The company will acquire land in Paranagua as part of the upgrading of one of its existing operations on willing buyer willing seller basis through a market based transaction. This will not result in any physical or economic displacement; hence PS 5 does not apply. Since none of the company operations is located in or within the area of influence of environmental sensitive areas, PS 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not applicable. Furthermore, PS7 (Indigenous Peoples) is not relevant to this project because of the absence of Indigenous People in the area of influence of the company’s operations. Regarding PS8 (Cultural Heritage), no cultural resources or paleontological/cultural relics have been identified, and hence it is not applicable.

This is a category B project according to IFC’s Policy on Environmental and Social Sustainability, because the Environmental, Social and Health & Safety (ESHS) impacts related to the investment are limited, site specific, covers a footprint of existing brownfield assets, and the associated environmental and social (E&S) impacts can be managed through the implementation of appropriate mitigation measures. IFC’s review did not identify any significant adverse impacts or high-risk exposures.

 Key issues associated with this project include: adequate development and implementation of a comprehensive ESHS management system; including the necessary policies and procedures applicable for current operations as well as for future developments and acquisitions; HR management including that of contractors and supply chain; implementation of occupational health and safety (OHS) measures; adequate management of air pollution, hazardous materials, hazardous wastes and  wastewater; impacts on health, safety and security of the nearby communities and ongoing stakeholder engagement. 

Environmental and Social Assessment and Management System

The company has an EHS management structure to oversee the E&S performance of its operations consisting of an EHS policy and site level standard operating procedures (SOPs) for the identification and management of ESHS risks and impacts; emergency preparedness and response; and monitoring and reporting of EHS performance to the corresponding environmental authorities.  As required by the local environmental authorities, the company conducts environmental assessments to identify risks and determine appropriate mitigations, and demonstrate compliance with host country requirements.  For the current operations, the company has confirmed that it is compliant with all the necessary EHS related permits, and satisfies the mitigation measures, as stipulated in the permit conditions.

Cibrafertil’s ESHS aspects are being addressed at site level. It was evident during the visit, that the current EHS systems and procedures developed by the company are being implemented on the ground.

As part of the project, the company will enhance the current systems and procedures at site level as well as establish and implement a corporate ESHS Management System based on the Brazilian regulations; IFC’s PSs; the relevant WBG EHS Guidelines. (See Action # 1 of the ESAP.) The management system will include among others: procedures for identifying E&S risks and impacts, improvements to the current organizational EHS structure and organizational line assignments and responsibilities; guidelines for training, communication, and audits; programs for risk and process management; emergency response and contingency plans; monitoring and reporting and community engagement programs.   

Assessing and Complying with Performance Standard Requirements for Future Developments

As the IFC’s investment will be also used for the acquisition of new blending assets in the future, as confirmed at this time, the company will develop an E&S procedure for new acquisitions and it will engage external consultants to commission E&S due diligence audits including mitigation actions and implementation timetables to ensure compliance with IFC PS requirements in a time bound manner. (See Action # 2 (a) and (b) of the ESAP.)

Policy

Cibrafertil’s Ethics Code highlights the principles that guide the way the company manages its operations including transparency, respect, team work, and professionalism.  It also states its commitment to preserve the environment by evaluating, preventing potential, and controlling operational risks; along with ensuring responsible use of natural resources; and ensuring safety conditions for its personnel. 

Organizational Capacity and Competency

At the corporate level, the company has appointed dedicated EHS personnel. This team is led by the Operations and Supply Chain Manager who, for EHS aspects, reports to the EHS Executive Committee comprising of 8 members (CEO, CFO, HR, Commercial, M&A, Operations and Supply Chain Directors, HESQ Manager and EHS Coordinator.) At corporate level, the company also has a dedicated HR team consisting of one manager and supporting specialists to oversee all operations. 

At operations level, even though the general managers are ultimately responsible for the EHS aspects, adequate EHS organizational structures are in place to manage the day-to-day EHS activities. All the operations conduct EHS trainings including at induction, periodic in-depth training, as well as special training for identified risky activities. 

