PS7: Indigenous Peoples does not currently apply as the socio-economic baseline studies and an additional screening study confirm the absence of villages or settlements of indigenous peoples (i.e., pygmy groups), as per the PS7 criteria, in the project area.                                    

This is a Category A project according to IFC’s 2012 Policy on Environmental and Social Sustainability due to significant E&S risks and/or impacts associated with palm oil plantations, part of them located in ecologically sensitive areas, which feature a large land leasing process with concomitant potential for adverse socio-economic impacts in project areas.

Key E&S risks and issues for this investment are: (i) effectiveness and adequate implementation and funding of OPG’s Environmental and Social Management System (ESMS) and relevant operating procedures, at plantations, mills, refinery and ancillary facilities, including E&S management plans, organizational capacity and competency; (ii) human resources management, including labor rights and working conditions, worker accommodations, existence of employee grievance mechanisms, effectiveness of occupational health and safety (OHS) management, (iii) safe storage and use of pesticides; (iv) emergency preparedness and response; (v) effectiveness of stakeholder engagement, including community grievance mechanism; (vi) security risk assessment and management; (vii) process to access land, including respect of customary rights, and engagement with affected communities, including the process of Informed Consultation and Participation (ICP); (viii) effectiveness of mitigation measures to improve livelihoods of project-affected communities; and (ix) risks on biodiversity values in Critical or Natural habitats due to plantation development adjacent to or within such habitats and relevant mitigation strategy. 

 Environmental & Social Policies. Olam Global Holdings (OGH) adopted a Sustainability Strategy in 2022 which is structured across four pillars, namely (i) Nature; (ii) Livelihoods; (iii) Climate; (iv) Governance, and defined 2030 sustainability goals, including a timebound implementation of the strategy. As a subset of the corporate strategy, Olam developed a Sustainable Palm Oil Policy (last update in 2021) which commits OPG to sustainable palm oil production and sourcing, including achieving RSPO certification at all its direct operations. Olam supports the protection of high carbon stock (HCS) and high conservation value (HCV) forests and ecosystems, no development of peatland, zero burning, responsible labor practices, respect the rights (including customary) of local communities, and improving the livelihood of rural communities. OGH’s Corporate Responsibility and Sustainability (CR&S) function oversees the progress against these commitments. The Board CR&S Committee monitors OPG’s performance.

Olam’s corporate Sustainability policy framework, including the Olam Living Landscape Policy (OLLP, 2018), the Fair Employment Policy (FEP, 2018), and the Olam Supplier Code (OSC, 2021) are consistent with IFC’s PSs. The Environmental and OHS Policies (2016) applying to its agro-processing operations (mills, refinery, and biodiesel) commit Olam’s companies to compliance with country-level E&S legal and regulatory requirements. Olam has achieved RSPO certification for all its OPG palm oil plantations in 2022. In addition, Mouila Lot 3 has been certified against International Sustainability Carbon and Sustainability (ISCC) Standard in 2018. Ndende is expected to achieve this certification in 2023. OPG is the largest company fully RSPO certified in Africa and a palm operation to be climate positive. OPG will upgrade both policies (Environmental and OHS) to align its E&S performance against IFC PSs for its projects and operations, including plantations, mills, refinery, bio-diesel plant, CPO bulk storage, and all ancillary facilities (ESAP#1).

Identification of E&S Risks and Impacts. Plantation Site Selection. The Republic of Gabon has determined priority areas at a national scale for agriculture development, in its “Vision 2025” as described in the Strategic Plan for an Emergent Gabon (“Plan Stratégique Gabon Emergent”, PSGE). This country-level screening layer was coupled with the work carried out by the National Agency for National Parks (ANPN) and the National Council for Climate (Conseil National Climat – CNC), which included a detailed landscape analysis of physical and ecological constraints associated with oil palm cultivation, considering protected areas, HCV, HCS, habitat types, rainfall, slope/topography, soil quality/fertility, and distribution of villages and infrastructures. Following the analysis, all (Awala, three Mouila and Ndendé) concessions were proposed to be located within the “favorable” to “most favorable” area types from an ecological, agronomic and social perspective by the Government of Gabon, ANPN and CNC. Additional OPG E&S pre-selection screening criteria were then undertaken using high-resolution Lidar data. The plantable area within each of these concessions was further defined using ESIA and HCV Assessments during which certain areas were excluded completely or HCV areas demarcated to comply with the RSPO New Planting Procedure (NPP). OPG commenced land conversion after completion and validation of the ESIA and HCV Assessments and permit granting from the Ministry of Forest, Fishery and Environment (MEFPE/DGEPN) and after RSPO NPP process clearance and therefore used the output of these assessments to guide its site level planning and oil palm plantation development process, to ensure that all the relevant HCVs identified (both social and environmental) are maintained or enhanced. In addition, OPG established 5,200 ha of set-aside (on a voluntarily basis) during the development phase of the concessions. These were not classified as HCVs during assessment but were protected by OPG during development as they presented ecological and/or social values. These areas are maintained and monitored as done with HCVs.

Environmental and Social Impact Assessment. As required by Gabonese law and RSPO Principles and Criteria (P&C), OPG commissioned ESIA studies for greenfield concessions (Awala, Mouila Lot 1, 2, 3, Ndendé). For Makouke plantations planted in 1981 under AgroGabon, ESIA studies were not prepared at that time. However, upon having taken over these plantations in 2017, OPG conducted an ESIA gap assessment and HCV studies in 2019 to protect HCV areas. Mill’s ESIAs were commissioned, as per regulatory requirements, before the construction of the Awala and Mouila Lot 1 and 3 mills in 2015, 2017 and 2019. The brownfield Lambarene refinery was subject to an environmental audit and HAZOP/QRA assessment in 2017. The ESIA studies for the CPO Bulking Station at Owendo Port was completed in 2015. The Makouke quarry ESIA was completed in 2017. OPG obtained the authorization from DGEPN on the Hazard Identification and Risk Assessment (HIRA) studies for the three mills and refinery, without specific recommendations beyond an Environmental and Social Management Plan (ESMP). The ESIA studies, including water resource sustainability assessment, for the establishment of the 24,000 ha irrigation project in Makouke and Mouila Lot 1, 2 and 3, and the biodiesel plant and refinery at Owendo Port were respectively completed in June 2021 and in February 2022. A HAZOP/QRA was also prepared for the bio-diesel plant. ESIAs/HCV Assessments are available at https://www.olamgroup.com/products-services/olam-international/olam-palm-gabon.html.

