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 existing plant is located on land acquired through a willing buyer willing seller transaction, and the new plant will be located on a land leased for a 30-year period owned by an existing company, therefore Performance Standard (PS) 5 (Land Acquisition and Involuntary Resettlement) does not apply. The project is to be constructed in modified habitat in an industrial zone where there are no Indigenous Peoples and there is no known cultural heritage in the area. Therefore PS 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), 7 (Indigenous Peoples), and 8 (Cultural Heritage) are also not applicable.

This proposed investment is an Environmental and Social (E&S) Category B project according to IFC’s Policy on Environmental and Social Sustainability because potential adverse environmental or social risks and/or impacts are limited, few in number, site-specific, largely reversible and readily addressed through mitigation measures. Key environmental and social risks and impacts during construction include occupational health and safety, dust emission, noise, and vibration from vehicle transit and earth moving activities as well as the potential for soil erosion. These impacts are expected to be temporary and will be minimized via implementation of the construction environmental and social management plan. Key risks and issues associated with operations relate to environmental and social management, occupational health and safety (OHS), management of hazardous and non-hazardous wastes, noise, volatile organic compound (VOC) emissions and particulate matter, Life and Fire Safety and emergency preparedness and response. Food safety management for packaging material also needs to be considered.

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



Simpa in Senegal was certified against ISO 9001, a quality management system; The facility will be re-audited in 2016 with the intention of again being certified against this standard. The quality management system includes procedures related to client’s needs, complaints management, internal audits, quality assessment of suppliers, European and West African Economic and Monetary Union regulations compliance, laboratory testing, etc. Simpa is also in the process of obtaining certification against the ISO 14001 environmental management system (by end of 2016) for the Senegal facility.

For the existing facility, Simpa has an Environmental and Social Management System (ESMS) which is partially aligned with the requirements of the Performance Standards. Simpa has a policy (described below) that indicates who within the organization is responsible for implementation of the system. The company generally identifies risks and impacts of new projects through an Environmental and Social Impact Assessments (ESIA). However this needs to be strengthened via a detailed risk and impact identification process at the workstation level and by the development of related management programs/procedures for environmental aspects, occupational health and safety, and fire safety. More details on requirements are provided in the paragraphs below.

For the new plant in Cote d’Ivoire, Simpa will develop and implement an ESMS in line with IFC’s Environmental and Social Performance Standards. As outlined in the ESAP (action #1a), the ESMS will incorporate the following elements: (i) a policy that will indicate who within the organization will ensure compliance and be responsible for its execution; (ii) identification of risks and impacts; (iii) management programs/procedures for environmental aspects, occupational health and safety, and social aspects; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) monitoring and review; and (vii) a community grievance mechanism in order to manage communication with customers and outside communities.

Policy



Simpa has an EHS and HR Policy. The EHS Policy includes provisions related to the ESMS, compliance with laws and regulations, internal and external audits, assessment of EHS issues at design and operations phase, pollution prevention, communication, and responsibility. The HR Policy is described under PS 2.



Identification of Risks and Impacts



An environmental audit of the existing Senegalese facility was prepared by a local consultant in 2015. Main recommendations identified in the audit include the following: collection of vapors through air extractors and subsequent treatment of gas stream by removing VOCs is required; hot temperatures in permanent work environments should be avoided through implementation of engineering controls and ventilation; need to set up a circulation plan and adequate signage, and improve evacua
tion routes; development of a waste management plan; improve enforcement of PPE use; and build secondary containment for all hazardous materials. For the new facility in Cote d’Ivoire, an Environmental and Social Impact Assessment will be developed as required by Ivorian law (Decree 98-43 of 28 January 1998).



Management Programs



Simpa has procedures in place for the following aspects: PPE rules, training (first aid, fire prevention, employee induction), and accidents. As outlined in the ESAP (action #1b), for all future developments, a construction phase Environmental and Health and Safety Management Plan will be developed by the EPC contractor; in addition the contractor will have a full time EHS Officer on site.