Emergency Preparedness and Response

Most of the operations have emergency response and contingency plans in place which are based on identified hazards and risks. Specifically, Camaçari has internal emergency response teams and the plant is part of the Mutual Assistance Plan for the Camaçari complex as well as of the Industrial Development Committee of Camaçari (COFIC) which has its own fire brigade and police station.  The Camaçari, Candeias and Paranaguá operations have emergency response plans in place.  The São Francisco do Sul operation is currently developing its emergency response plan, and the Cristalina and Sorriso operations are yet to develop their corresponding emergency response plans.  With the exception of Camaçari, the remaining operations can contact the nearest firefighters’ teams when needed. None of the company operations have had any accident or significant emergencies in the past.

As part of this proposed project, Cibrafertil will (a) enhance the current emergency response plans to include among other aspects, scenarios identified in risk analysis for emergency drills, emergency response training, identification of assembly points, relevant system to notify emergency to the nearby residential communities as necessary; (b) develop emergency response plans for Cristalina, Sorriso, Rondonopolis I, and Rondonopolis II; (c) audit and enhance, as needed, or develop emergency response plans for the third party operations of Rondonopolis, Rio Grande, and the Luis Eduardo Magalhaes warehouse; and (d) similarly, it will develop/update emergency response plans for the three blending facilities anticipated to be acquired. (See Action # 3 of the ESAP.)   Cibrafertil will also train and establish internal firefighting and emergency response brigades at all operations.

Monitoring and Reporting

The company conducts monitoring and reporting programs reflecting and complying with the requirements of the local authorities for its operations.   Sorriso and Cristalina are not required by the local authorities to conduct monitoring.  As part of this project, the company will upgrade the monitoring plan for all sites including parameters, frequencies, and sampling locations to reflect the local regulatory requirements as well as WBG EHS Guidelines (See Action # 4 of the ESAP.) The monitoring plan will also be implemented at the facilities to be acquired.

Human Resources Policies and Procedures

The company’s corporate HR policy and procedures are rooted in the values that guide its interactions with staff, partners and suppliers, customers, and the communities in which they operate. The company has committed to strive for the transparent application of their HR policy through its code of conduct and by broadly communicating the company’s policies on equal opportunity, local hiring practices, recruitment, compensation, etc. It also has a zero tolerance policy for discrimination and harassment. The company’s HR policy is aligned with the Brazilian labor laws and is consistent with IFC PS2 requirements. 

Working Conditions and Terms of Employment

The terms of employment, which are defined in the internal employment rules and regulations, are provided to each employee upon hiring. These include benefits, hours of work and overtime compensation, life insurance, health insurance, etc.  In addition to the legally required benefits, the company also offers fringe benefits to its employees such as dental plan, pension plan, etc.  

All operations promote local hiring. The total number of fulltime employees for all operations is approximately 450. There are 69 female employees which constitute approximately 14% of the total workforce (half in administrative positions and half at the industrial units.) The majority of the company’s employees are located in Bahia with a total of 260 employees. In Camaçari, where the company has its manufacturing facility, it has 156 employees; and in Salvador, where it has its headquarters, it has 60 employees, 28 in sales force. In Candeias, it has 16 employees; in Cristalina, it has 18 employees; in Paranaguá, it has 83 employees; in Curitiba, it has 8 employees; in Sorriso, it has 12 employees; and in Sao Francisco do Sul, it has 69 employees. In addition, Cibrafertil hires 125 contractors for supporting operations such as canteen, housekeeping etc., across all its facilities. Cibrafertil expects to create between 120 and 150 new direct job positions, resulting from the acquisitions, and approximately new 1000 indirect employees (i. e., trucks drivers, port operators, maintenance contractors, heavy equipment operators, food service, laboratory analysts, among others),

At its SSP production (make-to-stock) in Camacari, the company operates three 8 hours shifts, seven days a week. The blending facilities operations (make-to-order) schedule varies depending on the season. During the low season, it operates one 8-hr shift during the day. During the high season, the operations run three 8-hr shifts, 6 days per week. When necessary, overtime is used and in according to the Brazilian labor law extra hours are paid or compensated.