OPG implemented an E&S risk mitigation process, which is composed of the following three components: (i) legally binding ESMPs defined as part of the ESIA process and agreed upon by the DGEPN through issuance of “Certificat de Conformité”. Effective implementation of the ESMPs is verified annually by DGEPN. During its appraisal, IFC reviewed the 2021/2022 ESMP’s progress report for all plantations, mills and refinery with implementation status, including a corrective action plan (CAP). Based on the information reviewed, OPG has progressed with the implementation of the mitigation measures outlined in the ESMPs. Latest DGEPN surveillance audits in January 2022 at Mouila operations identified areas of improvement at the landfill site, storage/disposal of expired CPP and fertilizers, and completion of social contracts. Third-party grievances were captured in the surveillance audit; (ii) a RSPO’s external verification audit is undertaken annually. The scope of this audit encompasses progress status of ESMPs annually updated through the DGEPN surveillance audit and the implementation of the RSPO’s Principles and Criteria. Prior to the RSPO’s verification audit, OPG’s Sustainable Development Department (SDD) undertakes internal audits to verify compliance with the RPSO standard’s requirements; (iii) at the request of IFC, Olam MATS function undertook a gap analysis of Olam EHS Procedures against the applicable and relevant sections of the WBG EHS Guidelines (General and Sector-specific – Vegetable Oil Production and Processing) in 2021. Based on the results of this comparative analysis, MATS’s EHS procedures applying to OPG’s agro-processing facilities were upgraded and used to undertake internal audits at two mills and the refinery. Corrective actions were summarized in a CAP which was implemented, based on the review carried out by IFC. For its agronomic practices at plantations, OPG is implementing its Agronomic Policy and Manual of Procedures developed by OGH based on good international industry practice (GIIP). Further details are provided in PS3 section.

OPG maintains a legal EHS and labor registry of the applicable Gabonese laws and regulations, accessible to the legal, SDD and operational management teams. Per RSPO certification audit process, legal audits are performed annually by a third-party auditor. Going forward, OPG will (i) review and update the ESMPs for all its plantations, mills, refinery, irrigation system, CPO bulk storage, biodiesel plant (when commissioned) and all ancillary facilities against IFC PSs and applicable and relevant sections of the WBG EHS Guidelines, and report on implementation progress status; (ii) develop description of budgeted CAPEX/OPEX for 2023-2024 for all operations to close any pending ESMP issues, identified through annual DGEPN surveillance audits and RSPO verification audits, and/or periodic internal MATS audits; (iii) develop and report on measurement of environmental, OHS and resource efficiency parameters confirming that E&S performance of all OPG operations meet applicable and relevant WBG guidelines values and national standards; (iv) update risk and legal registers, consolidating the E&S risks and impacts for environment, social, occupational health and safety, and labor issues (ESAP#2). The regulatory requirements and permit tracking register will be used to track and report compliance of OPG operations with applicable national E&S requirements in Gabon, OGH policy framework, RSPO, and IFC PSs. For the proposed greenfield investments (CPO mill at Mouila Lot 2 or 3), OPG will commission a PS-compliant ESIA study (ESAP#2), as per E&S policies which will be updated (ref. ESAP#1). A Hazard and Operability Study (HAZOP) and Quantitative Risk Assessment (QRA), including reservoir integrity, will be prepared for the Lambarene refinery, and based on the recommendations of the studies, OPG will develop and implement any necessary improvement actions to meet IFC’s requirements, in line with GIIP based on time-bound implementation schedule and budgeted CAPEX/OPEX (ESAP#2). OPG will also align its agronomic Standard Operating Procedures (SOPs) with the relevant sections of the WBG EHS Guidelines on Perennial Crop Production, 2015 (ESAP#2).

Screening for Indigenous Peoples. In 2021, OPG commissioned a study to screen for the presence of IP populations in the project area of influence. The study was conducted by an anthropologist with experience in Gabon and was based on a literature review and interviews with communities. The study did not identify the presence of villages or settlements of indigenous peoples (i.e., pygmy communities) as per the PS7 criteria, in the project area of influence; at the same time, the presence of members from the pygmy communities (Bakoya and Babongo) was anecdotally reported in some communities. The consultant was not able to conclusively identify, visibly locate or observe any such groups and therefore exclude their presence. OPG will undertake consultations with non-governmental organizations (NGOs)/ civil society organizations (CSOs) representing or supporting such IP communities in Gabon so as to triangulate the information from the screening study. If the presence of IP communities is identified through further engagement, OPG will undertake a consultation process and assess the project-related impacts on these identified communities. In the event of any impacts attributable to the project’s operations, OPG, together with the affected communities, will jointly develop and implement mitigation measures in a manner commensurate with the nature and scale of impacts, cultural characteristics, and the vulnerability of these communities and consistent with PS7 requirements (ESAP#2).  

E&S Management System & Programs. As mentioned above, as part of the roadmap developed to improve its E&S performance and meet the IFC PSs, OPG developed and has implemented E&S policies, E&S risk and impact assessments and implemented mitigation measures as defined in the ESMPs, strengthened by the requirements from DGEPN’s surveillance audits and by the RSPO verification audits, and supported by the internal audits carried out by SDD and MATS. In addition, as described below, OPG has consolidated its sustainability/EHS function while strengthening its training plan, emergency preparedness and response, and monitoring and reporting. Under the proposed investment, OPG will finalize the development and implementation of its ESMS, aligned with IFC PSs, covering all its operations, to include the actions agreed under the ESAP#3. The ESMS will undergo a verification audit by an independent consultant. In case of a CAP following the verification audit, time-bound implementation schedule and CAPEX/OPEX will be assigned (ESAP#3).

