As the washing plant will be located within an existing facility located inside an EPZ where there are no neighboring communities, therefore, no impacts are expected on the communities. Also, the company has its own unarmed guards for security, hence PS4 (Community Safety and Security) is not applicable. No new land acquisition is required for the washing plant, therefore, risks or impacts related to PS5 (Land Acquisition and Involuntary Resettlement) are not applicable. As the AAL-AEPZ facility is located in an EPZ in the urban/semi-urban area of Dhaka, therefore issues related to PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.

This is a category B project according to IFC’s Environmental and Social Review Procedure for projects because a limited number of specific environmental and social impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines and design criteria.

Environmental and Social Assessment and Management Systems: As per the requirements of the Bangladesh Environment Conservation Rules 1997 (ECR 1997), the company will ensure completion of an E&S impact assessment (ESIA) and Environmental and Social Management Plan (ESMP) as part of the process of obtaining the Environmental Clearance Certificate (ECC) for the proposed facility from the Department of Environment (DoE). The company will implement the ESMP for the facility as well as obtain other required EHS permits.

Policy and management programs: Being a supplier of products to recognized global brands that require compliance with their codes of conducts, ethics and procedures, Ananta has implemented labor and EHS management systems, which include policy book, procedures, monitoring systems, internal audits and reporting mechanisms. The key aspects of labor, environment, occupational, health and safety (OHS) are covered under company’s existing policies and procedures. The HR policy manual includes policies and procedures on environmental management, working condition, health, safety and hygiene, use of personal protective equipment (PPE), fire prevention and drills, emergency response and community safety. These policies and procedures have already been implemented at the AAL-AEPZ facility for existing operations where the washing plant will be located; and the same will be extended to the washing plant being developed under the project.

Identification of Risks and Impacts: As part of its existing procedures, the company completes a risk assessment for all its operations. This has already been completed for the existing operations (i.e. cutting, sewing, embroidery, packing and utilities) at the AAL-AEPZ facility. As Ananta has washing plants at its other facilities where a risk assessment has already been completed and required preventive and mitigation measures have been implemented. Therefore, as set forth in the ESAP, similar risk assessment will be performed for the proposed washing plant, which will be shared with IFC and required preventive and mitigation measures will be implemented at AAL-AEPZ facility within agreed timelines.

Regarding structural, electrical and fire (SEF) safety risks, the facility has already been assessed by Alliance for Bangladesh Worker Safety (“ALLIANCE”) and a follow-up visit has also been completed. The company has already implemented many of the suggested corrective actions which are discussed in detail in the following sub-sections on emergency preparedness and response.

Organization Capacity and Competency: The corporate team has HR, compliance and EHS personnel reporting to the GM - HR, Compliance and Administration. At the AAL-AEPZ facility, the facility has a GM – HR, Admin and Compliance and a team of compliance officers, welfare coordinators and an EHS officer who are responsible for the day to day implementation of the internal policies.

Compliance team and EHS officer perform internal audits regarding fire safety, labor conditions (e.g., working hours, supervisory relations, etc.) and verification of basic OHS elements. Compliance officer is also responsible to ensure that the facility complies with SEF safety requirements of ALLIANCE. Welfare coordinators provide a link between workers and the management team by identifying worker’s needs, helping to solve issues, and facilitating overall communication among teams; they also provide training to employees. Dedicated EHS officer will be responsible for the environmental aspects of the washing operations. 

Emergency Preparedness and Response: The AAL-AEPZ facility has been provided with required fire safety systems including fire extinguishers, fire hydrant and hoses, and integrated fire detection and alarm systems. Sprinkler installation work is under progress in few areas and the detailed designs have been submitted to ALLIACE for their review. The facility was noted to have a number of exits and staircases from each of the floors. All exits were noted to be marked and provided with fire rated doors. Emergency evacuation maps have been displayed on all floors. In addition, BEPZA has a fire brigade and fire fighting team for the EPZ.  

The facility has already been assessed by ALLIANCE for SEF safety risks and also been visited by ALLIANCE for verification of the implementation of corrective actions. The company has made significant progress in implementation of the required corrective actions and the few remaining are in progress including review of designs of structural, sprinkler systems and lightning arrestor. The company will ensure implementation of all corrective actions at all its facilities and share regular updates with IFC.

The facility has an emergency preparedness and response plan and performs periodic fire drills. A number of workers have been trained on fire safety and emergency response through a combination of class room training and fire drills.

