Environmental and Social Assessment and Management System

As required by the local environmental authorities, the existing operations conduct environmental assessments to identify risks and determined appropriate mitigation measures as per host country requirements and follow the conditions stipulated in the environmental permits.

For the proposed logistic center dedicated for the storage of the hazardous materials, the company conducted assessment of potential impacts and it will upgrade the hazardous materials management plans that have been used at the existing storage area within the Egypt plat premises.

Assessing and Complying with Performance Standard Requirements for Future Developments

IFC’s investment will be also used to develop greenfield facilities (“system houses”) in Algeria and Nigeria. As locations / land for these developments are being identified, the company is defining the locations not only considering business opportunities but also looking for compliance with the requirements of IFC PSs and local environmental requirements. Specifically, the company, as part of its management systems, is developing screening procedures to assess the compliance with IFC PSs, and as needed is conducting E&S impact assessment (ESIA) studies to determine corresponding potential E&S impacts and mitigations (see action No. 1 of the ESAP.) Furthermore, the company will develop corresponding E&S management plans (ESMPs) to oversee the implementation and E&S performance of these activities.  (see action No. 2 of the ESAP.)

Policy

Even though the company has defined a mission and established a set of core values including integrity and transparency, humility & perseverance, prudent entrepreneurship, hands on approach to business, and financial discipline; it does not yet has an E&S policy and principles that guide the management of the (E&S) issues across its operations based on the IFC PSs. Thus, as part of the project, the company will develop the E&S policy (see action No. 3 of the ESAP.)

Management Programs

While, the company has a functional E&S management system, as part of this project, Unimetco will upgrade/develop its EHS operating procedures for its BCI Egypt, and Turkey operations in accordance with the IFC PSs. (see action No. 4 of the ESAP.) These will include policies and procedure for identification and management of the EHS risks and impacts, operational safety procedures, handling of hazardous materials, preventive maintenance, work at heights, enclosed spaces, work permits, lock out tag out (LOTO), etc.

Organizational Capacity and Competency

At the corporate level, the company has recently appointed a dedicated Environmental, Health and Safety (EHS) expert with strong know-how on production and handling of hazardous materials to support and oversee the EHS managers at the specific facilities in Egypt, Turkey, UAE, and Italy. The company also has appointed qualified E&S dedicated personnel to oversee the performance of the Turkey operations. Moreover, it also has qualified personnel dedicated to overseeing the HR procedures and practices at its current operations.

All the operations conduct EHS trainings including at-induction, periodic in-depth training, as well as special training for identified risky activities. The training programs forms part of the broader EHS management systems and will be extended to the new facilities to be developed under this project.

Emergency Preparedness and Response

Unimetco is updating its existing emergency response and contingency plans and is developing the emergency response plan for the Turkey operations. (see action No. 3 of the ESAP.) The emergency response plans will include evacuation plans/routes; designated and clearly marked assembly points; roles; responsibilities; communication procedures; protocols to conducting the emergency response drills; etc. The company ensures that the operations maintain dedicated and qualified fire and emergency response brigades.

Unimetco operations have and periodically maintain fire prevention as well as firefighting equipment including smoke detectors, alarm systems, fire extinguishers, fire hydrant systems with dedicated fire water storage and sprinklers, as well as water mains and fire hydrants, portable first aid, firefighting equipment, emergency warning alarms, emergency shutdown procedures,) The Turkey facility was built with  state of the art firefighting and emergency response equipment; furthermore, as this facility is in an industrial zone, the company is set to actively participate in the mutual aid programs in place.

For the proposed logistical center in Egypt, dedicated for the storage of the hazardous materials, the company will develop the corresponding management procedures including emergency response prevention and response measures as indicated in ESAP No. 8 below.

So far, none of the company operations have had any accident or significant emergencies.  Regular emergency drills will begin to be conducted as part of emergency preparedness. Unimetco will develop the protocols for conducting the emergency response drill at each of the operations, it will register observations and implement resulting recommendations (see action No. 6 of the ESAP.)  

COVID-19 Response

As a result of the COVID-19 pandemic the company has not laid-off workers but has made temporary adjustments to its workforce by adapting to the national as well as respective local labor laws. The company has paid full salaries to the employees during the lockdown period. The company hires local workers and has no migrant workers or worker acomodations.  There have been no significant health impacts on the company’s workforce due to the pandemic.  Furthermore, the company developed, and it is implementing a COVID-19 infection prevention, control and response plan, consistent with the provisions under PS2, PS4, and the Interim Advice for IFC Clients on Preventing and Managing Health Risks of COVID-19 in the Workplace.