E&S Organizational Capacity/Competency. OPG has established a Sustainability Development Department (SDD) in 2020, led by the VP Sustainability and with a staff of 271, organized in five divisions:  Biodiversity, Social, Certification and Compliance, Operational Safety and Health and Safety Process Divisions. All Divisions are led by a manager and represented at operations-level. Over the last three years, the safety function has been strengthened to implement more robust OHS management practices at the plantations where most of the recorded loss-time injuries were taking place. The biodiversity function has been strengthened through the recruitment of a biodiversity manager in September 2022. OPG will further strengthen its social and environmental functions going forward. This will include recruiting a suitably experienced Senior Social Manager to oversee the stakeholder engagement and livelihood and community development activities (ref. ESAP#3). A Learning and Professional Development Program, based on professional needs assessment, is scheduled to further strengthen competency of the SDD team in 2023. In compliance with national requirement, each concession/mill and refinery have an OHS Committee (“Comité d’Hygiene et de Sécurité au Travail”). OPG received the technical support of Olam MATS function for updating its EHS Procedures and auditing its implementation at mills and refinery. OPG also established an Independent Social and Biodiversity Advisory Panel in 2022 which objective is to advise OPG in aligning with IFC’s PSs by reviewing Project commitments and progress (including the OPG’s Biodiversity Action Plan - BAP), raising issues, recommending actions, and identifying additional work required to achieve social and biodiversity objectives of the company. OPG will strengthen the Panel by appointing an additional member with expertise in forest-based livelihoods and community development (ref. ESAP#3). Further details are found in PS6 section below.

E&S Training. OPG EHS managers and plant-level officers are providing mandatory EHS induction training to all workers, including permanent employees, temporary/casual workers, contractors and service providers. This training program includes, among others, Olam’s six OHS imperatives (lockout tagout, permit to work, reporting/recording accidents, bi-monthly system audit, workplace risk assessment and driving safety rules). The training plan also includes refreshers and specialized training (e.g., first aid, handling of weights). OPG will review and update its EHS training plan to integrate trainings relevant to E&S policy updates, technical and procedural updates and changes adopted as part of the ESAP (ref. ESAP#3).

Emergency Preparedness and Response (EPR). OPG has an emergency response procedure, and each mill and refinery has adopted a plant-level emergency response plan (known as Plan d’Opération Interne - POI) which is reviewed and approved by the local Fire Department. All mills and refinery are stationed with 24/7 trained firefighting teams. A team of paramedics/nurses/doctors is also present 24/7. Fire drills are carried out monthly. Fire risk assessments were conducted at three mills and refinery in February 2022, using as key reference the National Fire Protection Association (NFPA), the GAPS (Global Asset Protection Services) and Olam Fire Protection requirements, and relevant recommendations for improvement of fire system were identified, such as the upgrade of water reservoir, fire hydrant system and network. As part of this proposed investment, OPG will provide a consolidated CAP for the upgrade of its fire prevention system at mills and refinery, including time-bound implementation and CAPEX/OPEX for completion. OPG will also develop an overarching emergency preparedness and response (EPR) framework procedure to guide the upgrade of the plant-level EPR plan, covering relevant emergency scenarios for mills, refinery and bio-diesel plant in accordance with IFC’s PSs and GIIP. The procedure will include areas of improvement identified (e.g., hazard identification/risk assessment for all emergency scenarios, performance provisions, types/quantities of emergency equipment, identification of closest medical facility, emergency communication plan and relevant tools, maintenance routine). The plant-level EPR plans will include a process to provide appropriate information, assist and collaborate with local authorities and neighboring communities in case of emergency situations. The roles and responsibilities of the Emergency Response Team (ERT) will be clearly defined, including notification and activation process, training, drills and coordination and communication with local authorities and neighboring communities (ESAP#4). As mentioned above, storage and handling of gasoil and kerosene at the Lambarene refinery will be subjected to a HAZOP/QRA study and mitigation plan based on the outcome of the study (ref. ESAP#2).

E&S Monitoring & Reporting. SDD maintains monthly EHS performance dashboard for its operations, including KPIs, in line with each of its Divisions, namely Compliance and Certification (licenses/permit, including ESMP/MATS implementation, RSPO/ISCC/ISO compliance, contractor’s compliance, waste management, water quality), Environment (HCV 1/4 compliance, biomonitoring, elephant response), Safety (PPE use, warehouses, infrastructure safety, OHS leading and lagging indicators for employees and contractors, road safety and training), Social (HCV 5/6, grievances, community development projects and on-going engagement with NGOs and stakeholders) and Medical (annual medical check-up, emergencies and public health sensitization). Specific monitoring dashboard on sustainability KPIs for plantations, mills and refinery also exist, including water and energy usage. The EHS Manager undertakes monthly inspections of plantations, mills, and refinery while implementation of the six OHS imperatives is verified bi-monthly. Scheduled annual surveillance audits by DGEPN on ESMP progress status and internal (SDD) and external (RSPO/ISCC) annual verification audits take place annually for plantations and mills. In 2019, OPG prepared an E&S Monitoring Plan, including measurement of environmental parameters (e.g., energy and water usage/efficiency, ambient air quality, point source air emissions, surface water / underground monitoring, effluents, noise (workplace and community receptors), solid waste and hazardous material management, workers and community grievances, working conditions, including heat stress and light flux intensity). Going forward, these monitoring results will be included into the SDD dashboard, including performance with respect to guideline values in WBG EHS Guidelines for Perennial Crop Production and for Vegetable Oil Production and Processing. OPG will also define annual EHS objectives and targets as part of the ESMS (ref. ESAP#3), including resource efficiency at plantations, mill and refinery, GHG, and OHS statistics (permanent employees and contractors). As indicated, in addition to MATS annual audit report of all mills, refinery, biodiesel and logistics, OPG will commission an independent verification audit of the ESMS. In term of reporting, OPG prepare and disclose palm quarterly dashboards and annual Olam Palm Sustainability Update on its website and RSPO website. Going forward, OPG will prepare a Sustainability Report as per GIIP (e.g., GRI-G-4 Guidelines) which will be annually disclosed on its website while local communication plan on E&S performance and implementation of the ESAP will be delivered at the local level, including affected communities (ref. ESAP#3). The ESMS will include a reporting procedure to report annually the E&S performance of OPG operations to OGH’ Board of Directors.          

 As of December 2022, OPG employed about 5000 direct workers, of which 96% were Gabonese nationals and 37% were women. Around 20% of the Gabonese employees were recruited from project affected villages, the majority of whom were employed as plantation workers. In addition, up to another 4000 workers were employed by contractors and service providers to work on OPG plantations.

