All premises, whether for manufacturing or distribution, are located in commercial areas in leased spaces and any future acquired businesses are also expected to follow the same arrangement. Therefore, the impacts envisaged under Performance Standard (PS) 5 (Land Acquisition and Involuntary Resettlement) are not applicable to this project. No direct primary production of living natural resources is involved in the project and there is no material risk of significant conversion of natural and/or critical habitats in the supply chain and thus PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not applicable. Similarly, the type of risks and impacts envisaged in PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable. In going forward and prior to any future acquisitions by the company, whether they are a majority shareholder or not, environmental and social due diligence (ESDD) will be conducted to ensure that all social and environmental risks and impacts are adequately identified and managed in a manner compliant with local regulations, and consistent with all applicable IFC’s Performance Standards. This is in line with the company’s increasing focus on manufacturing.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

Key E&S risks and issues related to this project include: i) the company’s capacity and systems to manage its social, environmental, health and safety risks and impacts across all aspects of its operations (e.g., raw material sourcing, manufacturing, distribution and transportation) in compliance with legal requirements as well as IFC Performance Standards and World Bank Group (WBG) EHS General and sector-specific guidelines; ii) life and fire safety (L&FS) management and emergency response; iii) assurance of fair, safe and healthy working conditions for its workforce (both employees and third party workers – which is particularly relevant for acquisitions beyond South Africa); iv) occupational health and safety v) resource efficiency (mainly energy); vi) pollution prevention - especially management of hazardous substances and solid wastes, and (in the case of manufacturing) wastewater; vii) stakeholder engagement viii) product safety (includes food safety); ix) vehicular safety / and managing impacts from transportation operations and x) supply chain management.

The review included an assessment of (i) existing operations in South Africa and Poland (ii) potential acquisitions (known pipeline) and the (iii) process of ESDD to be applied to future yet-unknown acquisitions.Further information on the Environmental and Social (E&S) risks associated with the supply chain of rice was obtained from a list of the major suppliers, websites and the IFC’s Tool for the Assessment of Environmental and Social Risks of Agro-Commodity Production (GMAP.)

Identification of Risks and Impacts: Coast2Coast (C2C) and the Bounty Brands Group apply a formal Risk Management (RM) screening process that is implemented before the acquisition of target companies, which includes the assurance that the business has the required regulatory permits and approvals but does not explicitly include E&S elements.  Since the Group’s growth is predominantly via acquisitions, the company will develop and implement an Environmental and Social Due Diligence (ESDD) process that will be integrated with the existing Risk Management process. This will be applied prior to acquisitions or establishment of any new business, to identify the E&S risks while taking local legislation, the IFC Performance Standards (PSs), and the World Bank Group (WBG) General Environmental, Health and Safety (EHS) Standards into account. As per the ESDD (i) Bounty will undertake a review of all the potential opportunities as per their criteria and check applicability of PSs; (ii) screen out investment opportunities that will not meet their requirements (e.g. too unsafe, supply chain risks, legacy land or pollution issues or any other criteria) and (iii) for those accepted for investment, develop an action plan for compliance with PSs and other requirements. These actions are defined in the attached ESAP (ESAP #1).

Environmental and Social Policy, Assessment and Management System: Currently, there is no documented Environmental and Social (E&S) policy or management system applied to Bounty subsidiaries, other than a statement on Environmental Care in the Group Code of Ethics. During the site visits of selected South African operations, it was observed that in general, facilities were well managed with legally compliant quality and safety management procedures in place. Tuffy is currently working towards British Retail Consortium (BRC Certification), while Liberty and Rieses have a Quality Management System that is aligned with ISO standards and complies with the UK’s Food Standards Agency certification 2.  Liberty are working towards HACCP (Hazard Analysis & Critical Control Points) accreditation.  Sonko operations in Poland fulfil HACCP, ISO 9000, BRC (Global standard For Food Safety), and IFS (International Food Safety) standards, which is verified annually by TUVNord (Polska). While Sonko must comply with EU environmental directives in order to export products, at the South African operations, environmental issues are dealt with on an issue/site-specific basis. Policies or practices that relate to the statement on Environmental Care are not in place; in this respect, there is significant inconsistency across the Group.