Monitoring and Review: As the company is a supplier to a number of global brands, as per the requirements of code of conduct of these buyers and other global certification programs (like WRAP, BSCI, etc.), all Ananta facilities conduct regular internal compliance audits which cover labor, environment and OHS compliance. In addition, all facilities are audited by external auditors/compliance teams of the buyers. The results of the audits are shared with both facility and company management and required corrective actions are implemented. Similar internal and external audits are conducted at the AAL-AEPZ facility and washing plant will be covered in these audits. Specially on labor compliance, the company has well defined indicators which are monitored and reported to senior management.     

However, the buyers’ audits and, consequently, the internal audits by compliance teams are very facility focused. To strengthen its corporate monitoring and review processes, as set forth in the ESAP, Ananta will develop a corporate E&S monitoring and review procedure which will; (a) specify key performance indicators (KPIs) on OHS (e.g., accidents, incidents, lot time injuries, first-aid cases), labor compliance, EHS training, energy efficiency along with the frequency of their monitoring; and (b) specify parameters and frequency for ambient air quality, stack emissions (from boilers, gas generators, back-up diesel generators), ambient noise, work area air quality and treated effluent quality monitoring in line with the applicable legal requirements as well as World Bank Group (WBG) EHS guidelines. Regular monitoring will be conducted as per the procedure and reports will be generated with a summary of these indicators. Any corrective actions as required based on the monitoring results will be agreed and implemented. Further, based on the reporting by facilities on specified KPIs, the company will regularly present a summary to the senior management.

The AAL-AEPZ facility employs 1900 workers of which 1600 are female workers. The new washing plant is expected to employ 1200 additional workers and based on employment patterns at other wash facilities of the company, 30% of the workers are expected to be female.

HR Policies and Procedures: Ananta has a well-documented HR manual with detailed policies and procedures regarding working conditions and these documents are made available to all employees in the local language as well as communicated during induction. Specific policies regarding prevention of forced and child labor, prevention of harassment and abuse, non-discrimination and grievance redressal are in place. The policies are thus consistent with the applicable legal requirements as well PS2 requirements and are already implemented at the AAL-AEPZ facility. 

Working Conditions and Terms of Employment: Working conditions and terms of employment are explained verbally and in written form to all employees through the contracts, including benefits, salaries and provisions for termination of employment. The contracts are in the local language and employees confirm acceptance of the conditions by signing. In addition, the HR policy manual clearly explains compensation and benefits and administrative policies on leave, overtime, holidays and working hours. All employees receive a salary above the minimum wage defined for the facilities in the EPZ. Ananta has a policy regarding working hours and an overtime policy. The company has a comprehensive tracking system and is working actively with buyers and the production and planning teams internally to control overtime. As per recent updates, the company has demonstrated compliance with the legal requirements with respect to overtime. The company will continue sharing regular updates on working hours and overtime with IFC.

Non-discrimination and equal opportunity: As mentioned above, the company has a documented policy on non-discrimination and gender equality. The facility already has a significant female workforce and the proposed washing plant is also expected to follow the same.

Workers Organizations and Grievance Mechanism: Currently there is no trade union at the AAL-AEPZ facility and the same is also not permitted under the BEPZA rules.  The company ensures that all facilities (including the AAL-AEPZ) facilities have an elected functional bipartisan Workers Participation Committee (WPC) that meets at least once every month in each of the facilities with presence from the top management level and this helps resolve employees’ concerns. In addition, the company has a grievance redressal policy which offers several options by which grievances may be presented. The policy has specific avenues for raising anonymous grievances through e.g. one of the complaint boxes, a welfare officer, having a discussion with HR or one managers etc. Graphic illustrations of the grievance mechanism as well as a summary of key policies in the local language are displayed at the workplace.

In addition, considering the significant number of women, the company has a separate policy which covers grievances of harassment and abuse including sexual harassment. Complaints of this nature are treated with confidentiality and HR and admin department is responsible for conducting the investigation in the matter. HR management is empowered to decide on such cases.        

Protecting the Workforce: In compliance with Bangladeshi labor law, Ananta’s policy and buyers’ codes of conduct, no employee under 18 year of age is permitted to work at the company’s facilities. Similarly, policies and compliance mechanisms are in place for preventing forced labor.