For the operational phase of the existing facility Simpa has only a few procedures and is yet to develop its management programs for OHS and environmental issues. As indicated in the ESAP, the following procedures will need to be developed and implemented (action #1c): workplace monitoring (e.g., emissions, noise, heat stress, and illumination), hazardous and non-hazardous waste management; management of noise, management of volatile organic compound emissions and particulate matter; Life and Fire Safety; food safety for packaging material; emergency preparedness and response; external communications; monitoring and reporting. Such procedures will equally be part of the ESMS to be developed for the new facility.



Organizational Capacity and Competency



Simpa recently hired an EHS Manager to assist with development of the EHS management program. A training framework and an action plan was drafted including that related to EHS issues, Life and Fire Safety, first aid, evacuation drills, hazardous materials storage, accidents reporting, waste management, PPE. A Quality Manager is implementing the quality management system. The company currently has an organizational chart that does not include the EHS position and thus Simpa will amend the chart such that this position reports directly to senior management. As set forth in the ESAP (action #1d), a suitably qualified EHS Officer will also be hired at the new plant.



Emergency Preparedness and Response

Simpa has developed an emergency preparedness and response plan to be validated by local authorities. Major risks include fire and explosion, and hazardous materials spills. The proximity of other industrial facilities induce other emergency scenarios to consider such as ammonia leakage from neighboring plants. To be in line with requirements of PS 1, as set forth in the ESAP (action #1c), the existing emergency plan should be strengthened to include the following aspects: coordination and communication with other neighboring facilities, roles and responsibilities, interaction with authorities, regular drills, decontamination procedures, etc. Evacuation routes should also be improved. Equally, the ESMS for the new plant will include an emergency preparedness and response pla
n.

Monitoring and Review

The company has established a draft E&S monitoring and reporting program. Some parameters are regularly monitored such as PPE use, and noise levels. Under the ESMS, Simpa will adopt a structured EHS monitoring and reporting system on environmental, OHS and social impacts of its operations. Monitoring frequencies and methodology will be reflective of the risks and impacts and incorporated into the ESMS; monitoring data will be stored in a centralized database for monthly and annual report production. Simpa will also incorporate Key Performance Indicators related to its activities in order to be able to report upon E&S performance: a) Safety – Lost Time Injury Frequency Rate, Accident Free Days; b) Resource Efficiency – water usage, energy usage, solvent consumption, etc.; c) Staff - Retention and training days, d) Air Emissions (VOCs, particulate matter), and temperature in the workplace. The company will report annually to IFC in relation to any impacts affecting them and associated mitigation measures. These monitoring requirements will apply to the new plant as well.

Human Resources Policy and Procedures



The company has 440 full time employees, and in any given month hires up to 430 daily workers. Third party contractors are mainly hired to carry out construction and maintenance works. Every full-time employee has a contract registered at the “Inspection Régionale du Travail et de la Sécurité Sociale de Dakar” (Labor Ministry). The company is in compliance with the local labor code governed by a commerce convention, which defines the various work categories, employee benefits, as well as minimum salary to be paid for each type of work. The company contributes to social security and both the client and full time employees contribute to the ‘’Institut de prévoyance médicale’’ (medical insurance for employees and his/her family) as well as to the Caisse nationale de sécurité sociale’’ in case of work accidents. In addition, there is an optional private medical insurance for employees subsidized by the company. In Senegal the minimum age for work is 15 (although harmful work is not legal under 18) and in Cote d’Ivoire, it is 14 years. Simpa is not hiring anyone under the age of 18 years. There is a grievance mechanism but the existing HR Policy (‘’Règlement intérieur’’) does not cover all types of workers; it also lacks provisions related to non-discrimination and equal opportunity, and prohibition of forced and child labor.