The rapid expansion of Bounty Brands, the continued involvement of subsidiary shareholders, and an increase in product diversity has resulted in complexity from a consolidation perspective, and this is likely to continue. Bounty has appointed two corporate employees to focus on integration, and although their primary focus is not EHS, there is an opportunity to transfer the strengths of some operations to others within the Group.  Thus, it is agreed that the company will develop an overarching corporate Policy that defines its Environmental, Health and Safety (EHS) objectives and principles, and will apply this to guide the activities of all operations (ESAP #2).

The manufacturing operations of the Group apply the Good Manufacturing Practice (GMP) approach, which is a quality management system designed to ensure the efficient and effective production of products, but which does not include the identification of environmental risks / impacts and monitoring parameters (beyond good house-keeping). Thus, a corporate approach to manage Environmental aspects using an Environmental and Social Management System or ESMS will follow from the Policy development process, to ensure uniformity of application across subsidiaries. A risk assessment process which comprises the identification of environmental, labor, occupational health and safety (OH&S) and community-related risks/impacts/opportunities, will form the core basis of the ESMS, and will involve a review of all existing EHS policies and practices (drawn from the various subsidiaries) and their effectiveness, with subsequent consolidation and enhancement into an integrated system which can be tailored to each company in the Group. The ESMS will thus identify risks and opportunities, mitigation or implementation measures, monitoring parameters, and assign responsibilities. Monitoring parameters and thresholds will be consistent with those referenced by national requirements and the World Bank Group’s General EHS and sector-specific Guidelines.  Overall, the resulting management system will be compliant with the requirements of Performance Standard 1 but may also be aligned with other recognized international standards, such as ISO 14001 and OHSAS 18001.  Thereafter, this will become the corporate standard to be employed across Group operations, as well as all future businesses, as articulated in ESAP #3.  Bounty will undertake annual EHS assurance audits to confirm the adequacy of the ESMS for all operations, and based on the findings, will address gaps/deficiencies within specified timeframes.

E&S Capacity: Bounty has a strong but young management team with noteworthy experience in the importation and distribution of various consumer products. As the business grows the management team is expanding to significantly bolster capacity. This is evidenced by the current recruitment program to hire an executive for the Home and Personal Care divisions as well as an MD for the Central and Eastern European business, where the executive team will grow from 3 to 5 executives. Bounty does not have dedicated corporate Environmental, Health and Safety (EHS) employees (with the exception of Sonko that has three EHS staff to implement the requirements of an EU-compliant company). Within the South African subsidiaries, the Managing Director takes overall responsibility for EHS issues, although some make use of external service providers to support their quality, health or safety staff. Thus, the company commits to appoint an appropriately qualified person who will oversee the corporate development and implementation of the EHS Policy and integrated Environmental and Social Management System (ESMS) across the Group, and for apply it to each new acquisition / development.  In addition, the job description for site-level Health and Safety officers will be enhanced to define specific Environmental and Social roles and responsibilities, and Bounty will integrate E&S considerations into its training programs. The individual responsible at the corporate level for EHS will also coordinate reporting on such efforts to the Board(s), compile the EHS input into the Group Annual Report, as well as ensure implementation of the conditions of the ESAP (ESAP #4).

For the South African operations, a Group Environmental, Health and Safety Committee will soon be constituted, as the coordination platform for the subsidiary committees established in accordance with the South Africa Occupational Health and Safety Act. The draft Terms of Reference of this Committee will be expanded to include environmental aspects, and monitoring data on EHS will be reported to the relevant Board Committee. This approach will be similarly applied to the Polish operations (regardless of whether it is a statutory requirement or not), and other future acquired businesses.

Monitoring and Review / Reporting: As mentioned, some subsidiaries have Health and Safety officers who ensure compliance with local regulations and report incidents of H&S non-compliance to the relevant General Manager. In future, and as per the ESMS, specific EHS key performance indicators will be monitored and reported upon, as follows: compliance with legal and regulatory requirements, including the ESMS progress (and the maintenance of certification/accreditations such as HACCP, where applicable); energy and water consumption and efficiency; solid waste management; hazardous materials management; effluent discharges (in the case of manufacturing); compliance with national OHS requirements, including accident rates (lost-time accidents);  EHS training program; customer/community complaints; supplier performance and community engagement activities, as stated in ESAP #5. Implementation will be supported by the provision of resources (qualified and competent staff, capital and operating budgets), be integrated throughout operations, and include EHS training of employees to accomplish the program and its requirements. At any time in the future when a company in the Group is undergoing construction/renovation/expansion projects, the contractors will equally be required to comply with the above and to also provide regular EHS monitoring reports to the EHS Manager, who will ensure adherence the policies of the company.