Specifically, the company has established social distancing protocols for workers at plant sites as well as at transportation buses from and to work places; it contracted qualified companies which conduct periodic/rigorous disinfection at all premises; it distributes and requires use of masks at all times by all employees, while at premises; and it scans temperature of all persons coming into premises.  As part of its COVID prevention program, the company has conducted awareness training on hygiene at home and provides hand sanitizer for workers usage at home.

Monitoring and Review

BCI Egypt conducts weekly noise monitoring of workplace conditions. In general, the noise levels follow the WBG EHS General Guidelines and local regulatory requirements. For the Turkish operations, it will conduct workplace monitoring and it has installed noise reduction measures, as appropriate, to operate in accordance to the WBG EHS General Guidelines.

As part of this project, for all operations, including the BCI Egypt raw materials warehouse, the company will conduct monitoring of workplace conditions (dust and vapors) to determine the current level of compliance with the WBG EHS General Guidelines and identify mitigations measures, as needed (see action No. 7 of the ESAP.)

Furthermore, as part of the project, Unimetco operations will complement the existing monitoring plan in place to include monitoring of workplace conditions -, to demonstrate its operations will be operating in accordance with the applicable requirements of the WBG Environmental, Health, and Safety (EHS) General Guidelines.

 Human Resources (HR) Policies and Procedures

The company’s corporate HR policy and procedures are rooted in the values that guide their actions with staff, partners and suppliers, customers and the communities and environments in which they operate. The company promotes transparent and consistent application of its labor policy through its code of conduct and a series of HR procedures and measures including broadly communicating the company’s policies on equal opportunity, local hiring practices and grievance mechanisms. The company has a zero-tolerance policy for discrimination or harassment and has qualified HR personnel at all its operations. The company’s HR corporate policy is customized and implemented at local facility level with necessary customization, aligned with the local labor laws and are consistent with the requirements of IFC PS2.  Furthermore, it is anticipated that the new operations to be established in Algeria and Nigeria, will implement the same corporate HR policy and procedures. 

Working Conditions and Terms of Employment

All operations promote local hiring. The total number of employees for all operations as of May 2020 included the following:       

After the project is implemented, the total number of employees is expected to increase to 250 from the current headcount of 208. Furthermore, over 4,000 indirect and induced jobs along the value chain are expected to be created.

The terms of employment, which are defined in the internal employment rules and regulations, are provided to each employee upon hiring. They include benefits, hours of work and overtime compensation, life insurance, health insurance, pension plan, etc. The company also facilitates loans as a fringe benefit to its employees. All employment benefits and other relevant HR aspects are included in each employee’s individual file, which contains the written contract, remuneration details, company policies and the relevant procedures, all signed at the time of recruitment.

The normal working hours at the company operations are 8-hours shifts, five days a week. The company uses extra hours, depending on production needs and fully complies with local law requirements related to overtime benefits.

Workers’ Organization

Even though Unimetco employees have freedom of association, none of its current employees are unionized. All operations have enjoyed overall good and friendly labor climate and up-to-date there have not been any labor conflicts at any of its operations. In Turkey the workers are been registered in the national social security scheme and the company follows the Turkish labor laws.

Non-discrimination and Equal Opportunity

The company’s HR policy also includes provisions related to non-discrimination based on race, nationality, disability, social class, sex, religion and/or political ideas. The company is an equal opportunity employer that extends equal employment opportunity to all applicants and its selection decisions are merit based.

The minimum hiring age in the countries where Unimetco have operations is 18 years old, thus in compliance with the local law and IFC PS2, the project’s own as well as contracted personnel are all older than 18 years. In addition, in compliance with the local requirements as well as IFC PS 2 there is no forced labor in either its or contracted operations. No evidence of such was found during the site visits by IFC.

Grievance Mechanism

Even though, Unimetco encourages all employees to have respectful and transparent conversations with their leaders, the company has a formal and documented employees’ grievance mechanism in place for all its operations and is consistent with the IFC PS 2 requirements. The grievance mechanisms includes (a) means to present the grievances openly/anonymously (e.g. mail, phone, verbal report to immediate supervisor/reporting authority; etc.), (b) process of receiving and registering grievances/complaints, (c) assessment and categorization of grievances, (d) prioritization and hierarchy of grievances and response time, (e) guidelines for resolution and response of grievance, (f) responsible personnel in charge of resolution, (g) documenting grievance/resolution, and (h) periodic monitoring of grievances and review by senior management. The availability of this grievance mechanism is communicated to all the employees through internal communications.

Occupational Health and Safety (OHS)

The company’s operations present limited safety risks, and the company has put in place a management and monitoring program accordingly.