Human Resource Policy and Procedures. OPG has adopted the Olam’s FEP which is aligned to PS2 requirements and is applicable to all workers including those employed by third parties. OPG is in the process of operationalizing the Policy at the plantation level based on updated Human Resources (HR) procedures. OPG has a Sexual Harassment Policy and a Code of Conduct (CoC) that defines the values and behaviour that OPG staff should adhere to at the workplace. All direct employees are onboarded on key HR documentation, payroll systems, and EHS requirements at induction. The implementation of HR policies and procedures for the workforce is led by an HR Director and supported by an adequate number of site HR managers and payroll officers. To ensure consistent application of labor requirements, OPG will develop and implement a Labor Audit Procedure for all sites and for all workers including those employed by contractors and service providers. The Procedure will define (i) the parameters to be audited based on the FEP, PS2 and Labor Code requirements; (ii) the frequency of both internal and external audits and reporting requirements; and (iii) the process to address any audit findings (ESAP#5).

Working Conditions and Terms of Employment: The OPG ‘Réglement Intérieur’ defines the terms and conditions of employment in line with the Gabonese Labor Code. All workers are required to have a labor contract, which, at a minimum, states the nature and category of employment, place of employment, start date and duration, working hours, remuneration, leave, benefits, and employee rights and obligations as applicable. All employees receive pay slips showing the number of hours worked, wages (including overtime provisions), and statutory social security deductions. OPG has a salary schedule that sets out the pay for different categories of workers. No directly employed workers are paid on a “piece work” basis. The minimum wage at OPG aligns with the statutory minimum wage in Gabon. As Olam has signed up to the Global Living Wage Coalition (GLWC) standards and commitments, OPG will undertake a living wage assessment for Gabon using the GLWC benchmark established for Gabon, and based on this, develop a road map to align the country operations to living wages (ESAP#6). Absenteeism rate at the plantations is high, especially amongst local and female workers. Other working condition-related issues that were observed included lack of in-field water, sanitation and shade facilities. OPG will commission a gender assessment of all OPG workplaces (covering discrimination, equal opportunities, working conditions, health and safety and risk of gender-based violence and harassment (GBVH) and based on the findings, develop a Gender Action Plan to strengthen labor and working conditions across OPG operations (ESAP#7).

Workers Accommodation. Housing, including essential services such as electricity, water and sanitation, is provided free of cost to OPG employees and to third-party workers depending on need and availability. An Accommodation Policy and a Code that sets out the eligibility criteria, general rules of conduct, and roles and responsibilities have been updated and are applicable to all workers who have access to housing. The responsibility of allocation and management of housing to third-party workers is with the contractor employing them. Currently OPG does not monitor all housing sites to ensure that the accommodation terms are being respected. OPG will conduct i) a gender sensitive gap analysis of all worker accommodation against PS2 requirements; ii) based on the findings develop and implement corrective measures; and iii) develop a procedure to monitor the implementation of the Accommodation Policy and Code at all worker accommodation sites (ESAP#8).

Non-discrimination and Equal Opportunity. The FEP has a commitment to non-discrimination and equal opportunity through its standard on “Diversity and Inclusion”. Furthermore, OPG appointed a Gender and Diversity Assistant Manager in 2021, established Gender Committees (GC) at all sites to manage gender related issues, and is developing a Gender Strategy to enhance equal access to employment opportunities.

Workers Organization. As per the requirements of the FEP and the Réglement Intérieur, OPG supports freedom of association and collective bargaining for its workers. Numerous unions are represented at OPG. Each site has a Workers’ Representative Committee (WRC), the members of which are either assigned by the unions from the body of workers or elected directly by the workers. The WRC serves as a forum for communication and consultation between OPG and representatives of the unions or employees on industrial relations, including the welfare of employees and grievances. Typical issues discussed relate to salary increases, promotions, implementation of the Collective Labour Agreement (CLA) working conditions, and benefits. A CLA between OPG and its workers has been in place since 2017. At the time of appraisal, OPG was in the process of engaging with the unions to start the negotiations for a new CLA. 

Protecting the Workforce. The FEP has provisions on the prohibition of child labor and forced labor. Furthermore, the minimum age of employment at OPG is 18 years. All potential employees are required to present proof of age in the form of a birth certificate or an identification card.

Worker’s Grievance Mechanism. OPG has in place a labor grievance mechanism that specifies the process for managing grievances, the entities involved and the timelines. Whilst grievances can also be made through the WRC and the GC (for grievances related to GBVH), the mechanism currently does not explicitly account for these routes. Furthermore, the procedure lacks provisions for confidentiality and non-retaliation and does not extend to third-party workers. OPG will update and operationalize the labor grievance mechanism, in accordance with FEP, and aligned with PS2. OPG will identify suitable support services for complaints related to GBVH, establish suitable referral pathway for such services and facilitate external training for the GC to execute its role effectively and sensitively. The labor grievance mechanism and referral pathway will be accessible to all employees, including third-party workers (ESAP#9).

Workers Engaged by Third Parties. OPG utilizes contractors and service providers to undertake plantation-based activities such as harvesting fresh fruit bunches, loose fruit picking, and loading and transporting. Workers engaged by contractors are paid on a “task work” or “piece work” basis and not on time taken to achieve the task target. Contractor management is the responsibility of the Operations team and, beyond a documentation review, OPG currently does not monitor third-party workers’ terms and conditions of employment including the number of hours worked. OPG will (i) appoint a dedicated manager to oversee contractor management and act as an interface between HR and Operations; (ii) develop and implement a contractor management procedure that (a) defines the minimum contractual EHS/labor requirements including those pertaining to the FEP, wages, benefits and other social security obligations, recruitment process, access control, and worker data management; (b) establishes a process to procure, select, train, and monitor contractors and service providers with respect to the FEP requirements; and (iii) undertake a minimum wage assessment of workers engaged by third parties, to validate the assumptions used to determine the pay rates set for task-based work (ESAP#10). Labor and working conditions performance of contractors and service providers will be audited as per the procedure established in ESAP#5.