Emergency Preparedness and Response: The South African operations of Bounty have basic procedures in place for fire prevention, but these plans do not include response procedures for other unforeseen emergencies such as armed robberies, social unrest etc.  The company will therefore develop a comprehensive Life and Fire Safety and Emergency Preparedness Policy, and supporting documentation to guide its implementation, to be applied at all Bounty premises (current and future). Training to ensure all employees and security personnel responsible for acting in the event of Emergency and/or LFS incidents are competent will be undertaken (ESAP #6). As an integral part of the ESDD associated with each new acquisition (see ESAP#2), the company will perform a review of the Life and Fire status of all facilities of the target business. The ESDD process will assess the level of compliance of the target business with local building fire, and legal/insurance requirements, and if the site has public access, assessment criteria will include an internationally recognized LFS standard. Depending on the findings, Bounty will draw up an LFS plan to implement relevant corrective measures on the facilities, or to negotiate their being undertaken by the property owner as part of any lease agreement.

Supply chain management: Bounty is highly diversified company with 13 subsidiaries, and receives products from vastly different countries. Liberty, Rieses, BountyWear, Goldenmarc, Table Charm and Cosmetix import and re-distribute 85% of their products (either directly or through other local importers/suppliers), while the balance of products (Tuffy, Sonko and Annique) are manufactured. Sonko imports rice from 5 major suppliers (Italy: Euricom; Thailand: CP; Poland: Dako, Hammer, Mundi); the Annique product range is manufactured locally by Prime Product Manufacturing (PPM), which supplies most of all requirements (primarily for the skin and body care range) and the rooibos (one of the active ingredients) is supplied by the Red T Company (South African rooibos); Tuffy sources all of its raw materials and post-consumer plastic materials locally.

The Jeep apparel (footwear and clothing) and Levi’s footwear are manufactured under license agreements with contract manufacturers in China. The Jeep apparel is managed locally in South Africa by Musgrave and the Jeep and Levi’s footwear by Footwear Trading (FWT). Musgrave regularly visit their factories in China and undertake unofficial assessments, and during the appraisal responded that they are satisfied with the working conditions and that no labor exploitation is taking place. Furthermore, they are in the process of acquiring ethical compliance certificates from two of the smaller import manufacturers, in line with supplier requirements recently outlined by Walmart. Levi’s and Jeep Footwear are  managed by FWT, who confirmed that the Levis and Fila brands are governed by a license or distribution agreement which specifically outlines the minimum factory standards and a Code of Business Conduct (the Code refers to the prohibition of child labor, forced labor, and discrimination while emphasizing safety and health, environmental responsibility and ethical standards). The factories must be approved by each of the brand holders before any production can take place. To be approved, each factory is required to undergo and pass an independent audit against the brand holders’ requirements. The cost of the audits are borne by the factory and the buyers (the most recent audit report was provided; scores are given for working conditions, labor standards, occupational health and safety as well as basic environmental aspects), with deadlines for corrective actions. Levi Strauss & Co. (LS&CO) strictly enforces a Chemical Source and Compliance Agreement with their suppliers, to ensure that the limitations and prohibitions in the Restricted Substance List (RSL) are not violated, and that suppliers understand the ban on the use of alkylphenol ethoxylates (APEOs - only APEO-free chemical formulations are utilized for all chemicals, compounds, substances and other goods that they supply/deliver to LS&CO). All factories need to clear Chinese customs for export, and require letters of authority from the brand holders in order to export to FWT. This is one way of controlling unauthorized factories from exporting branded footwear.