Workers’ Organization

The company’s HR policy establishes freedom of association for all the employees.  According to the Brazilian legislation, all employees have to be represented by a labor union and are entitled to negotiate collective bargaining agreements. Bahia employees belong to the Sindicato dos Trabalhadores do Ramo Químico e Petroleiro do Estado da Bahia and to the Sindicato das Industrias de Adubos e Corretivos Agrícolas do Nordeste (SIACAN); Cristalina employees belong to the Sindicato das  Industrias Químicas do Estado de Góias ( SIN Q F P GO); Paranaguá  employees belong to the Sindicato Da Industria de Adubos e Corretivos Agrícolas do Estado do Paraná  (SINDIADUBOS); São Francisco do Sul employees belong to the Sindicato dos Trabalhadores nas Industrias Quimicas, Farmaceuticas e de artefatos de Borracha de Joinville e Região; and Sorriso and Rondonópolis employees belong to the Federação dos Trabalhadores nas Industrias do Estado de Meto Grosso ( FIEMT.)

Non-discrimination and Equal Opportunity

The company’s HR policy includes provisions related to non-discrimination based on race, nationality, disability, social class, sex, religion and/or political ideas. The company is an equal opportunity employer that extends equal employment opportunity to all applicants and its selection decisions are merit based. Cibrafertil hiring age is 18 years, which complies with the local law and IFC PS2 requirements related to minimum hiring age. The contracted personnel are also older than 18 years. Furthermore, in compliance with the local requirements as well as IFC PS 2 there is no forced labor in either its own or contracted operations.

Retrenchment

During 2016 and early 2017, the company retrenched 270 employees at the Paranaguá unit due to production reduction.  The retrenchment was conducted based on consultations with the affected workers, the Sindiadubos union, the national labor requirements, and in accordance with IFC’s PS2 requirements. There are no pending legal actions.  As the company anticipates to have additional retrenchment, the company will develop a corresponding retrenchment plan in accordance to IFC PS2 (See Action # 5 of the ESAP.)

Grievance Mechanism

Even though, Cibrafertil encourages all employees to have respectful and transparent conversations with their leaders, the company does not have a formal and documented employees’ grievance mechanism in place.  As part of the project, the company will develop and implement a grievance mechanism for each of its operations.  The grievance mechanisms will include (a) methods of communication about the mechanism to employees (i.e. existence of the grievance mechanism), (b) means to present the grievances openly/anonymously (e.g. mail, phone, verbal report to immediate supervisor/reporting authority; etc.), (c) process of receiving and registering grievances/complaints, (d) assessment and categorization of grievances, (e) prioritization and hierarchy of grievances and response time, (f) guidelines for resolution and response of grievance, (g) responsible personnel in charge of resolution, (h) documenting grievance/resolution, and (i) periodic monitoring of grievances and review by senior management. (See Action # 6 of the ESAP.) The availability of this grievance mechanism shall be communicated to all the employees through internal communications. 

Occupational Health and Safety (OHS)

Cibrafertil aims to establish a health and safety (H&S) management system to ensure zero accidents across all operations. The company is focused on developing procedures for the prevention of risks related to aspects such as work at heights, confined spaces, exposure to electricity, etc.; and has made compulsory the use of personal protective equipment (i.e., ear protection when workers noise exposure is above 85 dB, safety helmets, safety goggles, mechanical protection gloves, safety shoes, etc.) As part of this project, the company will establish at each of its facilities a process risk analysis and review program and update the operational safety procedures as needed in accordance with the WBG EHS Guidelines (See Action # 7 (a) of the ESAP.) Furthermore, specifically, for the SSP plant, Cibrafertil will develop a hazard and operability study (HAZOP) and implement the resulting recommendations. (See Actions # 7 (b) and (c) of the ESAP.)

The operations have appropriate fire prevention measures including water mains and fire hydrants, portable first aid, firefighting equipment, emergency warning alarms, emergency shutdown procedures and adequate fire water storage onsite and have dedicated emergency response teams available while in operation. Fire and emergency response drills are also conducted.

As part of the overall housekeeping improvements, the company will conduct a comprehensive clean-up of its SSP plant and will establish strict housekeeping measures in the production and storage areas to reduce risk of accidents. (See Action # 7 (d) of the ESAP.)