Occupational Health & Safety. Key OHS risks for workers in palm oil plantations includes musculoskeletal conditions, injuries from sharp tools and FFB’s thorns, snake bites, infectious diseases (e.g., malaria and leptospirosis), road accident, and potential exposure to pesticides and herbicides. Risks at palm oil mills and refinery include slippery working conditions, working at heights, hot environment, confined space, and hearing loss due to excessive noise levels at specific workstations. Since 2021, as a result of a tragic road accident, and based on the review of the relevant statistics, OPG has been working towards strengthening safety management practices and performance at its operations. A risk assessment (Hazard Identification and Risk Analysis - HIRA) was conducted by an independent OHS consultant. Based on the HIRA recommendations, OPG took action to strengthen OHS management, including (i) development / implementation of a 2022-2025 Strategic Management for Health and Safety, (ii) strengthening SDD’s OHS function through the establishment of two safety teams (operational safety division focusing on PPE, warehouses, infrastructure safety and monitoring of OHS statistics; health and safety processes division, focusing on preventive health, mills, road safety and training) and competency of “Comité de Santé et Sécurité au Travail”, (iii) professional development on ISO 39001 (road safety), including truck safety and checklist, ISO 45001 (OHS) management systems and safety leadership, (iv) implementation of daily safety and toolbox talks at work stations, (v) strengthening the use of PPEs, including provision of harness and lifeline for working at heights, implementing machine guarding, upgrading firefighting systems, improving lighting systems, and ensuring access to drinking water to workers in plantations and mills/refinery, and (vi) monthly OHS performance review at plantations, mills and refinery. Following implementation of these measures, the number of recorded Lost-Time Injuries (LTIs) reduced from 1174 in 2019 to 132 in 2022 and Lost Time Injury Frequency Rate (LTIFR) decreased from 15.98 in 2019 to 1.26 in 2022. Going forward, OPG will be focusing on improving reporting and analysis of unsafe working conditions and near-misses, including the digitalization of their reporting, easing the process and allowing robust leading indicators’ collection and interpretation. Road safety measures are further discussed under PS4.

OPG adopted a medical policy in March 2021 which defines the implementation of provisions for occupational health, prevention of professional risks and illnesses, and emergencies management. Each facility operated by OPG has a health clinic staffed with a doctor and nurses, and with an ambulance. A medical check-up is required for all workers, and annual check-ups (including audiometry starting in 2023 for mills/refinery workers) have been rolled out since 2019. CPP sprayers undergo cholinesterase testing twice a year. Furthermore, OPG implements measures to protect the health of expectant mothers undertaking potentially hazardous activities such as applying CPPs; these include sensitization and awareness of the nature of the activity, and where required job reassignment in line with FEP requirements. OPG will strengthen its OHS management practices at plantations /mills/ refinery /logistic, including increasing medical oversight from SDD’s Health Division in monitoring high-risk working conditions (e.g., CPP sprayer), promoting public health practices at worker’s accommodation, and ensuring implementation of Olam’s Water, Sanitation and Hygiene (WASH) standards at all operations (ESAP#11).

Workplace noise level measurements were undertaken for the mills and refinery. This noise mapping identified high risk workstations for noise exposure (i.e., above 85 dB(A)). OPG identified engineering measures to reduce noise level in high-risk areas through the installation of noise-level mufflers at genset and/or installation of acoustic walls (blowing section at the Lambarene refinery). Management controls, such as limiting the noise exposure of mill and refinery’s workers, will also need to be implemented. Going forward, audiometry tests for workers at mills and refinery will take place – as part of annual check-up, and specific operational and workplace suitability criteria and engineering/administrative requirements will be defined in relation of the results of the tests (ref. ESAP#11). 

 Resource Efficiency. The refinery relies on diesel generator (genset) while the mills rely on diesel genset for start-up only, then self-sustained by palm by-products feeding the boilers that generate the power. Water and energy usage and efficiency are monitored and recorded in line with GIIP. To further improve resource efficiency, OPG started the implementation of measures which include the installation of biogas co-generation power plants at the mills, using fibers and palm kernel shell as feedstock. A first plant was installed in 2022 in Awala and others will be completed at Mouila Lot 1 (Bilala) and 3 (Dola) mills in 2023-2024. A fourth mill will be constructed as part of the project, and it will be equipped with the infrastructure needed to capture the biogas from POME. Upon completion, OPG’s plantations and mills, and their ancillary facilities, will be energy self-sufficient. Empty Fruit Bunches (EFBs) are used as organic fertilizer, in addition to synthetic fertilizer.

Greenhouse Gases. In the baseline scenario, it is estimated that the operation emits 248,400 tons GHG per year, of which 179,100 tons GHG (or 72%) are associated with fugitive biogas emissions from the POME ponds. The project comprises capturing this biogas and combusting it onsite, avoiding both the fugitive emissions and diesel use in gensets in mills and the refinery. The remaining operations emit 68,400 tons GHG, resulting in 180,100 tons GHG avoided as a consequence of the project. Consequently, the emissions intensity of CPO production will reduce from 1.63 tons GHG / ton CPO to 0.36 tons GHG / ton CPO with the project implementation. Based on 2022 data for the three mills, taking into account emission source from land conversion, CO2/NOx emissions from fertilizers and fuel consumption while subtracting carbon sinks from crop sequestration and sequestration from HCV areas, it is estimated that OPG has a negative GHG balance of 623,438 tCO2eq (-9,82 tCO2eq/ha). OPG is also increasing its conservation area which will result in a larger carbon sink. It is expected that the reduced GHG intensity of the CPO production operations due to the project, plus a larger carbon sink, will result in a larger negative value for the operations of OPG. OPG used RSPO calculator for assessing its GHG emissions and will report annually on its GHG emissions in accordance with internationally recognized methodologies and good practice.

Air Emissions. OPG has adopted an Air Quality Management Plan to manage facility’s point source air emissions and ambient air quality. Applicable performance requirements are Gabonese legal and regulatory requirements (Environment Code for Air, Environmental Code for Smoke and Dust) and relevant WBG General EHS Guidelines (air emissions and ambient air quality). Based on ambient air quality monitoring in February 2022 at the refinery, concentrations measured were within the WHO Ambient Air Quality Guidelines values. As for the point source emissions at its three mills and refinery, including the boiler and diesel-fired gensets, the results indicated compliance with Gabonese requirements and were within the applicable levels of the WBG EHS Guidelines, aside from particulate matter which was reported as slightly above guideline value. Olam will be installing soot blower and will implement measures to abate particulate matter emissions to achieve levels consistent with the applicable guideline value. OPG will continue to undertake measurement of its ambient air quality and stack emission at mills and refinery (ref. ESAP#2 (iii)).