The remaining apparel imported and distributed by Bounty Brands  - Levis, Diesel, Superdry, Hurley and Vans - are all purchased from the international principals, whose factories are monitored and audited against each company’s production and ethical standards (these may be found as follows : Levi’s: http://levistrauss.com/sustainability/production/ ; OTB Group (Diesel): https://www.otb.net/en/the-group/; Supergroup (Superdry): http://careers.superdry.com/about-us/csr-ethics-sourcing-and-environment;

Hurley: s3.amazonaws.com/nikeinc/assets/48555/Hurley_Code_of_Conduct.pdf?1445396121; VF Corporation (VANS): http://sustainability.vfc.com/people/worker-well-being-at-suppliers/vfs-auditing-policy/)

As part of the overall ESMS, the company will, over time, develop a specific management procedure for its supply chain (across the Group), which will include the implementation of a Supplier’s Code of Conduct for each subsidiary’s primary suppliers. This will be mainstreamed into contractual agreements with suppliers that are deemed to be operating in high risk situations (either geographically or due to the commercial sub-sector such as apparel or agriculture), and reviewed over time as needed. The focus of the Supplier’s Code of Conduct will be on fair labor practice, and product safety, and over time will include environmental compliance (ESAP #7). 

Human Resources management: Bounty currently employs approximately 1768 permanent staff members (53% male, 47% female) and an average of 312 temporary/contract staff, with a total management team of 27 people, across the various brands. The Group and each subsidiary company have various Human Resource Policies in place.  All Bounty companies take legal requirements into account concerning working hours, minimum wages, overtime compensation, benefits, sick leave etc via comprehensive policies. Sonko complies with Polish labor legislation and the relevant EU requirements and employs 312 people, with the majority working in the production department. The Executive team (Managing Director, Finance Director and Sales Director) have all been with the company for between 13 and 18 years. Sonko reports that none of the employees belong to a union and has been able to maintain low turnover levels (2.3%). The recruitment process is standardized as per Polish labor law, with several HR procedures in place to ensure the company is able to attract and retain industry specialists (talent management policies are aimed at promoting internal talent development and career progression, rather than filling positions from the market). A performance management system is in place, providing staff with performance-related bonuses.

South African employees are free to join a union of their choice, however union membership is low as most food and personal care companies fall under the Wholesale and Retail Sectoral Determination which provides for payment of a government-gazetted minimum wage, while Tuffy falls under the trade association Printing Industries Federation of South Africa. At Goldenmarc, the only company where representation is above the statutory threshold (>35%), a 3-year collective bargaining agreement has been signed with the South African Commercial Catering and Allied Workers Union (SACCAWU). Regular meetings are held in the office between Management (HR and Operations Manager), the Union representative and Shop stewards.  On average, employees work between 40 to 45 hours per week.  Operationally, depending if retail or manufacturing, there can be 1, 2 or 3 shifts in a day.

The HR and Ethics Code are clear about non-discrimination, however it will need to be enhanced to include a statement on child labor, use of forced labor, sexual harassment, and corruption (including extortion, fraud or bribery). Bounty is in the process of implementing a group-wide HR portal/system, which will ensure that all employees in the Group have access to one set of harmonized policies, so that procedures are applied consistently across the Group. The same principles and standards will be applied to future acquisitions, notably those in other jurisdictions where labor rights are not as well established (ESAP #8).

Grievance procedure: An Ethics Hotline is soon to be in place that can be used to anonymously report unethical practices, and a formal documented grievance mechanism is in place for all employees and contractors. South African labor standards are strictly applied, enforced and reported (to the Department of Labor) and alignment with these standards ensure compliance with PS2. The Polish operations also comply with the national labor legislation, and have a procedure in place specifically to deal with harassment/intimidation. This will need to be adapted to align with the Bounty Group HR policies and processes.

Occupational Health and Safety (OHS): There is an emphasis on OHS in the Group. The MDs of all subsidiaries are responsible for ensuring adherence to applicable Health and Safety (H&S) legislation and policies. As described in PS1, many of the companies in the Group have an appointed Health and Safety committee to ensure all the policies and procedures are implemented and enforced. All employees responsible for Health and Safety receive training, and in turn conduct OHS induction and refreshment training at the workplace. The Department of Labor also occasionally audit the premises. H&S risk assessments and fire risk assessments are a statutory requirement. Employees are provided with H&S information, instruction and training on: provision and use of necessary personal protective equipment (PPE); documented procedures / safe systems of work; basic first aid and occupational health; reporting of incidents; and preventative actions. The number of non-fatal injuries reported by the Group over the past year was 32, of which 18 were due to vehicle accidents (Rieses uses mopeds in their distribution network). This is being addressed via a vehicle safety plan (see PS4).  The HR Manager at Bounty is in the process of reviewing all relevant OHS documentation in order to centralize the procurement of PPE, training and medical insurance for employees. Sonko complies in this respect with all national / EU labor and OHS regulations.

