (via SAER) are prepared for term staff (CDD, Contrat à Durée Indéterminée) and open ended staff (CDI, Contrat à Durée Déterminée), of which 24 are open-ended contracts and 77 are term contracts ranging from 3, 4, 6 and 12 months depending on the needed skills. A term contract also includes seasonal work and accommodates temporary and seasonal staffing needs. The open-ended and term contracts specify the employment duration (several months) with a possibility for renewal, paid leave of 2.5 days per month worked, a trial period (15 days to 2 months for a 3-month contract), identification of job grade and salary, including a breakdown of amount to be deducted for contributions to the national pension (ITS, Impôt et Traitement sur Salaire) and social security (INPS, Institut National de Prévoyance Sociale) from the staff and from Cediam. In addition, the term staff is entitled to a fixed travel allowance and other indemnities in the context of work trips. A specific clause for dismissal and employment litigation is included in the contract, and is signed by the prospective employee, Cediam, the labor inspector (Inspecteur du Travail), and the physician (Médecin du Travail).

Seasonal daily workers’ income ranges from CFA 1,650 to CFA 3,000 per day, which is in the middle or upper part of what is paid in the area. ITS and INPS are paid for seasonal workers as well. Monthly salaries range from CFA 60,000 (watchman), to CFA 75,000 (driver), CFA 100,000 (mechanic) and even CFA 300,000 (qualified administration job) hired under term contracts for specific duration.

During the busiest season (May – July), there is an average of 300 people employed in the processing plant and they work in 3 shifts of 8 hours each. There are about 80 women and 30-40 men in each shift. Seasonal workers are recruited on an ad-hoc basis depending on current needs and are payed on a weekly basis. All workers are issued an “attendance” card to reflect the hours worked and their age. Seasonal daily workers will need to have  (via SAER) a written contracts to have a better understanding of their employment terms and conditions per ESAP action #8. All workers are required to go through a medical check-up as part of the recruitment process and if a prospective worker is tested positive for tuberculosis, a contagious disease, skin diseases, eye and ear infections, he or she is not recruited.

Every year, a representative from the Mali Labor inspectorate comes to inspect the facility and measure indoor lighting and noise. To date, Cediam has not received any negative findings. Transport is provided to the workers between the processing facility and Yanfolila. There is no on-site canteen at the processing facility for the workers. Workers who do not bring their lunch to the facility need to go to Yanfolila on a bus provided free of charge by Cediam. Worker facilities at the processing plant entail basic changing rooms with lockers and a staff dispensing the necessary protective equipment and blocks of toilets and showers, separate for male and female workers. Per ESAP action #8, Cediam will prepare a plan to upgrade these facilities and ensure these are sufficient for the number of workers present on site. Specifically, adequate lavatory facilities (toilets and washing areas) should be provided for the number of people expected to work at the processing facility, including allowances made for segregated facilities, or for indicating whether the toilet facility is “In Use” or “Vacant”. Toilet facilities should also be provided with adequate supplies of cold running water, soap, and hand drying devices as per the WBG EHS and COVID 19 Guidelines.

Workers’ Organizations. Cediam workers select their own representative delegates among themselves through elections every year with a total of 4 delegates for the processing facility. The elected delegates’ names are disclosed on Cediam’s office board and participate in discussions regarding pay, contracts and also grievances. Seasonal workers are not represented by the elected delegates, which means that there is no formal channel to raise issues such as pay increases and terms of employment. Cediam will support a mechanism for which seasonal workers’ representation of their issues and concerns can be done in an organized manner per ESAP action #9.

Grievance Mechanism. Cediam does not have a formal written process to resolve workers’ grievances, aside from directing workers to the designated delegates for raising any issues before it is presented to management. The names of the delegates are posted on Cediam’s information boards around the facility. Female workers are instructed to reach out to specific female workers to discuss and potentially resolve grievances. Cediam will design and implement a grievance mechanism accessible to all workers regardless of their types of contracts to ensure that a formal grievance process is followed as per ESAP action #10. This will need to include i) procedures for documenting, managing, and monitoring their resolution; ii) involvement at appropriate level of management (including designated staff and accountability); iii) clear and timely management of grievances; iv) allow for anonymous complaints to be raised and without fear of retribution; and v) inform access to other judicial and regulatory mechanisms available under the Mali law for workers. The mechanism shall be accessible by all workers, including temporary and seasonal workers, currently not represented by the elected delegates. Cediam shall inform all workers about the objectives and procedures for the workers’ grievance mechanism. Cediam will inform its staff and workers about the grievance mechanism and how it operates.