As part of managing the working conditions, the employees are provided with and require using PPEs, and are trained on H&S aspects.  Furthermore, all operations track and monitor accidents and incidents.  No accident or injuries have occurred during the last 4 years; nor during the construction of the facility in Turkey.  Few small accidents that have taken place have required just first aid support.

In general, the sites visited exhibited properly maintained production areas, good housekeeping and safety management practices such as storage tanks with double containment, fire alarms, enclosed moving parts, etc.

For the Egyptian operations, the company has a clinic equipped for emergency, full-time nurse, and two medical doctors each available 2 days/week (2 hours/day), and an ambulance. It conducts medicals check-ups and provide adequate personnel protective equipment (i.e., uniforms, respiratory protective devices, safety shoes, etc.) as per specific potential risks, which are required to be used always. For the Turkish operations, the company has first aid kits for medical emergencies in addition to outsourcing the medical services to a nurse and fully equipped doctor office, located nearby.

Energy and Material Efficiency Projects

BCI Egypt has two natural gas boilers, it procures the electricity from the national grid, and have diesel-powered generators as back-up to be used occasionally in case of power failure

The Turkish facility has one natural gas boiler and procures its needed electricity from the national grid. This facility has embedded reduced energy consumption as all reactions are exothermic and uses steam only to the point where the process reaches reaction temperature and then cuts off the steam supply. All process pipelines are also well insulated.

Water and Wastewater

The water needs for its current operations are met from the municipal water supply systems. BCI Egypt uses an average of 1,200 m3/month for its closed loop steam production and as an additive for the polyols production. The new reactor to be installed at BCI Egypt will reduce the amount of water currently used to an approximate total of 1000 m3/month as there it will be no need, as previously, for cleaning this reactor whenever different products are to be produced.  However, the additional cooling tower to be installed will increase the amount of evaporated water which might result in an increase of total water consumption to approximately 1,400 m3/month. The Turkish operation consumes water only for cooling and steam generation, both of which are closed systems.  The water will be sourced from an authorized well. 

BCI Egypt’s wastewater are domestic wastewater and small quantities of process wastewater from the polyester reaction. The domestic wastewaters are sent to the industrial zone sewage system for treatment prior to being used for irrigation. The small quantities of process wastewaters are sent to the economic zone, where the plant is located, for further treatment.

The Turkish facility generates domestic and process wastewaters. The domestic wastewaters are released to the municipal sewage system and the process wastewaters are sent to the Mersin-Tarsus Industrial Zone wastewater treatment system for final treatment and disposal.

Air Emissions and Ambient Air Quality

BCI Egypt has two natural gas 1,000 kcal/h boilers consuming 471,187 m3/year of natural gas and as part of this project, it will install an additional 1,600 kcal/h natural gas boiler. It anticipates increasing the natural gas consumption to 36,000 m3 /month of natural gas. It also has a diesel back-up generator. At this operation, there are no process air emissions as it has close loop systems. The Turkish facility has one 680 kcal/h natural gas boiler consuming 10,000 m3/month.  At this plant, the process is conducted in closed reactors thus there is no generation of process air emissions.

GHG Emissions

The estimated scope 1 GHG emissions from BCI Egypt operations, from its total natural gas consumption were about 630,000 tCO2equivalent and those (scope 2) from its electricity consumption of 1,429,945 KWh/year were about 15,00 tCO2 equivalent in 2019. 

For the Turkish operation, as it will also source from the national grid, the (scope 2) GHG emissions generation will be due to its electricity consumption of approximately 240,000 KWh/year. It is anticipated this facility will produce 1,100 tCO2e as GHG emissions. 

After the project, the CO2 emissions are estimated to be the same as there are no anticipated neither increase nor reduction in energy consumptions.

Solid Waste Management

The operations have adequate systems and procedures in place to handle their solid and hazardous wastes. The plants have adequate hazardous waste areas to segregate, store, and dispose hazardous wastes. At BCI Egypt, the off-spec batches are recycled or reintegrated into the process and the flexible foams residues generated are recycled as they are shredded and once again agglomerate. Residues that cannot be reused are collected by the licensed contractors authorized by Ministry of Environment for final disposal.  Currently, it generates between one to five tons/year, this same generation will be maintained once the project is completed. Other wastes such as wood pallets are reused. A similar procedure is applied at the Turkey facility. It is anticipate that this facility will produce between one half to three tons/year of hazardous waste.