It is envisaged that within a period of two years, any newly acquired company will implement the corporate E&S management system (ESMS), which will include OHS, LFS, emergency preparedness, and risk management (to comply with sections 3.2-3.7 of the General EHS Guidelines).

Contractor management: Bounty subsidiaries have Service Level Agreements (SLA) in place with contracted or outsourced parties for cleaning, security, pest management and other services. At Group level, these are being reviewed to improve efficiencies.  Once the corporate ESMS is in place, Bounty will implement a Contractor /Third Party Management Policy, and its service level agreements (SLAs) will be amended to include actions and measures necessary for them to perform their services in a manner consistent with the Group’s labor, OHS and environmental policies. Likewise, bidding documents for any future construction will include a mandatory section in the contract committing to the Group’s HSE and Emergency/LFS requirements (#ESAP 9). The same principles will be followed by acquired businesses, subject to local conditions. All contract staff will be included in EHS induction, with training on PPE, security procedures, access control, appropriate behavior and emergency procedures.

Medical surveillance, access to medical care, and workplace monitoring: Medical surveillance monitoring is not a statutory requirement for the distribution companies, other than those persons involved in the food re-packing activities at Liberty. A travelling clinic visits some sites on a regular basis to conduct eye and hearing tests or general health tests, as defined by each employee’s role in the company. First aid boxes and certified first aiders are also present where clinic services are not applicable. At Tuffy, a workplace environmental assessment is completed periodically (testing ventilation (ozone levels), air quality (formaldehyde and volatile organic compounds), noise levels as well as adequate lighting and temperature) by a certified occupational hygiene service provider. Sonko complies with the EU Food Safety requirements for medical testing of food handlers.

HIV/Aids program: The Group has an HIV/Aids statement in its Transformation and Non-Discrimination Policy, and provides employees with HIV/Aids testing on a voluntary and confidential basis (status is not disclosed to the company without consent); there is also strict confidentiality applied to all employees’ medical information, and the company management states they will in no way discriminate against an employee known to be living with HIV/Aids.

Resource conservation and Material Efficiency: No formal plans to target resource consumption are in place other than the statement of Environmental Care in the Ethics Code, and standard cost saving measures as part of the annual budgeting process. The plastic which is used for manufacturing its black refuse bags and some retailers’ carrier bags are made from 100% recycled plastic and is sourced from local, registered recyclers.

Energy consumption and efficiency: Electricity for the company’s operation is sourced from national grid.in both South Africa and Poland. As expected, the manufacturing operations are the highest consumers of energy (Tuffy and Sonko), and this is primarily due to process machinery operating 24 hours a day (agitation/washing, heating/baking, cooling, blowing and drying). Tuffy has 2 large 500 KVA generators, 1x 180 KvA and 1x 80 KvA generators – all on Auto Switch. Musgrave has a John Deer Powertech 6.8L generator, which carries about 600L of fuel. These are back-up generators which operate only occasionally. They are all refueled, tested and cleaned monthly by a certified external company. Company vehicles and trucks (other than forklifts which are battery-operated) in the South African operations are a mix of petrol and diesel engines, and consume approximately 198,035 L (petrol) and 166,204 L (diesel) per annum. Where possible, energy efficient equipment has been installed in the manufacturing operations, however there are no Group-wide targets to reduce energy use, other than the installation of master switches controlling large areas such office floors and warehouse areas, light sensors to allow for lighting only during movement, limited usage of desk heaters/air-conditioning etc. The energy consumption estimate for all existing subsidiaries is 13,540,000 KWh per annum (Sonko’s annual electricity consumption is 5,700,000 KWh while Tuffy utilizes 5,916,118 KWh), corresponding to approximately 12,940 tons of CO_2eq emissions per annum. With significantly increased acquisitions in the manufacturing sector, this could (over the period of the project), exceed the IFC’s greenhouse gas reporting threshold of 25,000 tCO_2eq emissions per annum.