Occupational Health and Safety. Cediam has appointed the administrative & HR manager for oversight of workers’ health, safety and welfare. Today however there is no OHS committee nor systematic process for analyzing OHS risks to workers across Cediam operation and tracking injury rates. Cediam has a procedure for workers’ health, safety and welfare (specifically for mango farmers and fresh fruit handlers), which includes a risk assessment matrix to identify types of hazards, likelihood of risk, and how to mitigate the risk through a combination of hazard signs, employee training on hazards, and use of personal protective equipment (such as gloves, face mask, and rubber boots). Cediam also has a work instruction on personal hygiene for workers at the processing facility with a focus on verifying the health condition of workers (absence of rashes, cold/cough/sneezing, cuts/wounds, eye/ear discharges) at the start of each shift as well as a procedure on hygiene, behavior and training, which outlines the requirements for washing hands and wearing proper apparel during the shift. Some signage related to quality and food safety (such as use of required PPE, hand washing, and prohibited behaviors) was noted around the factory. Although much of the mango processing at the facility is undertaken by machines (such as removing skin/peeling, removing stone, and pulping), nonetheless tasks such as handling mango crates, cutting out impurities from fruit, and walking on wet surface may present an OHS risk to workers, which is currently not addressed through OHS procedures.

General awareness training on hygiene and worker safety was reported to be undertaken each year at the start of the processing season, followed by weekly reminder meetings. However, Cediam wish to improve a formal, comprehensive annual training plan designed to address the risks associated with its operations although training needs (related to food safety, OHS, and First Aid) are mentioned in various procedures. Furthermore, only limited evidence of attendance records was available for review although Cediam’s procedures specify the need for maintaining records. Despite the fact that Cediam contributes annually through its taxes to a national training fund for the private sector in Mali (as per the law), the company has not been able to benefit from this fund as the relevant government authority is unwilling to use the funds to partially cover the costs of an external trainer identified by Cediam to best meet its training needs. As per ESAP action #11, Cediam will undertake a job risk analysis across all company operations, develop the necessary procedures reflecting the OHS measures in place, including implementation of a training plan.

The emergency procedure outlines the steps to follow in case of an accident or injury, including informing a Cediam representative and documenting the occurrence of the injury. Cediam reported that First Aid kits are available in key locations (including in trucks) and that there is a person on site who has been trained by a medical doctor to provide first assistance in case of minor injuries and workers feeling ill. Furthermore, in the event of an accident, Cediam transports the injured or ill person to the nearest hospital (Yanfolila).

Supply Chain. Mali is among the West African countries with the highest occurrence of child labor, which is the most prominent in the agriculture sector. Although the Sikasso region is believed to have the highest prevalence of child labor, there are typically no children involved in mango production given the height of the trees from which mangoes are picked. The involvement of children, if any, is typically for keeping potential livestock away from orchards rather than activities such as carrying heavy crates to collection points.

Cediam purchases mango from a network of over 2,000 smallholders in the Sikasso region and plans to further increase the volume purchased with the proposed project expansion. Among these smallholders, 21 farmers currently already fall under the Global GAP certification program, which has strict requirements to prevent child labor. Moving forward, Cediam would like to increase the number of certified farmers and will work with a number of farmers each year that have expressed willingness to take on board the principles considered under the Global GAP program. Cediam establishes written buyer contracts with smallholders annually, committing the company to buy a farmer’s entire crop for the season, but does not have a supplier code nor specifications in the contract regarding child labor (as this is already considered under national law) or good agricultural practices. As per ESAP action #12, Cediam will develop a supply chain management system including a responsible sourcing policy with targets over time to increasingly source primary production from suppliers that are adhering to good agricultural practices as specified in a supplier code (including to avoid harmful child/forced labor, prevention of life threatening situations from an occupational health standpoint, and avoid expansion of existing plantations within areas of Natural or Critical Habitats), and, over time, that have received Global GAP certification