Construction works for the new plant in Cote d’Ivoire entails the creation of 150 jobs for about one year; all employees will be hired via the EPC contractor; operations will involve 200 workers. As set forth in the ESAP (action #2a), to comply with the requirement of IFC’s PS 2, Simpa will enhance its existing approach to HR for the facility in Senegal to ensure compliance with the Performance Standards and specifically include issues related to policies regarding non-discrimination and equal opportunity, and prohibition of forced and child labor amongst others. In addition, the procedures will also ensure the management of contract labor including daily workers aligns with the requirements of this Performance Standard, including that related to OHS management. Equally as it relates to the new facility the company will also develop and implement HR policies and procedures aligned with the Performance Standards (for permanent and contract employees alike) including but not limited to the following provision: working relationship; working conditions; terms of employment; non-discrimination and equal opportunity; grievance mechanism; prohibition of child and forced labor; and occupational health and safety. Once the policy / procedure has been updated for the existing facility this will be communicated to all employees. For purposes of construction the company will ensure that the EPC contractor complies with national requirements, and that all employees have written contracts and they have access to a grievance mechanism.





Workers’ Organizations

As per local labor laws and r
egulations, current employees have the right to freedom of association. Employees are unionized and affiliated to the CNTS (‘’Confédération des travailleurs du Sénégal’’) and CSA (‘’Confédération des syndicats autonomes’’). There are 16 workers representatives at the Simpa facility in Senegal. According to the labor law, workers representatives have the following tasks: ensure that workers grievances are communicated to management and to the Labor Ministry; ensure implementation of OHS preventive measures; propose measures to improve work organization and productivity; and opine on potential retrenchment. The Ivorian labor law has similar requirements that will be enforced at the new plant.



Occupational Health and Safety



In order to minimize OHS incidents, Simpa provides PPE such as ear plugs, foot wear and gloves. During the site visit, IFC observed that not all employees were wearing adequate PPE (e.g., loading of trucks without protective footwear). Noncompliance with PPE was more prominent with subcontractors, and daily workers. Heat stress is a concern through most of the facility as are VOC and particulate matter emissions. There is also no clear approach to safety and associated movement of vehicles / rolling stock on-site. Pavement markings for workers safety also need to be improved. Simpa records accidents for the purpose of reporting to the social security services. An OHS committee was set up in March 2015 and is composed of 6 members (Plant Manager, Doctor, Quality Manager, EHS Manager, and 2 workers representatives). The committee meets once a month, inspects each workstation, prepares a report including preventing measures and proposes an action plan. The number of minor injuries is high (>200 in 2015), though only one major accident occurred in the last 6 years. There is a clinic on site.



Given the number incidents and to be in line with requirements of PS 2 related to adequate OHS management, Simpa will conduct a third party OHS audit for the existing facility in Senegal and this will include workplace monitoring associated with heat stress, exposure to VOC’s and particulate matter emissions, lighting and noise, and review the approach to machine guarding and traffic safety (action #2b). In addition, gaps will be defined relative to the existing OHS systems and that as aligned with the requirements of the Performance Standards; thereafter the client will agree with IFC on a time based plan to implement actions to address the gaps identified including the findings associated with the environmental audit as referenced under PS1. Similarly, following commissioning of the new plant, an OHS audit will also be undertaken to assess project compliance relative to the Performance Standards requirements / accepted industry practice; thereafter and based on the audit findings the client will agree with IFC on a time based plan to implement the recommendations of the audit.



During the site visit at the construction site, main
observations related to absence of PPE for a number of workers, and the person responsible for EHS did not have clear procedures to implement. Thus as defined in the action plan for purposes of construction of the Cote d’Ivoire facility, an OHS management system will be developed and implemented as part of the Environmental and Health and Safety Management Plan described under PS 1. The client will also implement engineering controls and ventilation to avoid high temperature in the work environment.



Simpa intends to provide workers accommodations for about 20 workers during construction of the Cote d’Ivoire processing plant. Simpa will ensure that standards for workers’ accommodations will be compliant with the IFC and the European Bank for Reconstruction and Development Guidance Note on Worker Accommodation Process and Standards (2009).