Water and waste-water: Water is obtained from the respective municipalities and is potable. Consumption across the Group is monitored retrospectively via utility bills. Sonko utilizes water for the washing and processing of the rice grain, and Tuffy utilizes 11,265 KL water annually for washing (post-consumer plastics) and for cooling (condensors); for all other operations, water is used for domestic purposes (hand washing, drinking, floor cleaning etc). Bounty’s consolidated annual consumption is 34,922KL. As the ESMS is implemented, allied to the required EHS monitoring, this will become a more proactive exercise which will inform the need for water conservation initiatives and targets.

Where wastewater treatment is needed (process water from Tuffy and Sonko), the removal and treatment is outsourced to a certified 3rd party service provider, as none of the operations have waste water treatment facilities on site. Tuffy has implemented water recycling in its manufacturing operations, and re-uses most of its process water from two 25000L reservoirs. The water (mainly used for washing and cooling), is strained through a mesh filter at each rinse cycle, is collected, passively cooled and re-used in the condensers. Process water that contains water-based inks cannot be re-used and is decanted to 1000L tanks which are collected and disposed by a certified waste management company. All companies in the Group are connected to municipal sewerage systems.

Solid Waste Management: General waste is removed from all sites in South Africa and Poland by municipal contractors on a weekly basis, and as a Group there are plans to consult with certified service providers to design and introduce a waste management plan. Some of the subsidiaries segregate specific categories of waste for certified waste handlers/transporters to collect. For example, at Tuffy, wood, cardboard, metal and oil are separated and sent for recycling or re-use. No hazardous wastes are generated at any business other than used engine and hydraulic oil which is collected as a result of on-site vehicle maintenance at the Tuffy factories. The oil is collected in containers and a certified contractor (Enviroserve) collects and sells to oil recyclers. There are protocols in place for spillages, and the Tuffy sites all have certified chemical stores where the oil is kept before collection. An integrated waste management plan will form part of the ESMS that will be developed for the Group, as per ESAP#3.

Community Exposure to Disease (Product Safety):

Food: Rieses and Liberty Foods implement a Quality Management System incorporating random food quality testing (on site laboratory as well as outsourced microbial analysis). A portion of the Liberty DC is in the final stages of implementing a HACCP system for its re-packaging section (the clean rooms are almost completed), which will also require environmental monitoring (only 5% of products are re-packaged). Their major customers (for example national retailer Pick’n Pay) conduct regular food safety and quality audits, which are reported at management level, and corrective actions are implemented within defined timeframes. A procedure is in place for all product recalls and expired goods (these are returned to the manufacturer or supplier).  The Sonko manufacturing operations fulfil all the product safety safeguards – HACCP standards (Hazard Analysis Critical Control Point), ISO 9001 (Quality), BRC (Global standard For Food Safety), and IFS (International Food Safety) standards - whose compliance is verified annually by TUVNord (Polska) and the company is subject to annual customer audits by Tesco, Zabka, Lidl, PoloMarket, Eurocash, and Biedronka. The purchase of rice (all raw materials) is compliant with the requisite EU regulations, which includes pesticide monitoring; if there are any listed pesticides which are not allowed in the production, it is rejected. This applies to rice from the Asian suppliers, where controls are in place at the point of entry (EU border) and at the supplier’s premises (point of exit).

Plastic bags: Tuffy implements a rigorous Quality Management System, and employs an in-house Quality Control Team who monitors all raw materials to finished goods, with multiple QA/QC tests throughout the manufacturing process.  Every product is engraved with a Unique Product Tracking Code (UPTC) for traceability from the plant to consumer, in the event that a product must be recalled or if there is a consumer complaint.

Cosmetics: Prime Product Manufacturing, which produces the Annique skin and bodycare range, was the first company in South Africa to achieve ISO TC 22716 certification for Cosmetic Good Manufacturing Practice (GMP), as well as implementing six sigma, and have embarked on the process towards ISO 9000:2000 accreditation. The production areas feature positive pressure with regulated temperature and humidity. Water is processed through a deionizing plant with ozone purification, to guarantee the water quality required for cosmetics manufacturing. They also manufacture products for other well-known SA businesses such as Tiger Brands (listed on the JSE), Avon, Justine and Sh’zen (details on http://www.primeproductmanufacturing.com/). The rooibos (active ingredient) production process by The Red T Company conforms to an HACCP system and the final product is steam pasteurized to ensure a product of high microbial quality. The product is then sent in bulk (loose tea leaves) to various packers and exporters in South Africa. It is inspected, prior to shipment, by the PPECB (Perishable Products Export Control Board) of the Department of Agriculture.