Energy and Resource Efficiency. Cediam operations (processing facility) are primarily powered by electricity from the national power grid, which for the most part is reliable except for occasional power outages during the rainy season (May to October). There are 2 backup generators (1000 kVA and 769 kVA), which are used primarily during the rainy season when power outages occur (typically in 30-minute duration). In 2019, the total energy consumption was 270,000 kWh corresponding to 3 months of production (April to June). The largest energy needs are the ripening chambers (to operate the fans), the various parts of the processing plant (to operate equipment), air conditioning, followed by water pumps at the boreholes and lighting. There is one boiler used for generating hot steam and hot water used as part of the production process (to provide heat treatment for product sterilization) and for cleaning, which is powered with heavy fuel.

Additionally, the company uses significant volumes of local wood to manufacture single use palettes (6,000 palettes annually with current production volumes, equivalent to 66,000 kg of wood) for the purpose of packing and shipping finished product containers. Wood is sourced locally from a supplier in Bougouni from naturally growing trees and assembled by Cediam employees into palettes. Cediam is currently exploring options to cultivate a fast-growing tree, (Gmelina arborea, known as beechwood, non-native but commonly found in Mali) to create its own supply of wood and thus reduce pressure on local trees.

Water Consumption. As a country situated in the semi-arid climate of the Sahel, Mali has been severely affected by past droughts and a generally decreasing trend in rainfall. Furthermore, surface and ground water are threatened by pollution, sedimentation, and mismanagement leading to degradation and overconsumption. Southern Mali, where the proposed project site is located, is characterized by the Soudanese climate with annual rainfall occurring mostly during the months of May to October with a minimum of 90 days of rain per year and the average annual rainfall for Sikasso is estimated to be 1,122 mm. There is no surface water at the site but along both the eastern and western side of the site, there are natural drainage depressions toward which water flows especially during rainy periods (June to October). Water drains toward the northwest into an (unnamed) west-flowing tributary (approximately 6 km from the site) of the Ouassoulou River, which in turn, flows to the north (north of Yanfolila) into the north-flowing Sankarani River before it is dammed at Selingue Dam. The site falls within the superior Niger catchment.

At the processing plant, Cediam sources all water via 3 on-site boreholes; raw water is then stored in an above ground storage tank (with a capacity of 50,000 liters) prior to being treated (chlorination using 1 ppm, filtering, and UV treatment for water used in processing) to potable water quality level, which is stored in an another above ground storage tank (also with a 50,000-liter capacity). The raw water storage tank also serves as the reservoir connected to the fire hydrants (see section above). Cediam currently uses approximately 16,200 cubic meters of water per year. Water is primarily used for washing (fruit, crates, and factory floor) prior to processing, generating steam and creating condensate, regular cleaning of the facility, and to irrigate the nursery at the processing facility. Water is also used for washing trucks and for cooling in the ripening chambers. The company uses clean-in-place (CIP) practices for cleaning equipment, which reduces water consumption.

Cediam’s normalized water consumption rate was approximately 1.5 cubic meters per ton of fruit processed.

In addition to Cediam’s processing plant, the only (known) and current local groundwater use in the area is as a domestic supply for surrounding settlements. According to the SIGMA (Système informatique de gestion des ressources en eau du Mali) database, originally set up in 1985 and used for the preparation of a Master Plan for the Exploitation of Groundwater Resources in 1991, which was last updated in 2014, 564 wells were identified in the Sankarani aquifer; however, only 396 are considered to be productive wells. The well density around the site is estimated to be 60 groundwater wells per 1,000 km2 of the aquifer, which is considered to be low as a result of the relatively low demand for water from sparse village populations. Almost all identified boreholes target the basement aquifer and thus abstraction for domestic water supply is not only from the shallow aquifer through traditional wells. The location of the boreholes generally coincides with the locations of identified settlements (1 borehole per settlement) although several villages exist for which no boreholes are listed. These villages likely use groundwater-fed springs or artisanal wells targeting the shallow aquifer.

