This project does not trigger PS 5 Land Acquisition and Involuntary Resettlement as the land (6 ha) for the construction of the new processing plant was acquired through a willing buyer – willing seller transaction. The new plant is located within an established industrial zone with other seafood packing plants, animal feed producers, and other manufacturing operations.  In addition, satellite imagery shows that the area has not been inhabited for more than ten years. PS 6 Biodiversity Conservation and Sustainable Management of Living Natural Resources is not triggered as the site of the new processing plant has been significantly modified and is now covered with native and introduced species. A fauna and flora inventory performed as part of the construction permitting process indicated no presence of rare, threatened or endangered species.  Likewise, PS 8 Cultural Heritage is not triggered as the site review conducted for the construction permit did not indicate presence of any archeological and cultural assets. Lastly, PS 7 Indigenous Peoples is not triggered as no indigenous peoples have been identified in the project’s area of influence. 

This is a Category B project per IFC’s Policy on Environmental and Social Sustainability because a limited number of predictable environmental and social risks and impacts may result, which can be avoided or mitigated by adhering to generally recognized industry standards. The main environmental and social risks of Omarsa’s operations are the expansion of shrimp farms in areas with key biodiversity values, management of solid waste and wastewater from the processing plant, occupational injuries and illnesses among workers, and abuses from private security forces. These risks are adequately mitigated through the company’s policies and procedures.  

PS1 - Assessment and Management E&S Risks and Impacts

Environmental and Social Assessment and Management System – OMARSA’s management objective is to be a global leader in sustainable shrimp farming.  For the past 20 X years it has established the policies, procedures, employee training, internal control systems, and organizational capacity and competence to meet this objective.  Quality, environmental and food safety controls and monitoring systems are applied across all segments of the company’s operations and audited by internal and external teams.  Based on IFC’s review of regulatory requirements, results of certification audits across its production and processing operations, IFC concluded that there is a functioning ESMS with appropriate internal controls and competent staff. The company has now consolidated these standards into a single system with common control points and consolidated Standard Operating Procedures (SOPs) making significant progress since IFC’s original appraisal.

Environmental and Social Policies –The company has established an overarching policy that defines its environmental and social objectives and provides a framework for the assessment and management of risks and impacts. Policies are clearly stated and available on its website (http://www.omarsa.com.ec). Environmental and social policies are included in mandatory training across hatchery, farming and processing operations and included in supplier requirements. Environmental and social policies are largely prescribed through adherence to internationally recognized standards through credible certification systems, which are compliant with IFC’s Performance Standards (described below). Labor policies are established through a well-defined work code (Reglamento Interno de Trabajo) and consistently communicated internal human resources policies and procedures designed to meet Ecuador’s legal requirements and ILO labor conventions.

Management Programs - Information obtained during appraisal indicates that the company’s policy commitments to sustainability are matched through measurable actions and continuous certification to multiple standards (http://www.omarsa.com.ec/index.php/es/certificaciones.html)   and adherence to Ecuador’s regulatory requirements. Omarsa processes and labels production from its own farms to ASC, GlobalGAP and or organic standards and shrimp from its suppliers under exported under quality and food safety standards. Notably, OMARSA was the first company in the world to achieve certification of its three farms to the rigorous Aquaculture Stewardship Council Shrimp standard in September 2014 (see attachment for audit report). In addition, OMARSA’s Chongon Farm is certified to the European (Regulation 834/2007) and Naturland organic standards (http://ec.europa.eu/agriculture/organic/organic-farming/what-is-organic-farming/organic-certification/index_en.htm) by accredited certifying bodies.  Processing operations meet the food safety requirements of the BRC Global Standards and BAP Seafood Processing Standard. The company maintains a traceability system intended to meet phytosanitary, food safety and sustainability requirements.  This chain of custody system (COC) is based on physical separation and batch processing with a unique lot numeration scheme which allows traceability of all shrimp processed back to the farm of origin, pond and date of harvest. The company is providing support for suppliers interested in elevating their practices to ASC requirements and expects supply of certified products to increase in the future. There are now eight ASC-certified producers in Ecuador  

As agreed to in the previous appraisal the company has completed a review of its primary  supplier’s performance against the 10 criteria common to BAP, ASC and GlobalGAP requirements. They have identified the primary gaps and have recently developed an Action Plan to improve supplier compliance with the ASC requirements.  The Company is now testing a pilot program with several of its largest suppliers (which together supply more than 50 percent of its non-owned production) to support their certification to the ASC standards during the next year.  This is a bold and important step for Omarsa which will help it to retain its leadership and improve supplier loyalty as well as its brand. The Company has agreed to provide IFC with a final Action Plan to improve its supplier compliance with ASC and will report its progress annually within the AMR (ESAP Item 1). 