Supply Chain



The existing plant in Senegal uses approximately 200 t/month of recycled plastic out of a total of about 1,300-1,500 t/month. Recycled plastics is sourced from two main suppliers, who provide 90% of the material. The rest is sourced from about 10 smaller suppliers. Most suppliers source their raw material from approximately 2,500 collectors who obtain used plastics from the municipal landfill. Collectors may use children for collecting, sorting, or washing used plastics. In order to mitigate any potential incidence of harmful child labor in its supply chain, as set forth in the ESAP (action #2c), Simpa will adopt a management procedure for its supply chain, which will include the development and implementation of a Supplier’s Code of Conduct which will be mainstreamed into its contractual agreements with recycled plastics suppliers. This Code of Conduct will include provisions against child and forced labor in line with requirements of PS 2. Simpa will monitor full compliance with the provisions through regular visits in the field and awareness raising of suppliers. Suppliers will also be mapped by levels of risks. Where remedy is not possible, the client will shift primary supply chain to suppliers that can demonstrate that they are complying with this Perfomance Standard. Results of visits and mapping should be reported in the Annual Monitoring Report (AMR).

Resource Efficiency



At the Senegalese facility, energy is provided by the national grid and four back-up generators (4 X 1,000 kVa) supplied via a 10,000 L and 15,000 L diesel tank respectively; both of these do not have secondary containment. Approximately 18,000,000 kWh of electricity are consumed annually. Simpa owns 10 trucks (10 tons) and maintenance is not carried out on site. Annual GHG emissions of the existing operations are estimated at around 12,000 tonnes CO2 equivalent. To be in line with requirements of this PS, as set forth in the ESAP (action #3a), Simpa will ensure that all hazardous materials (e.g. hydrocarbons, solvents, ink, chlorine) in the existing and future facilities have adequate secondary containment.



Water Consumption



At the existing facility, potable water comes from the municipality and cooling water from 2 boreholes. There is no process water, except for washing equipment at the bleach production line. Water is also used for sanitary purposes. Total quantity usage in 2015 was 19,000 m3. At the new facility the situation will be similar with water being sourced from the municipality, but there will not be any bleach production.



Pollution Prevention



Air emissions are the main source of pollution at the Senegalese facility. Flexography, thermoforming, and the area for ink preparation are a source of VOCs, and particulate matter. Very limited emissions controls are in place in the form of a few air extractors and aeration ducts and air emissions monitoring is not conducted. Recommended pollution prevention and control techniques may include optimization of processing conditions for handling and mixing; filter air exhaust from material handling using cyclone and/or baghouse; and capture and control fugitive emissions from production devices.



To be in line with requirements of this PS, air emissions monitoring will be carried out monthly by an independent and certified laboratory in the existing and future facilities. Expected results should be within specific and general World Bank Group Environmental, Health and Safety or national guidelines values. The client will also need to audit the facility in Senegal and the design of that in Cote d’Ivoire to define efficient pollution prevention and control systems for VOC and particulate matter emissions (e.g. use of enclosed storage for all solvent and cleaning fluids; installation of ventilation control systems; air extractors and gas treatment by removing VOCs; filter air exhaust from material handling and granulation areas using a cyclone and / or baghouse) (actions #3b). This audit which will be conducted by a suitably qualified specialist, will also include a review of engineering controls and ventilation for both facilities to avoid high temperature in permanent work environments; and will propose improvements. Based on the findings of the audit the company will agree on time based plan with IFC to implement the recommendations for the plant in Se
negal, and equally agree with IFC on those measures to be implemented at the new plant under construction.





Wastes



In Senegal, plastic quality rejects are recycled and reused by Simpa. Other wastes include wrapping material, empty containers (for inks, solvents, chorine), used rags, etc. Solid waste except plastic is not sorted and sent to the municipal landfill. To be in line with requirements of IFC’s Performance Standards as set forth in the ESAP (action #1c), Simpa will develop a hazardous and non-hazardous waste management plan that will include the following: review of all waste sources, quantities, pollution prevention opportunities, and necessary treatment, storage, and disposal infrastructure. For hazardous waste, the plan should also include an occupational health and safety component, including hazard communication and training programs to prepare workers to recognize and respond to workplace chemical hazards, safe operating and materials handling procedures, and basic emergency procedures.