Cediam has a water policy, which does acknowledge that water is an important resource in Mali, the focus of the water policy is on managing water quality to ensure food safety and quality of product rather than on water usage and conservation measures. Relevant authorities analyze water quality every year but have never shared their findings/conclusions with Cediam. Instead, Cediam internally undertakes their own water analysis of process water at various points (microbial and chemical) and also requests an analysis once a year through an external contractor to confirm their own findings. As per ESAP action #13, Cediam will implement and develop a water management plan for the processing plant to: i) monitor water use by the project as well as availability of water resources to meet both project and local community demands; and ii) identify opportunities for reducing water consumption (such as use of recycled waters (if quality permits).

Air Emissions. The main source of air emissions across Cediam’s operations are from the boiler (estimated 3,900 kW), the fleet of 17 trucks, fugitive emissions of ethylene gas (used in the ripening chambers), and operation of the back-up generators (only during power outages, used on average less than 500 hours per year). There is no process for monitoring air emissions or recording hours of operations of the back-up generators but a maintenance plan is in place. Ethylene gas is used in the 8 ripening chambers in combination with forced ventilation (which also reduces the risk of asphyxiation of workers) and air flow evaporators, which are all equipped with sensors to monitor the temperature, relative humidity, ethylene and CO2 concentrations. As per ESAP action #14, Cediam will implement a written maintenance plan for the generators and the boiler to ensure that they are regularly serviced to ensure that the quality of air emissions is consistent with WBG guidelines for point source emissions to air. Furthermore, Cediam wiling to keep a log of hours of operation of the generator such that if the generators are operated for more than 500 hours per year, Cediam shall conduct air emissions measurements at the stack and compare parameters with WBG General EHS Guidelines for ambient air concentrations (particulate matter limit (PM10) of 50mg/Nm³; NOx of 460 mg/Nm³; SOX of 2000 mg/Nm³. If measurements exceed WBG limits, Cediam will propose corrective measures and plan to bring all emissions into compliance with WBG limits. Annual GHG emissions are estimated to be 757 tons of CO2 equivalent.

Wastewater Treatment. Cediam’s processing facility generates significant volumes of wastewater primarily from washing fruit, rinsing crates, steam generation, and cleaning factory floors. A smaller volume of wastewater is also generated from the evaporation process during the production of concentrate. Cediam has installed a wastewater treatment system, which consists of a series of 3 interconnected water basins (for sedimentation, active charcoal and stone filtering, and second filtration through porous substrate), which discharge into a ditch that follows the natural slope of the facility to the perimeter wall, where it drains to another ditch outside the facility. Rainwater commingles with process water and as mango processing occurs primarily during the rainy season, this tends to accumulate in areas outside the facility perimeter and has caused flooding of areas further downstream (see section below). Sanitation wastewater (employee toilets and showers) drains to an on-site septic tank, which is emptied as necessary by an external contractor. The management of wastewater is referenced in Cediam’s waste management procedure but the company does not test the quality of the effluent prior to discharge into the drainage ditch, which the company will be required to do per ESAP action #15.

The company plans eventually to upgrade, in case of necessity, the wastewater drainage area outside the facility’s boundary by creating a water retention pond to reduce the risk of potential  flooding further downstream as well as plant vegetation to further improve the quality of the wastewater.

Solid Waste Management. Cediam has a waste management procedure, which states the company’s commitment to reduce the impact of its operations on the environment through proper disposal of its waste streams. The following waste streams were identified at processing facility level: organic waste from production, bags and containers (plastic, metal), defective packaging waste, used lubricants (grease, oil, and solvents), and liquid waste with basic systematic process in place for tracking volumes generated at the company level. Per ESAP action #16 and building on the ESIA requirement to develop a Waste Management Plan, Cediam will revise and further expand the scope of its existing waste management procedure for all waste streams, including proper handling and storage (in dedicated bins), record-keeping on quantities, and work to identify alternatives for disposal such as recycling (for example, for glass, metal, plastic and paper).