 Identification of Risks and Impacts –Omarsa operates in accordance with Ecuador’s general environment legislation and regulations, and new regulations required by the Normalization of the national Aquaculture Operations Law. The company conducted Environmental and Social Impact Assessments (ESIAs) of each of its hatchery and farm operations aligned with requirements under PS1.  Permitting and operating licensing requirements have been met for Omarsa’s own production and information available from internal controls and government regulators indicate appropriate compliance with environmental and labor requirements. Ecuador’s Aquaculture Control Division has recently updated its registration, and auditing system which now provides detailed and time-stamped transportation documents providing additional assurances that Omarsa’s suppliers meet, on real-time, phytosanitary and business registration requirements. 

The proposed facility is on a well-established Industrial Zone which underwent a complete ESIA in 2007. A Fauna and Flora Assessment was conducted and approved by the Environment Ministry in October 2016 which determined that the proposed development is consistent with the Integrated Management Plan for the Zone. The company has been provided with the necessary construction permits from the Duran Municipality for Land Use, Fire, Electricity and Wastewater Treatment. The Municipality authorized Construction Permits in November 2016 and civil works were underway during appraisal. Omarsa will provide IFC a copy of the detailed plan for the new pack house facility including a completion schedule and a list of the primary equipment prior to disbursement (ESAP Item 2).  The Company will also provide a working draft of the ESIA (only required by law at plant commissioning) for IFC’s review and comment (ESAP Item 3). Lastly, Omarsa shall provide IFC with all of the requisite Environment Ministry, Aquaculture Ministry and Municipality operating permits and licenses necessary for operations before the commencement of full scale operations (ESAP Item 4). 

Risks to biodiversity, Indigenous Peoples, and Cultural Assets associated with Omarsa’s farming operations were considered during IFC’s previous appraisal which can be found at  https://disclosures.ifc.org/#/enterpriseSearchResultsHome/Omarsa.

Organizational Capacity and Competency   - The Environmental Certifications Coordinator is responsible for a team that establishes EHS management practices, working closely with the farm management staff to ensure implementation, and measure compliance with regulatory requirements and conformity to international standards and certification schemes. They are supported at the farm level through close supervision by Farm Managers and implementation of SOPs. Interviews with staff and workers at all levels indicated appropriate levels of awareness and management of EHS risks.  The Commercialization and Quality Assurance Manager and his team ensure the application of food safety, product testing and supply chain traceability for suppliers. The Human Resources Manager helps to align skills and labor practices in the farms and processing facility to meet these requirements.  Interviews with each team indicated that they understood E&S risks and impacts associated with its operations, implemented relevant SOPs and continued to have the full support of senior management.

Emergency Preparedness and Response – As part of its occupational health and safety program the company has developed a comprehensive general Emergency Preparedness and Response Plan which identifies and addresses potential threats to life and property, such as explosions, fire and ammonia leakages. Catastrophic natural events including seismic, severe weather, and floods are also well covered and tested during the April 2016 earthquake.  A review of emergency plans, evacuation routes, fire detection and suppression equipment, and inspection reports by Duran’s fire brigade indicates that fire and life safety risks at the processing plant are well managed.  Nevertheless, considering the elevated risks in the plant due to storage of large quantities of industrial gases – such as anhydrous ammonia and nitrogen – fuels, and the presence of large number of workers, Omarsa will reinforce the training of its emergency brigades (ESAP Item 5).  The company will report the trainings received by its emergency brigades annually within the AMR. A doctor and a nurse are present at the plant both during day and night shifts.  No doctors are present at the farms, but farms are equipped with first aid kits and the company maintains several speed boats and a helicopter for evacuation needs. Communications between the farms and the base headquarters operations are good and guaranteed by radio and cellular service.  Marine transport of workers and staff is on licensed boats equipped with radios, and personal floatation devices of proper size and number.