Hazardous Materials Management and Safety: Some of the subsidiaries utilize diesel (generators), LPG gas, flammables (solvents) and lubricants, which are kept, in accordance with national legislation, in dedicated purpose-built and certified Chemical/Flammable stores. No external fuel tanks are used and no extra fuel is stored beyond immediate needs.

Emergency Preparedness and Response: As indicated in PS1, there is need to enhance / develop Emergency Preparedness Plans for all existing businesses. Although most of the buildings are leased, they are in compliance with the Polish/South African Building Standards and are certified by the Fire Department and Department of Health (LFS compliance is a condition of the lease agreement in all cases). As stated, functional Safety Committees are in place, which also assess and monitor L&FS. An assessment is currently being implemented across the Group to ensure that those companies not certified to ISO 18000 are compliant with the relevant OHS legislation.

Security Personnel: Bounty companies employ reputable (registered) third-party companies for their security. Personnel are accredited with the appropriate security association, are suitably trained, equipped, and regularly rotated. They are unarmed and follow a Standard Operating Procedure prescribed by the security company with whom they are employed and trained. Additional security measures also include:  access control gates and booms; electric fences, security lighting; CCTV which is monitored 24/7; emergency lighting; intercoms; and access to armed response in the case of an emergency. Security arrangements, policies and contracts which are in place at the subsidiaries are presently being reviewed so that they can be managed at Group level.

Vehicle/Driver safety: Bounty companies collectively own and operate a fleet of 191 vehicles (including 42 forklifts), 21 trucks and 71 mopeds/scooters. Drivers are licensed for operations and to carry passengers; occasionally driver sessions/road readiness training is arranged for motorcycle riders. All drivers of Forklifts are accredited every 6 months before being allowed to operate.

Rieses, which has reported 18 vehicle accidents in the last year, has implemented a number of initiatives to mitigate some of the risks, and this is  receiving priority attention as follows: a daily bike checklist is required to be completed for all riders; all vehicles are fitted with electronic tracking devices which are monitored electronically, and any transgressions such as speeding or hard braking are subject to disciplinary action; safety briefings are regularly included in weekly and monthly sales meetings; safety tips are regularly included in  the company newsletter; when the forecast indicates a probability of rain/ wet weather, the area managers send out a reminder email to all motorcycle drivers to exercise caution. Any riders that are involved in accidents that may affect their confidence are sent to training providers for a post-accident training assessment to assess the effect on their riding confidence and/or any unsafe riding habits which are corrected. Only once approved, drivers can resume their duties.

As part of its overall OHS management and the ESMS, the Group will develop and implement a safe driver and vehicle plan, including a training and monitoring program to enforce safe driving habits and reduce vehicle accidents (ESAP #10) across all subsidiaries

Pest management: Pest management is outsourced in each case, to a reputable pest control company who monitors rodents (using bait) every month. Fumigation for cockroaches, flies, pests is undertaken by the same company on a quarterly basis.

Bounty has not formally identified its significant stakeholders, which differ from company to company. Subsidiaries use an assortment of platforms through which the public can communicate, should they have questions or complaints. All companies have a website where the contact details are clearly shown, should a member of the community wish to contact them, and some have a toll-free number which customers can call.  If a grievance is lodged, there are internal processes to ensure that the Managing Directors are made aware of the grievance, and appropriate action is taken. In the case of Tuffy, a dedicated customer care line and customer care department is in place to lay formal complaints. The Group does not have a specific corporate Stakeholder Engagement Plan and grievance procedure, which will be developed and applied across Bounty Brands Limited, as per ESAP #11. The company will ensure that for all new acquisitions in other territories, affected local communities are proactively engaged via a Group communication/stakeholder engagement process.

Contact Person:Peter Spinks

Company Name: Bounty Brands

Address: 22 Sloane Street, Johannesburg

Email: peter@bb.co.za

Phone: +27 (0) 11 036 9419