Each operation has own mandatory on-boarding and job-safety training programs, and it implements daily safety dialogues. The company performs full physical and medical assessment as a pre-employment screening and the detailed job risk profiles it has developed serve as the basis to conduct the regular periodic medical checkups (i.e. audiometry, blood count, clinical, etc.) for all its employees. The overall medical condition of Cibrafertil’s work force (past medical liabilities) is satisfactory and no chronic job related illnesses are reported.

Even though, the operations track and monitor accidents and incidents, the company will enhance this system to prevent accidents. This will be done by establishing criteria and responsibilities for classification of accidents (including near misses), systematic root causes assessments, as well as, identifying measures to prevent similar/new occurrences. Moreover, Cibrafertil is committed to conduct periodic monitoring and measurement of the work place conditions at all its operations as per Brazilian laws and WBG EHS Guideline requirements.

Supply Chain

Currently, the company has two third party suppliers with tolling operations. Also, as part of its expansion, Cibrafertil anticipates having tolling operations through which the company will blend and distribute fertilizers. Thus, as part of this project, the company will develop EHS procedures for the tolling operations to ascertain compliance with the IFC PS and applicable WBG EHS Guidelines to be applied to these activities (See Action # 8 of the ESAP.)

The SSP production involves mixing sulfuric acid and pulverized phosphate rock in a reactor. The reaction is discharged onto an enclosed conveyor belt and then fed to a granulator. The acidulation operation generates particulate matter and Fluor air emissions, and the granulation operation generates particulate matter, Fluor, SOx, and NOx. The process wastewater is generated primarily through scrubber operation, as well as through tank cleaning and plant cleaning operations. Cibrafertil blending operations mix nitrogen, potassium, and phosphorus nutrients to produce fertilizers. The raw materials are stored, transferred to the mixers, and once homogenized, the product is sent for packaging.

Energy and Material Efficiency Projects

At Camaçari, Cibrafertil is implementing a project to recirculate 100 % of the scrubber water back into the process; this initiative will reduce water consumption approximately by 30 %. In addition, as part of this project, it will also identify and establish energy and water consumption optimization measures at its blending operations as well as the SSP plant. (See Action # 9 of the ESAP). Furthermore, the company is developing the preliminary studies to substitute the gas furnace with a biomass furnace at the Camaçari plant. 

Water and Wastewater

Camaçari consumes approximately 136,000 m³/year and each of Cristalina and Sorriso consumes approximately 1,500 m³/year of groundwater. Candeias, São Francisco do Sul, and Paranaguá each consume approximately 2,000 m³/year of water and obtain it from their corresponding municipal water supply systems.

The Camaçari SSP plant generates scrubber and process wastewater as well as domestic wastewaters.  Most of the scrubber wastewaters are recycled back into the process, while the remaining scrubber wastewater along with the process and domestic wastewaters are discharged untreated to CETREL, the Camaçari industrial complex wastewater treatment plant, which after treatment discharges them to the Atlantic Ocean through a Submarine Emissary (5 km from the coast).

The Candeias, São Francisco do Sul, Paranaguá, Sorriso and Cristalina blending units generate only domestic effluents. These are released to the corresponding municipal systems for further treatment.

GHG Emissions

All facilities procure their needed electricity from the national grid.  The Camaçari plant also has a natural gas boiler and a natural gas-fired furnace.  Furthermore, Camaçari and all blending operations use diesel for the loaders operation.  GHG emissions generation is taken into account electricity, diesel, and natural gas consumptions.  The GHG emissions from Camaçari operations reached approximately 70,000 tCO₂ equivalent; for Candeias, approximately 35,000 tCO₂ equivalent; for Sao Francisco do Sul, 50,500 tCO₂ equivalent; for Sorriso approximately 26,000 tCO₂ equivalent; for Paranaguá approximately 61,000 tCO₂ equivalent; and for Cristalina approximately 35,000 tCO₂ equivalent. The total project CO₂ equivalent generation is approximately 250,523 tons/yr.

Air Emissions and Ambient Air Quality

The Camaçari plant has a natural gas 5-ton/hr boiler that consumes 0.47 MM m³/yr and a natural gas-fired furnace that consumes 4.43 MM m³/yr.  Furthermore, Camaçari’s plant and all blending operations use diesel for the loaders operation as follows: Camaçari (415,000 lt/yr), Candeias (36,000 lt/yr); Sao Francisco do Sul (143,000 lt/yr); Sorriso (50,000); Paranagua (111,300 lt/yr); and Cristalina (40,000 lt/yr.) 