Occupational Health and Safety: As mentioned above, the company undertakes OHS risk assessment at all facilities and implements required preventive and corrective actions, as necessary. As set forth in the ESAP, a detailed OHS risk assessment will be undertaken for the washing plant which will include ventilation requirements, use of personal protective equipment (PPE), machine guarding and the requirements for the storage and handling of hazardous materials. This risk assessment would have a special focus on spraying areas where resin and potassium permanganate (PP) are applied to the denims. In line with the other washing facilities, ventilation, water curtains and PPE will be provided for these areas.

The basic provisions regarding OHS were noted to be implemented at the AAL-AEPZ facility for currently running operations. The workplaces were noted to be well lit and ventilated. Workers were using the required PPE in cutting and utilities areas. Occupational monitoring for workplace noise has been undertaken in the production areas. The facility conducts basic safety training for workers including specific training for workers involved in operation of utilities.

The facility has a medical room staffed with a doctor and nurse during the working hours. Based on available records, no lost time injuries have occurred since the facility has started operating and only first-aid injuries have been reported.

Resource efficiency: AAL-AEPZ facility has been designed and constructed as a green building in order to obtain LEED Gold certification of the United States Green Building Council (USGBC). The key resource efficiency features included in the building design are:

• LED lighting

• Low E Glass for the façade

• No volatile organic compounds (VOC) containing gum and paint

• Water efficient fixtures

• Recycling of treated effluent through dual flushing

• Efficient cooling and ventilation systems

• Building management system alongwith additional metering of energy and water usage

• Rainwater harvesting

Regarding washing and drying machines selection, based on its experience of installing similar machines at its other facilities, the company has factored in energy and water efficiency in its selection.  

Energy use and greenhouse gas (GHG) emissions: AAL-AEPZ facility has a grid connection from BEPZA. The company also has back-up diesel generator (DG) sets (2000 KVA and 500 KVA). As regards steam generation for existing operations and washing plant, the facility has dual fuel boilers (9 tons/hour + 2 x 500 kg/hour, can use both natural gas and diesel). The generators and boilers are already installed, however, the higher capacity boiler and generators are currently not being used.

Based on available information on electricity and fuel consumption, the expected annual GHG emissions from the washing plant are estimated to be 700 tons CO2 equivalent.

Wastewater Treatment: The wastewater will be generated from the washing, drying and finishing operations. AAL-AEPZ facility already has completed the civil work for the wastewater treatment plant and will complete the installation before the washing plant is made operational. The treatment plant (with a capacity of 130 m³/hour) will have secondary treatment with wastewater received in an equalization tank to be further treated through physico-chemical and biological treatment in a bio-tower with active media. The treated water will be reused for toilet flushing.

Air emissions and ambient air quality: The company conducts regular testing of stack emissions (for operating boilers and DG set and the results were noted to be compliant with the national standards. As part of the implementation of the monitoring and review procedure (discussed under PS1), the company will conduct regular stack emissions and ambient air quality monitoring and ensure compliance with the national standards and WBG EHS Guidelines. Also, as set forth in the ESAP, in order to enhance the quality of stack emissions monitoring, the company will improve the monitoring facilities including providing port-holes and platforms for all stacks. 

Hazardous materials management: Chemicals used for washing and finishing processes are selected by Ananta’s clients and are aligned with good industry practices. Ananta avoids the use of products on the suppliers restricted chemical lists; for example, the company does not use formaldehyde based products and the use of solvents and azo dyes are restricted. Furthermore, resins used in the washing process are pre-approved by clients. The company has already identified separate and designed areas for chemical storage. Material safety data sheets (MSDSs) are made available in local language and safety signages are provided in the storage and usage areas. As mentioned above and as set forth in the ESAP, the company will complete a risk assessment for the washing plant specifically including storage and use of hazardous chemicals and implement the required corrective and mitigation measures.

The company will disclose this ESRS and the ESAP locally at the following address:

Ananta Apparels Limited

Plant 246-249

Adamjee Export Processing Zone (AEPZ)

Siddirganj

Narayanganj-1420

Bangladesh

Enquiries and/or comments about the project may be directed to:

Mr. Sawasdee Kamal Chowdhury 

Ananta Apparels Ltd.

House 20, Road 99

Gulshan 2, Dhaka 1212

Bangladesh

Phone: +88-01755-02952

Fax: +88-02-8810656

Email: sawasdee@ananta-bd.com