Cediam operations generate primarily large volumes of organic wastes (in the form of pits/stones and peels from the mango, estimated to currently represent 35% of the total raw material input), which is disposed of on a daily basis through an external service provider (Elephant Vert) for use as compost in agriculture throughout the country (approximately average of 1000 metric tons). Company operations also generate a limited quantity of office waste (paper) and packaging material (plastic, cardboard, empty containers, and defective product packaging), which is removed on a regular basis by an external service provider and disposed of at a site designated by the municipality.

Hazardous Materials Management. Cediam uses the following types of hazardous materials in its operations: i) large quantities of diesel (to fuel vehicles and for back-up generators when in operation); ii) large quantities of heavy fuel (to power the boiler); iii) limited quantities of caustic soda (for clean-in-place process), iv) pesticides (currently only used on-site for the facility’s own vegetable garden), and other inflammable materials. Diesel is stored on site in a 50,000-liter, above-ground storage tank with the necessary secondary containment structure, capable of containing more than 110 percent of the tank volume in the event of a leak. In the event of an overflow, the secondary containment is connected to a separate retention tank, which is equipped with an oil/water separator. Heavy fuel (fuel 180) is stored on site in 3, 50,000-liter, above-ground storage tanks, on a concrete base but currently without a secondary containment structure to prevent potential spills from spreading. Limited quantities of chemicals are stored on wooden crates without secondary containment in a dedicated area of the warehouse, which is also used for storing primarily empty packaging material. The company in future will ensure that hazardous materials are adequately stored with measures to prevent and contain spills as per ESAP action #17.

The company currently owns 15 trucks and a few other vehicles (cars and motorcycles), which are all maintained on site in a dedicated workshop area. For the most part, maintenance such as oil changes and used oil, oil filters, and batteries are temporarily stored on site prior to removal by an external service provider who in turn sells the waste products to locals for reuse. The company will develop the Hazardous Materials Management Plan per ESAP action #17.

Pesticide Use and Management

Since 2013, the company has financed and managed broad treatment against the fly using pheromone traps over an area of 1,400 hectares (involving 3,400 farmers), which are effective and help preserve the organic features of cultivations. Furthermore, the company has used and introduced Good Agriculture Practices to local farms to promote sustainable farming techniques without pesticide applications.

Cediam has a pest control and prevention procedure, which applies to the processing plant to fight insects and rodents. This entails an integrated management approach of maintaining a clean environment inside the facility (by preventing the accumulation of organic matter and removing all waste immediately), preventing entry (screened windows and keeping doors/windows closed; monitoring and repairing all potential cracks in walls; and keeping clear of vegetation the exterior of the factory. Pest control devices include the use of glue-based traps, UV fly killers, and mechanical traps inside the factory and traps with poisoned bate are only used outside. Cediam maintains the MSDSs of all the products used and undertakes regular monitoring of traps to identify early on the potential need for more aggressive treatment

Food Safety Impacts and Management. As stated above, activities at Cediam’s processing facility are performed in accordance with the principles and practices of Hazard Analysis Critical Control Points (HACCP). This reduces the risks related to hygiene and food safety and mitigates potential impacts to the community. As part of HACCP requirements, the design of the processing facility is organized such that products move from “dirty” to “clean” areas to avoid contamination and the packaging of the finished product is done through automated filling machines, thus removing the potential for contact between workers and the finished product. Procedures are in place for ensuring the daily cleaning of equipment; all staff receive awareness training on food safety issues and have been issued the necessary work clothes (clothes, gloves, and hair coverage).

Cediam has an on-site laboratory for undertaking daily microbial and chemical analyses of product samples (puree and concentrate), which are logged according to batch code numbers and kept in case of a product recall. Cediam has procedures for product traceability to quickly identify and recall a product in case it does not comply with the company’s standards. According to the procedures, this process is tested once a year in the event of both a contamination of the raw material and in terms of the finished product such that the issue can be fully contained within a 4-hour timeframe.