At the existing facility wastewater comes from sanitary sources, stormwater, and the bleach and soap production line (from washing equipment). Part of the sanitary water is sent to a septic tank and then collected by a specialized company for disposal; shower water from the ablutions is discharged along with stormwater in the municipal drainage system for which there is no treatment process. Washwater from the bleach production line is accumulated in a tank and then disposed of in a nearby field. Given the varied approach to waste water management, the company will agree with IFC on implementation of a time-based plan to ensure that the wastewater is disposed of in line with requirements of this Performance Standard (action #3c).



For the new facility, stormwater will be separated from sanitary wastewater streams in order to reduce the volume of wastewater to be treated prior to discharge. Simpa will ensure compliance with national or local standards for sanitary wastewater discharges or, in their absence, the applicable World Bank Group EHS Guideline values applicable to sanitary wastewater discharges. Oil water separators and grease traps will be installed and maintained as appropriate at refueling facilities, workshops, parking areas, fuel storage and containment areas (action #3c).

Community Health, Safety and Security



The Senegal facility is located in an industrial zone as is the facility in Cote d’Ivoire. In Senegal, the client has 10 trucks (10 tons) and this project will not induce any increased traffic in neighboring areas. Most of the transport for the future plant will be done by third party operators and the industrial nature of the zone will not affect communities.



Infrastructure and Equipment Design and Safety



In September 2015 a Life and Fire Safety (LFS) audit was conducted at the existing facility. Main recommendations were as follows; augment the capacity of water reserves as well as number of extinguishers; properly recharge and test all extinguishers; install fire hose cabinets especially where flammable materials are stored; install fire sirens, smoke alarms and detectors, and connect to a central switchboard; etc. Simpa is currently implementing the audit recommendations. As set forth in the ESAP (action#4a), once corrective actions are implemented, the client will confirm compliance with national regulations and Life and Fire Safety international standards.



The company is in the process of engaging a suitable consultant to review the approach to the design of LFS at the new facility and based on this will implement the recommendations accordingly to ensure compliance with national standards and accepted industry practice.



Security Personnel



In Senegal, security arrangements are made by the client. There are 6 non-armed guards permanently stationed at the premises and a CCTV system. Before hiring non-armed security personnel in Cote d’Ivoire, Simpa will make reasonable inquiries to investigate the employment statement and other available information, including any criminal record, of individuals or firms and will not employ or use any individuals or companies that have abused or violated human rights in the past.

Consultations and Grievance Mechanism

For the existing facility, in the course of the Environmental Audit conducted in 2015, public consultations were held to identify issues and concerns associated with the neighboring community of Rufisque, Senegal. Participants did not mention any negative impacts and rather noted positive issues including support to local schools and health centers, and opportunities for plastic recycling. During the consultations with local communities, the Simpa General Manager confirmed that any grievances regarding the company can be transmitted through the Mayor of Rufisque. This mechanism is available to any individual or groups that wishes to communicate a grievance related to various environmental and social issue.

Simpa commits to ensure that project related information is shared with the general public and stakeholders. In line with requirements of PS 1, as set forth in the ESAP (actions #1a, c), Simpa will implement and maintain a procedure for external communications and grievances that includes methods to; (i) receive and register external communications or grievances from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) adjust the management program, as appropriate. In addition, Simpa is encouraged to make publicly available periodic reports on their environmental and social sustainability.

Local Access of Project Documentation:

Contact Person: Mr. Ibrahim Hawili
Company Name: Societe Industrielle et Moderne des Plastiques Africains (SIMPA)
Address: Km 18 Route de Rufisque BP 977 Dakar, Senegal
Email: mailto:brahms@simpa.sn
Phone: (221) 33 879 00 79
Facsimile: (221) 33 834 41 90