Hazardous Materials

BCI Egypt produces polyester polyols via (i) PET and glycol and (ii) adipic acid, phthalic anhydride and glycol and purchases polyether polyols. It purchases methylene diphenyl diisocyanate (MDI.) It also produces isocyanate prepolymers by mixing MDI with polyol. Other raw materials used include additives such as catalysts, surfactants, fire retardants, blowing agents, and fillers, which are used to tailor PU to specific product requirements. Both, raw materials and finished products can be shipped and received in bulk, packed (drums.) All liquid materials, including diesel used for the back-up generator and the forklifts, are adequately stored with double containment walls. BCI Egypt has 13 storage tanks (75 MT/tank) and placed them in containment impermeable basins.

MDI is adequately stored at room temperature as per MSDS requirements. MDI is the least hazardous of the commonly available isocyanates. Their very low vapor pressure reduces its hazards during handling compared to the other major isocyanates. Compared to other organic cyanates, MDI has a relatively low human toxicity; however, like the other isocyanates, it is an allergen and sensitizer. Furthermore, as it is a potentially violently reactive material towards water and other nucleophiles, BCI Egypt has strict engineering controls and requires mandatory use of personal protective equipment. Another raw material used at BCI Egypt is recycled PET, which is sourced from established companies that collects it from informal collectors.

As part of this project, BCI Egypt is building a second warehouse and an extra cold room to segregate raw materials from products thus ensuring proper storage/handling of raw materials and products.  Furthermore, it will also develop Hazardous Materials Management Plans for the current operations and the Turkish operation (see action No. 8 of the ESAP.)

Key raw materials for the Turkish operations include Polyols, MDI, MI 50, etc. The details of their proper storage and handling will be reflected in the hazardous materials management plant to be developed for the operation.

 As Egypt has signed the Montreal protocol to stop using HCFC-141b (1, 1-dichlorofluoroethane) blowing agent in the foam industry, Unimetco is working with its clients looking having them considering 141B alternatives.

Transportation Safety

The imported raw materials for the operations in Egypt arrive to the Alexandria and Sokhna ports and are transported to the current operations by truck (100-200 trips/month.) The products provided to their customers or those sent to the warehouse are also transported by truck (60 trips/month.) Furthermore, the products transported from the plant to the port are transported by isotainers (12 trips/month.) All transportation is contracted. Even though Unimetco provide rules and guidance for carrying out loading and unloading operations in the safe manner, as part of this project, the company will develop safety transportation plans, for each of its operations, and will establish specific procedures to include protocols and checklists to conduct inspections for trucks coming and going out (see action No. 9 of the ESAP.) Diesel is also supplied via truck and offloaded into the storage tanks. So far, the operations have registered zero transportation related incidents / accidents.     

Security Personnel

At its operations in Egypt, the company has 13 dedicated own private non-armed personnel in charge of 24-hour security. For its operations in Turkey, the company outsources its security personnel to a licensed security agency to provide unarmed security personnel. 

The security personnel are screened for criminal backgrounds; and so far, there have been no incidents related to security. As Unimetco is committed to run its operations in line with the Voluntary Principles on Security and Human Rights as per IFC PS4, it will develop a security management protocols at each of its operations, including security screening procedures consistent with Voluntary Principles, and relevant human rights good practices (i.e., proper use of force; appropriate conduct toward workers and other stakeholders; etc.) and will conduct relevant trainings (see action No. 10 of the ESAP.)

 As part of its outreach, the company hires personnel from the local communities. At the moment, the company does not have a public disclosure program related to its E&S issues and risks. The public disclosure of this ESRS will be a part of the stakeholder engagement by the company.

  Documents to be disclosed are:

- Environmental and Social Review Summary (ESRS)

- Environmental and Social Action Plan (ESAP)

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

Contact Person: Abdel Rahman Jahmani

Company Name: Baalbaki Egypt for Chemical Industries SAE

Disclosure Address: Plot 178, First Industrial Zone, 6th of October City, Egypt

Email : aaljahmani@bci-emea.com

Phone : +20 115 456 7906

City: 6th of October

Country: Egypt

Contact Person: Noureddin AL JALLAD

Company Name: BCI Baalbaki Kimya San Ve Tic AS

Disclosure Address: Burhan OSB Mah. 3, Cad. No. 9, 33209 Akdeniz, Mersin, Turkiye

Email : njallad@bciholding.com

Phone : +90 531 894 88 65

City: Mersin

Country: Turkey

Contact Person: Alp SARICI

Company Name: BCI Baalbaki Kimya San Ve Tic AS

Disclosure Address: Burhan OSB Mah. 3, Cad. No. 9, 33209 Akdeniz, Mersin, Turkiye

Email : asarici@bciholding.com

Phone : +90 542 360 66 79

City: Mersin

Country: Turkey