The Camaçari plant has a cyclone and a wet scrubber system to control the process emissions from the acidulation and granulation operations.  It also applies coating to the end product, thus avoiding dust generation during operation and field application. The plant monitors the particulate matter, fluoride, SOx, and VOC air emissions generated during the acidulation and granulation processes. These emissions are in compliance with the local and the WBG EHS Guidelines (Table 1) requirements.

At the Candeias operation, it monitors particulate matter and those emissions are also in compliance. At the Paranaguá operation it measures the fugitive emissions which are above local as well as WBG IFC Guidelines (Table 1.1.1.) At the Sao Francisco do Sul it measures fugitive emissions at two locations, one in front of the plant and a second one, behind the plant.  The measured concentrations at both sites are in compliance with the local requirements; however, the measures at the front of the plant are above the WBG IFG Guidelines (Table 1.1.1) requirements. As part of this project, it will install control system to bring the particulate matter emission concentrations of the Paranaguá and the Sao Francisco do Sul operations to reach compliance with the WBG IFC Guidelines (See Action # 10 of the ESAP.) 

Noise

None of the operations report noise monitoring results. As part of this project, the company will conduct noise monitoring to ascertain that the noise levels are in accordance with the applicable WBG EHS Guidelines and local regulatory requirements as part of its EHS performance monitoring.

Solid Waste Management

For each of its Camaçari, Candeias, and Paranaguá operations, Cibrafertil has implemented robust waste management systems including waste identification, segregation, collection, temporary storage, transportation, and disposal. As part of the solid waste management, the company also looks to reduce and recycle the wastes generated.  For instance, at Camaçari, the empty gas cylinders are returned to the provider; all liquid wastes generated from tanks cleaning, sludge generated in the production’s filter press, as well as the laboratory samples are reintegrated back into the process; used oils, paper, plastic, wood are sold for reuse; the fluosilicic acid generated as by-product is sold.  At Candeias and Paranagua, it generates wastes such as paper, cardboard, plastic, glass, scrap metal, metal packaging, rubber, wood, batteries, etc.  Camaçari, Candeias and Paranagua contract licensed waste handling companies for the transport and disposal of both hazardous and non-hazardous solid waste and maintain registries of the transportation of the disposal wastes to the final destinations to ensure proper disposal. Since São Francisco do Sul, Sorriso, and Cristalina currently do not have waste management programs, as part of this project the company will develop the solid waste management programs for these facilities, similar to that at other operations (See Action # 11 of the ESAP).

Hazardous Materials

Hazardous materials at the Camaçari manufacturing plant include phosphate rock, approximately 180,000 -200,000 ton/year; sulfuric acid: 96,000 liters/yr, diesel 10,000 lt/yr. It keeps a list of hazardous materials used in production, which are handled and stored according to respective material safety data sheets. Several of the storage tanks containing liquid hazardous materials such as sulfuric acid and diesel have double containment and needed safety prevention measures.  As part of the project, the company will conduct an assessment of the storage tanks of all its operation to ascertain and install as appropriate all safety measures. (See Action # 12 of the ESAP.)

Pesticide Use and Management

The use of pesticides in relatively low and it is used to manage pests and plagues in the operations. Management of pesticides and agrochemicals follows best practice procedures.

Logistics and Transportation

Logistics and transportation of raw materials and products to and from Cibrafertil facilities is a critical component of the operations. The imported and local raw materials for the Camacari plant and the blending operations are transported by truck, as are the products provided to costumers or sent to the warehouse.  All transportation, at all operations is contracted. The number of truck used for product distribution vary depending of the time of the year, as the sale of the products is highly dependent on the planting season.  For instance, in Paranagua II, during low season, there may be approximately 8 trucks leaving the site, whereas during high season (July-September) there may be approximately combined 150 trucks entering and leaving the site every day. Communities and authorities from two sites, São Francisco do Sul and Candeias have requested Cibrafertil establishing improvements measures to reduce the number of trucks parked in front and around the sites. 