Broad Community Support is not applicable for this project

SIMPA CI(38053) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
For the new plant in Cote d’Ivoire, Simpa will develop and implement an Environmental and Social management System (ESMS). The ESMS will incorporate but not be limited to the following elements: (i) a policy that will indicate who within the organization will ensure conformance and be responsible for its execution; (ii) identification of risks and impacts; (iii) management programs/procedures for environmental and social aspects; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) monitoring and review; and (vii) a community grievance mechanism.	01-Nov-2017	In progress	Under discussion with IFC Client
Develop and implement a construction phase Environmental and Social Management Plan (ESMP) and hire a full time EHS Officer on site in Cote d’Ivoire	01-Aug-2016	Completed	Completed	9/1/2016
Improve the ESMS at the plant in Senegal by developing and implementing the following management programs: hazardous and non-hazardous material; noise, control of volatile organic compounds (VOC), particulate matter, and heat; storage rules; occupational health and safety; Life and Fire Safety; food safety for packaging material; suppliers monitoring, mapping, and prioritization; emergency preparedness and response; external communications/ grievances; monitoring and reporting.	01-Jun-2017	Completed	Completed	3/31/2020
Hire an EHS (Environment, Health and Safety) Officer for the new plant in Cote d’Ivoire for the operations	01-Apr-2017	Completed	Completed	6/1/2018
For the construction phase, ensure that the EPC Contractor complies with national requirements, and that employees have contracts, and access to a grievance mechanism	01-Aug-2016	Completed	Completed	10/1/2016
For the existing operation in Senegal, ensure that the HR Policy and procedures are in line with requirements of PS 2.	01-Dec-2016	Completed	Completed	3/1/2018
Develop and implement HR Policies and procedures for the operation phases of the new plant in Cote d’Ivoire.	01-Jun-2017	In progress	Under discussion with IFC Client
Conduct third party occupational health and safety (OHS) audit for the existing facility in Senegal by a specialist acceptable to IFC that includes monitoring of workplace parameters such as heat stress, VOC and particulate matter emissions, lighting and noise. Based on the findings of the OHS audit, agree with IFC on a time based plan to implement and address the audit recommendations.	01-Oct-2016	Completed	Completed	3/31/2018
Undertake an OHS audit by a suitably qualified specialist acceptable to IFC against the same parameters as defined above for the audit at the new facility. Thereafter, agree with IFC on a time based plan to address and implemented the audit findings.	01-Jun-2017	Completed	Completed	10/31/2019
Develop a management procedure for the supply chain at the existing and new facility which will include the development and implementation of a Supplier’s Code of Conduct which will be mainstreamed into its contractual agreements with recycled plastics suppliers. This Code of Conduct will include provisions against child and forced labor in line with requirements of PS 2.	01-Aug-2016	Completed	Completed	1/31/2017
Monitor progress and compliance of the supply chain management procedure against this Performance Standard through regular visits in the field/landfill site, and report to IFC (through the AMR).	01-Dec-2016	Completed	Completed	1/31/2017
Construct secondary containment around storage tanks for hazardous materials (inks, solvents, hydrocarbons, paints, etc.) for the existing and new facilities	01-Jun-2017	Completed	Completed	1/31/2019
Review the operations at the existing facility in Senegal and the design of the facility in Cote d’Ivoire to identify efficient pollution prevention and control systems for VOC and particulate matter emissions aligned with accepted industry practices. This audit will also include the identification of engineering controls and ventilation to avoid high temperature. Based on the findings of the review, agree with IFC on a time based plan to implement the findings at the existing facility in Senegal and ensure the recommendations are implemented at the new facility in Cote d’Ivoire prior to project commissioning.	01-Mar-2017	In progress	Under discussion with IFC Client
Implementation of recommendations of pollution prevention systems, and engineering controls for temperature audits in existing and new facilities	01-Oct-2017	In progress	Under discussion with IFC Client
Ensure that the wastewater from the existing facility is disposed of in line with requirements of this Performance Standard. For the new facility, stormwater should be separated from sanitary wastewater streams. Simpa will ensure compliance with national or local standards for wastewater discharges or, in their absence, the indicative EHS guidelines values.	01-Jun-2017	Completed	Completed	12/31/2018
Implement recommendations of the Life and Fire Safety audit and ensure compliance with requirements of national regulations and internationally accepted standards of the existing facility	01-Mar-2017	In progress	Under discussion with IFC Client