Transportation Safety. Vehicle traffic currently peaks during the mango season and entails the movement of trucks between smallholders and the processing facility to transport by road containers of finished product to the ports of Dakar or Abidjan, respectively. Cediam uses a combination of its own trucks and drivers and the services of externally contracted drivers.

The company willing to improve a specific policy or procedure in place for ensuring the safe operation of vehicles (for example, screening drivers and providing formal training on safe driving) nor for documenting incidents and accidents involving road traffic. However, Cediam reported that at the start of each season, an external provider provides awareness training on safe driving including the need to respect speed limits, not using a cell phone while driving, and how to use a fire extinguisher. The company willing to develop a Traffic Management Plan as well as procedures for the safe operation of vehicles per ESAP action #18. This will include driver safety training to emphasize the following: driver skills, 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.

Security. The processing facility is surrounded by a 2.5-meter high, concrete perimeter wall and Cediam employs its own on-site guards, which primarily interact with the workforce and are responsible for access control and verification of people entering the site. Cediam currently has a security procedure for the processing plant, which describes: (i) security responsibilities of all Cediam staff though it is unclear if this communicated to the seasonal workers; (ii) requirement to conduct annual security assessment but this is not done as often in practice; (iii) steps to patrol and monitor the processing facility perimeters, including a basic arrangement between the Cediam guards and the national guard personnel; and, (iv) other security measures involving Cediam staff, access control, data management and equipment.

In addition, Cediam has a service contract with the national guard (local garrison in Yanfolila) to provide additional security (3 people who are armed) at the processing facility, who are responsible should a conflict or a theft occur. The national guard personnel have clear procedures and a code of conduct on the use of force as the last resort in the event of a conflict, and they maintain a good relationship with the communities in the area. However, CEDIAM willing to implement the security protocol and procedures are in place between Cediam guards and national guard personnel to clarify the roles and steps to take in the event of a strike, social conflict, or disruptions. Cediam willing to provide adequate training through a qualified expert on security procedures and human rights principles, in coordination with the national guard personnel.

In a broader context, security in the region has been ramped up due to its proximity to the borders with Guinea and Cote d’Ivoire, and the presence of the local garrison has contributed toward maintaining peace and order

  Supply Chain

Cediam currently sources mangoes from more than 2,000 independent farmers in the region (representing about half of Cediam’s overall procurement) and works with 40 cooperatives (each with approximately 35 members) located in the Sikasso and Koulikoro regions. These are existing mango plantations and the conversion of further Natural or Critical Habitat is considered low to zero. These regions fall under the umbrella of the national program to fight against the mango fly and many of the smallholders have benefitted from the installation of pheromone traps (see section above), which are effective and help preserve the organic features of cultivations although these are not certified as such. Furthermore, Cediam has worked with farmers (approximately 45% of its total supplier base) to introduce good agriculture practices (for example, good hygiene, absence of child labor, proper fruit handling, regular pruning, and orchard maintenance activities) to promote sustainable farming techniques, which do not require pesticide applications. Among these suppliers, a subset of 21 farmers (representing 199 hectares and approximately 42% of Cediam’s overall supply) have been included as part of Cediam’s Global G.A.P. certification and these farmers are paid a premium for organic fruit (which is sold as fresh fruit and currently packed at the Bougouni site). Cediam plans to increase the number to 100% of smallholders that are Global GAP certified. Although Cediam will grow its own mangoes, the company will continue to source mangoes from the existing supplier base in order to meet the capacity requirements of the additional processing line. The company maintains a procurement log book to identify the procurement of mangoes by smallholder (and thus keep separate the organically certified fruit) and has a system in place allowing for traceability of Global GAP certified mangoes. As per ESAP action #12, a supply chain management system will be put in place to monitor expansion of existing plantations from which primary production is sourced to ensure that these do not entail the conversion of Natural or Critical Habitats. Global GAP certification is assumed to be an indicator of areas at low risk of Natural or Critical Habitat conversion

Contact Person: Mr. Francesco Caponetti

Company Name: Cediam SA

Address: Quartier du Fleuve, Route de Farako, Place de la Nation, Bamako, Mali

Email: f.caponetti@montecarlofruit.com

Phone/Facsimile: +223 20.22.08.35