Water resource sustainability assessment. Water supply for mills and worker accommodations is currently sourced from surface waters. As this supply requires treatment prior to usage at the camps (including use of chemical products, such as coagulants and flocculants), OPG started to install borewells to provide with drinking water. A Water Resources Sustainability Assessment was carried out for the c. 24,000-ha drip irrigation project at Makouke and Mouila Lot 1, 2 and 3. Maximum drip-irrigation water demands for the project during the months of August and September can be met from the Ngounie and Ogooue rivers and irrigation demands amount to 5% of the 20-year minimum daily flow (5% percentile) in September at Mouila. Water availability for the Makouke and Bindo plantations near Lambarene is plentiful as the average daily flow of the Ogooue river is 4,700 m³/second. A maximum threshold of 20% of total flow of the water sources were recommended in the ESIA studies for the irrigation project as a conservative approach to avoid any downstream impact. This recommendation was agreed upon by DGEPN and reflected in the delivered Certificat de Conformité for this project. At least until 2050, climate change is not expected to have a significant impact on the water availability for OPG plantations. OPG will install measurement stations to collect daily flow data at the water sources providing water to the plantations to monitor and report on water availability and compliance with the limits agreed by the local authorities. When the project will reach Mouila Lot 2 and 3 (scheduled in 2025), similar monitoring will take place for Ovigui and Dola rivers to confirm the potential for irrigation from these tributaries. As per its existing surface water and planned underground water monitoring, OPG will strengthen the analysis of its monitoring results by a hydraulic expert – assigned to the Independent Panel – and will communicate the results of such monitoring to the neighboring communities of its operations, through Community Liaison Officers (CLOs). This approach will support the implementation of a participatory and adaptative water management and monitoring program which will cover water resource availability, effluent management and water quality (ESAP#12).

Noise. OPG has updated its noise monitoring for sensitive receptors during day and night-time, as the refinery is within the city limit (even though land use is industrial zone). Latest measurements indicated that the noise values are within WBG EHS Guidelines. OPG will formalize its noise management approach into a management procedure for workplace noise and community receptors (ESAP#13).

Effluent Treatment Plant. The Lambarene refinery generates industrial effluents, which are channeled to an effluent treatment plant (ETP), which was upgraded in 2022 to meet statutory requirements and operates within the levels as defined in WBH EHS Guidelines on Vegetable Oil Production and Processing. The results of December 2022 confirmed compliance with guidelines values. The Palm Oil Mill Effluent (POME) are channeled into open lagoons for anaerobic digestion (including biogas capture) and for land application. OPG developed a SOP for POME discharge (land application) aligned with RSPO Principles & Criteria (P&Cs). Taken into account the Iroungou spill in May 2022 and recent minor spills, OPG will strengthen its POME management practices through the recruitment of a consultant to review and upgrade its SOPs while POME agent will be hired for each mill to improve ponds and land application supervision, in addition to include effluent management in the water management and monitoring program under ESAP #12. As part of the proposed investment, OPG will upgrade the storm water drainage at Lambarene refinery to collect and treat by the ETP potentially contaminated storm water from certain areas of the refinery, prior to be discharged in the Ogooue river (ESAP#14).

Water quality monitoring. A surface water monitoring program has been established since 2011 to monitor water quality with 46 sampling points in the water streams upstream and downstream of OPG plantations. Water analysis is done twice a year, and results provided by the company show that the levels of pesticides detected are within the local regulations for surface water quality. OPG is installing a series of piezometers at mills and plantations to monitor groundwater levels and quality and timely detect potential pollution. Piezometers at Awala have been observed during the field appraisal and same device will be installed at the other sites (mills and plantations at Mouila Lot 1 and Lot 3). Three piezometers will be installed at each site, one under the POME lagoon, one under the POME land application and another one in plantations (as pilot) (ref. ESAP#12). The water management and monitoring program under ESAP #12 will integrate all pollution management and monitoring actions relevant to the protection of the surface and ground water resources.

Waste Management. OPG has developed Solid and Hazardous Waste Management plans at all sites, as per Olam MATS EHS Procedures which are aligned with GIIP and relevant WBG EHS Guidelines. The waste management plans identified solid and hazardous waste streams generated; estimated quantities; defined management measures on sort/reduce/re-use/treatment/storage and disposal of each waste stream, implemented monitoring /reporting requirements; identified final disposal facilities to receive waste; implemented a chain of custody mechanism, including due diligence of service providers. Non-hazardous waste stream generated at OPG’s operations are mainly organic waste, paper and cardboard, plastic bottles and metal scraps. Sorted waste streams are collected at waste storage areas which are operated by OPG within the concessions. In total, five waste storage areas are currently operated. Each waste storage area includes landfilling cells for biodegradable waste and dedicated storage areas for the other types of waste, including hazardous wastes. Areas of improvements include waste segregation at worker’s accommodation and the frequency of the disposal of plastic and metals by licensed service providers. Organic waste, such as EFBs and palm kernel shells, are used as biomass at the mill’s boilers. EFBs are also distributed in plantations as natural fertilizers. Hazardous wastes generated from the operation/maintenance activities include used oils, generator filters, lubricant containers, soiled rags, soiled PPE, medical waste, waste electrical and electronic equipment, pesticides containers, and sludge from oil/water separator. Licensed service providers are under contract to collect and dispose of hazardous waste and other wastes, such biomedical wastes, and used oil and chemical containers. A waste manifest system is implemented. As per ESAP#2, OPG will strengthen its waste management practices, including audit of service providers (collection, transport and disposal). 

Storage of Hazardous Materials. Hazardous materials storage at the mills and refinery includes diesel storage tanks for generators and storage tank of hydrocarbons. Storage of hazardous materials, including installation of secondary containment, need to be upgraded – especially in the plantations, providing for adequate physical separation between incompatible materials stored in tanks, installation of overfill protection (e.g., automatic fill shutoff valves on storage tank and refueling station), and integrity tests of reservoirs, among others. OPG will strengthen the implementation effectiveness of its hazardous materials storage areas and relevant procedure which will be implemented at all its operations (ref. ESAP#3).