Even though, the Brazilian legislation requires the transportation companies to control drivers daily working hours and have additional requirements for transporting of dangerous cargo, like sulfuric acid, Cibrafertil will develop a corporate safety transportation plan and establish specific procedures for each of the operations to include check-up protocols and checklists, conduct inspections for trucks coming and going out, establish measures to rationalize the traffic in front of the sites, etc. (See Action # 13 of the ESAP.) Diesel is supplied via truck and offloaded into the storage tanks.  The ammonia used in Camacari’s operation is transported via truck and unloaded directly into the reactor thus avoiding onsite storage of ammonia. 

Security Personnel

The company employees non-armed private security personnel from specialized firms. Security personnel are screened for criminal backgrounds, however it will be provided with training in the use of force particularly on those facilities located close to communities such as São Francisco do Sul and Paranaguá. The company will develop relevant security procedures for all its operations. (See Action # 14 of the ESAP.)

Cibrafertil does not have in place community grievance mechanisms at any of its operations. Thus, as part of this project, it will develop a corporate community grievance mechanism as well as specific community grievance mechanisms for Sao Francisco do Sul; and Paranagua which are the two operations with communities nearby (See Actions # 15 (a) and (b) of the ESAP.)

As part of its outreach, the company hires personnel from the local communities. In addition, Cibrafertil is partner of Instituto Comvida, a non-profit institution, that promotes personal development, professional qualification and job market opportunities for young people in endangered communities in Catu de Abrantes (Camaçari). The company provides financial support to the Institute and also employs young technicians and administration professionals promoted, schooled, and supported by the Instituto Comvida.

Documents to be disclosed are:

- Environmental and Social Review Summary (ESRS)

- Environmental and Social Action Plan (ESAP)

The complete set of documentation is available locally at the following locations:

Contact Person: Jorge Arbelaez

Company Name: Cibrafertil

Address: Av. Luis Viana Filho, 13.223, Torre 3, salas 401 a 410

 Centro Empresarial Hangar Business Park,

              CEP.: 41.500-300, Salvador- Ba.

Email:  jorge.arbelaez@cibra.com

Phone: Tel 55 71 2202 4200

Contact Person: Fernando Gonçalves Neto

Company Name: Cibrafertil

Address: Av. Luis Viana Filho, 13.223, Torre 3, salas 401 a 410

Centro Empresarial Hangar Business Park,

             CEP.: 41.500-300, Salvador- Ba

Email: fernando.goncalves@cibra.com

Phone: Tel 55 71 2202 4200

Contact Person: Jesus Mancini

Company Name: Cibrafertil

Address: Rua Alfa 1428 COPEC, Camaçari-BA, 42810-290

Email: jesus.mancini@cibra.com

Phone: Tel 55 71 2107-0730

Contact Person: Patricia Varjão

Company Name: Cibrafertil

Address: Via Matoin, S/N, Braço BC Cia Norte, Distrito Industrial, Candeias - BA, 43813-000

Email: patrícia.varjao@cibra.com

Phone: Tel 55 71 2202-4292

Contact Person: Mario Rodrigues

Company Name: Cibrafertil

Address: Rua Conselheiro Correa Júnior, 625/829, 29 De Julho, Paranaguá - PR, 83203-780

Email: mario.rodrigues@cibra.com

Phone: Tel 55 41 3422-8646

Contact Person: Sergio Monteiro

Company Name: Cibrafertil

Address: Rodovia Duque de Caxias, 160, Reta, São Francisco do Sul - SC, 89240-000

Email : sergio.rodrigues@cibra.com

Phone : Tel 55 47 3444-0713

Contact Person : Gabriel Silva

Company Name: Cibrafertil

Address: Rod. BR 163 km 760, S/N, Expansão Urbana, Sorriso - MT, 78890-000

Email: gabirel.silva@cibra.com

Phone: Tel 55 66 3545-2800

Contact Person: Cristovão Silva

Company Name: Cibrafertil

Address: Rod. GO 436 km 56, S/N, Zona Rural, Cristalina - GO, 73.850-000

Email: cristovao.silva@cibra.com

Phone: Tel 55 71 2202-4261