Pesticide Use and Management. OPG adopted Integrated Pest and Disease Management Practices as part of its Agriculture Policy and SOPs Manual which was updated in 2022. With the establishment of HCV corridors within and around its plantations which are hosting birds of prey and snakes, OPG reported that there are no significant rodent issues in its plantations. Cultural methods involve planting beneficial flowering plants stimulating the breeding of leaf eating insect’s natural predators. Biological control includes the use of infectious fungi and bacteria. The use of agro-chemicals is a last resort control method. In accordance with Olam Sustainable Palm Policy (2021), OPG does not use paraquat and other pesticides categorized as World Health Organization (WHO) Class Ia and Ib, as well as those that are listed by the Stockholm or Rotterdam Conventions. For safe usage of agro-chemicals, OPG developed SOPs for spraying, medical check-up of CPP sprayers and chemical hazard communication. Use of PPEs are strictly applied. As indicated, CPP sprayers undergo medical screening. Safe storage of CPPs have been observed during IFC’s visit, including access to Material Safety Data Sheet (MSDS), inventory log, and CPP sprayers changing rooms/showers and PPE lockers.                                                  

 Community Health and Safety. Aside from the Lambarene refinery, which is located within the city center, all other OPG operations are either located at least three km away from the nearest communities (plantations) or within the Owendo Port (the bulking plant and the bio-diesel refinery). With respect to the Lambarene refinery, OPG will undertake a QRA to assess explosion risk and implement any corrective measures needed (ref. ESAP#2). Furthermore, the EPRPs will include a process to provide appropriate information, assist and collaborate with local authorities and neighboring communities in case of emergency situations (ref. ESAP#4).

Road Traffic Safety. OPG’s operations are equipped with a fleet of thousands of heavy vehicles (e.g., tractors, dump trucks), heavy machines (e.g., bulldozer, graders, compactor), CPO tankers, and light vehicles (e.g., ambulance, school buses, workers transport trucks). Road traffic safety (RTS) risks of OPG’s operations are significant and resulted in several road accidents since 2011. As per the above mentioned fatal road incident of June 2021, OPG commissioned a road transportation and safety risk analysis, in accordance with ISO 39001 – Road Traffic Safety (RTS) Management System. As indicated above, the audit’s recommendations were included into OPG’s Health and Safety – Strategic Management Plan for 2022-2025 and implemented through a Road Safety Action Plan. This action plan included the formalization of a Road Safety Policy in 2022, the recruitment of a road safety leader and mobile teams (Brigade de Sécurité Routière) at plantations focusing on the implementation of road risk assessment procedures and mitigations, such as road safety signage, speed control using speed bump and radar gun, random alcohol test within plantations, enforcement of a maximum speed of 30km/h in plantation and 70km/h on surfaced road for company and contractors’ trucks. Every driver (OPG staff or contractor), following training, must sign a Commitment Letter acknowledging the understanding of OPG Road Safety Policy and Code of Practices, which clarifies disciplinary measures in case of violations. Worker’s transportation fleet was also modified, to allow for all workers to be seated and to use a seat belt. A checklist of 52 indicators was established and is applied prior to finalizing contractual agreement with transport contractors, complemented by regular field verification of lighting, brake and tire conditions, horn, in addition to document checks such as driver licenses and insurance. For each driver, OPG has established a safety pass valid for three months, and renewal will be validated by the road safety leader. Additional road safety measures include the (i) strengthening of compulsory tests of alcohol testing, 24/7, (ii) internal safe driver training and qualification; (iii) internal audit on road traffic safety management (aligned with GIIPs/ISO 39001) by 2023.

Food Safety. OGH adopted a Quality and Food Safety Policy (2016) which commits to certify its processing facilities to one of the Global Food Safety Initiatives (GFSI) recognized standards. OPG implemented a Hazard Analysis and Critical Control Points (HACCP) for its Lambarene vegetable oil refinery. The operation is ISO 22000 (Food Safety Management System) certified for processing and supply of refined palm oil and fractions since 2021.

Influx Management. The influx of migrant workers, and possibly, other groups of people in search of economic opportunities created by the project, into the communities around the concessions, is a risk that was identified and could lead to negative impacts including social conflict, increased pressure on community infrastructure and resources (including biodiversity), increased risk of health issues, and GBVH. These risks and potential impacts were not adequately assessed in the ESIA studies or have not been monitored by OPG. OPG will undertake an assessment of the risks and impacts of the influx of migrants and based on the findings, develop an Influx Management Plan that is designed to effectively manage such risks and impacts (ESAP#15).

Security Personnel. Security personnel at the plantation sites and mills is either directly employed by OPG or by a private security company. Some of these security personnel are recruited from the local communities. The security personnel are unarmed and are mainly used for access and perimeter control and general surveillance at its sites. OPG will undertake a Security Risk Assessment and develop a Security Management Plan as per PS4 requirements and as guided by the IFC Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts. The Security Management Plan will include provisions for annual/refresher training to the security personnel on the OPG Code of Conduct and Sexual Harassment Policy (ref. PS2) and the Voluntary Principles on Security and Human Rights (VPSHR) (ESAP#16). 

 Of the OPG concessions, three plantations (Makouke, Mouila Lot 2, part of Awala) overlap the Atlantic Equatorial coastal forests ecoregion. Awala partially overlaps the Central African mangroves ecoregion. Three plantations (Mouila Lot 1, Lot 3 and Ndendé) overlap the Western Congolian forest-savanna mosaic. In total, OPG concessions cover ~202,500 ha of which ~63,330 ha is planted. No additional land clearing or planting is planned. All conversion and planting took place between 2011 and 2017. The total cleared area exceeds the planted area because additional land was cleared for supporting infrastructure and facilities, estimated at 10% of the planted area (~6,000 ha).

While most clearing occurred before IFC’s involvement (2017), most of the cleared land is treated as Natural Habitat (a total of 24-25,000 ha forest, 34,600 ha savannah) for the purpose of meeting PS6 requirements under the proposed investment. Cleared Natural Habitat was of variable quality, including heavily logged and degraded areas. Multiple studies (e.g., ESIAs, HCV assessments, specialist fauna and flora surveys) have been completed and included inputs from independent biodiversity experts and organizations (e.g., the National Agency for National Parks, Missouri Botanical Gardens, World Wildlife Fund). Consultation with IUCN’s Avoidance, Reduction, Restoration and Compensation Task Force on apes has started and will continue through the finalization of the project’s mitigation strategy.

Monitoring programs for fauna in the HCVs are ongoing since 2018, and priority biodiversity values are three fauna species: Central Chimpanzee, Western Gorilla, Forest Elephant, and one habitat – lowland terra firma forest. Critical Habitat is triggered for threatened species (e.g., Chimpanzee, Gorilla, Forest Elephant, Slender-Snouted Crocodile, Red Capped Mangabey and various plant species), restricted range species (e.g., various terrestrial plants and fish species), significant concentrations (e.g., Rosy Bee-Eater), and threatened ecosystems (savannah dolines).

Completion of the ESAP will align the project with PS6 requirements. Regarding avoidance, as indicated, OPG concessions were selected based on national conservation and development plans, as well as stakeholder feedback, to avoid high value forest. The process followed for site selection has been formally adopted in Gabon through a National Directive on sustainable site selection of the palm oil sector. The project has also set aside ~50% of the concession area for conservation. Regarding minimization, OPG developed and is implementing a Biodiversity Action Plan (BAP), linked to plantation-level biodiversity management plans (BMPs). A staff code of conduct to prohibit hunting is also implemented. Additional species-specific management and monitoring plans are also in development for great apes and elephants. To further develop specific mitigation for key species, the project will complete additional baseline surveys as required in the BAP (ESAP#22) and prepare and implement species specific management and monitoring plans for great apes and elephants (ESAP#23). A Biodiversity Monitoring & Evaluation Plan (BMEP) has been prepared and will be updated in 2023. The updated BMEP will include monitoring for the offsets discussed below and the development of plantation-level monitoring plans (ESAP#23).

Regarding resources, a biodiversity manager was recruited, and such function will remain in place as a requirement of IFC investment. At the plantation level, biodiversity activities are implemented by OPG’s field teams. The project will conduct a resource needs assessment to identify and prioritize resources (e.g., training, equipment, vehicles) to ensure that the BMPs are effectively implemented throughout the life of the project (ESAP#24). An independent Biodiversity and Social Advisory Panel has also been established and will meet annually to review alignment of the project with their biodiversity commitments and provide technical input.

Residual impacts still exist however on forest, savannah, great apes, and elephant habitat, due to the extent of the land clearance. For this reason, biodiversity offsets will be required to achieve No Net Loss for Natural Habitat and Net Gain for Critical Habitat. An Offset Feasibility Study (OFS) is being finalized and will include the on-site HCVs that will be managed for conservation, and an off-site offset. The current preferred option covers ~128,000 ha in the Sud-Estuaire landscape and has been identified in consultation with external experts. The project will develop an offset management plan (ESAP#25).

Makouke plantation overlaps the Bas Ogoué Ramsar site. Although OPG acquired the plantation in 2016, it was established in the 1980s, prior to Ramsar recognition in 2009. Independent assessments confirmed that biodiversity values associated with the Ramsar designation are not present at the Makouke plantation, and OPG has committed to not undertake any new land clearance. OPG is establishing buffers between planted areas and watercourses and is supporting several initiatives by ANPN that benefit the conservation of the Ramsar site beyond the plantation area (e.g., development of savannah conservation plan, studies and pilot initiatives to reduce human-elephant conflict, joint patrols with OPG and ANPN staff).

OPG is using non-native plants for various purposes (e.g., pest control, soil enrichment, erosion control). Although the invasive species risk is low, OPG will complete a specific assessment, including control of naturalized alien species in natural habitats (ESAP#26).

Priority ecosystem services have been identified in the ESIAs and HCV assessments, including hunting, fishing, water for drinking, collection of forest products, cultural and sacred sites. Watercourses such as rivers and streams that provided sources of drinking water and fishing activities, and cultural and sacred sites were protected in set-asides; whereas areas that provided subsistence livelihood activities were subject to the land access process. Local communities have access rights to collect natural resources within the set-asides, subject to national legal requirements.

As indicated above, OPG has been a member of RSPO since February 2011 and all concessions have been RSPO certified. OPG also sources raw logs for construction (e.g., bridges), which are certified (Forest Stewardship Council).

 OPG used the SIA/HCV methodologies (including participatory mapping) to identify and protect cultural heritage sites. The specific types of sites identified through this process varied according to geography and local customs but ranged from natural features like sacred grounds and caves, to burial areas and sites having other cultural or archeological value such as old villages. OPG will develop and implement, in consultation with the affected communities, plans to manage such sites (ESAP#19). Furthermore, OPG will develop and implement a chance-find procedure in the event that field staff, and/or contractors happen upon a site that has not been identified in prior assessment/monitoring work, but may require protection, including potentially through the halting of clearing operations or maintenance activities (ref. ESAP#3).                                                  

  OPG has undertaken an extensive amount of stakeholder engagement with affected communities, NGOs and CSOs as part of the ESIA and HCV assessments and the process to access land rights from the communities, contributing to the project’s ICP process. OPG currently does not have a Stakeholder Engagement Plan (SEP) aligned to PS1 requirements for each site. OPG has an operational Community Grievance Mechanism (CGM) in place for affected villages at all concessions. Based on village meetings attended by the IFC, the communities were aware of the mechanism and how it functions. At the same time, Olam is in the process of developing a Framework SEP and Grievance Procedure at the corporate level to define its process of managing internal and external communications and grievances. In total 251 grievances have been registered since 2013, of which six were registered in 2022. These mainly related to land claims and unintentional destruction of crops and other assets. For the 2022 data, all but one of the grievances lodged directly by households were closed out. Building on this and to further strengthen the project’s ICP process, OPG will: (i) develop an overarching SEP and develop and implement site-level SEPs to consolidate and strengthen the approach to engagement adopted across the various concessions and sites in line with PS 1 and Olam requirements; (ii) review and update its CGM to comply with PS1 and Olam requirements. The CGM will be accessible to members of any community potentially affected by OPG’s operations, or by OPG’s employees’ or contractors’ community interactions at any time; and (iii) establish an appropriate and accessible centralized data management system that allows for aggregation and tracking of engagement records and information by community (ESAP#27). 

  The ESRS will be made available via IFC Project Information Portal and at OPG (plantations, mills, refinery) in Gabon. The ESIA studies and HCV assessments for the plantations/mills are available at https://www.olamgroup.com/products-services/olam-international/olam-palm-gabon.html.                          

Name and Address: 

Mr. Quentin Meunier, Vice-President

Corporate Responsibility and Sustainability Gabon - Plantations

Olam Global Holdco Pte. Ltd. (OGH)

Galerie Tsika | BP 1024 | Libreville | Gabon

Tel: +241 (0) 62001423

E-mail: quentin.meunier@olamnet.com