Monitoring and Review –As stated above the company maintains multiple certifications and has an exhaustive internal and external audit system.  All aspects of OMARSA’s operations are routinely reviewed.  Review of water and energy records for hatchery, nursery, and grow-out farms provided substantial information about management of EHS risks and system performance. The recent ASC certification identified several areas for improvement in feed record keeping and monitoring of water quality and exchange. The Certification Team has made good progress establishing a harmonized system to keep track of the various standards and minimize M&E duplication as was requested after the first appraisal. Helping suppliers to improve explicit conformity with 3^rd party standards is an area for growth described later.   

Omarsa employs about 2,000 people in its processing plant and 600 people in the shrimp farms. Roughly 50 percent of workers at the processing facility are women, while women are practically absent in shrimp farm operations. The company employs about 200 part-time workers for shrimp harvesting activities in its farms. In 2016, Omarsa was audited against the BSCI – Business Social Compliance Initiative – standard, which is based on the International Labor Organization (ILO) labor standards. BSCI is not a certification scheme but a system to help companies gradually improve working conditions. The BSCI audit identified required improvements with regards to its employee grievance mechanism, occupational health and safety (OHS), and monitoring of social performance of suppliers. No required areas of improvements were noted with regards to freedom of association, fair remuneration, decent work hours, child labor and bonded labor. 

Human Resources Policies and Procedures – The company has a comprehensive set of HR policies and procedures, including non-discrimination and anti-harassment policies, and recruitment, hiring, training, grievances, disciplinary, and termination procedures. HR policies and procedures are in line with PS 2 requirements.

Working Conditions and Terms of Employment – Shrimp farms employ approximately 160 men per farm, who work ten consecutive days followed by four days off. The company employs additional part time workers for shrimp harvesting activities (approximately ten days/month) in its farms. Part time workers are directly hired and compensated by Omarsa. As part of workers’ contracts, the company provides in/out transportation, lodging and meals at no charge to all workers.  Omarsa is currently carrying out a construction program, including building maintenance, at all camps to improve and expand housing as required. The processing mill employs approximately 2,000 workers. Shrimp processing workers are paid by piece-rate and all are ensured at a minimum the legal minimum wage.  The company operates in two eight-hour shifts: a day shift from 8 am to 5 pm, and a night shift from 8 pm to 5 am. Workers are entitled to two days off per week. Overtime (1-2 hours/day) is commonly required during shrimp harvesting days (approximately ten days per month). Piece-rate is paid 1.5 times the regular rate during overtime, and 2 times the regular rate during days off and holidays. The company provides workers’ transportation from communities around Duran (up to 40 km) and meals at no charge.  Terms of employment, workers’ rights and responsibilities, and disciplinary procedures, are documented in written contracts and internal work regulations (“Reglamento Interno de Trabajo”) approved by the Ministry of Labor, and communicated to workers through mandatory induction training. The company is compliant with all its social security obligations.

Workers’ Organizations – Ecuador’s labor laws allow for worker’s organizations and protects labor leaders against discriminatory actions by employers. No union exists in the company but workers’ right to freedom of association is stated in the company’s HR non-discrimination policies, which is communicated to workers during mandatory induction training.

Non-Discrimination and Equal Opportunity – Ecuador has strong anti-discrimination laws and a vigorous affirmative action program that requires that at least 4% of the labor force be integrated by handicapped workers. The company has non-discrimination policies and procedures. In addition, disciplinary procedures provide employees with the right to respond and appeal to ensure they are non-discriminatory.  Roughly 50 percent of workers at the processing facility are women, while 99 percent of workers at farms are men. Women are well represented among managerial positions, and most supervisors inside the processing plant are women. Since 2016, the company is proactively hiring women at farms for technical posts.

Retrenchment – No retrenchment is expected as part of this investment. On the contrary, the expansion of the processing capacity is expected to create 500 additional jobs. Likewise, no retrenchment is expected as a result of investments in automatization in shrimp farms; workers will be trained and redirected to higher skilled jobs.  

Grievance Mechanism – The company has a professionally staffed Department of Social Well-Being (DSWB). This department is responsible for receiving workers’ grievances.  Each farm and the processing plant have a grievance committee that channel important grievances to the DSWB, which in turn notifies management of worker’s issues. There are also grievance boxes on each farm and at the plant for anonymous submissions. Review of grievance records indicated that the system is active and responsive to workers’ grievances.

Occupational Health and Safety – All the elements of an OHS management system – risk assessment and determination of controls, management programs, safe work permits, inspections, joint management-worker committees, training, records of accidents, emergency preparedness and response, and management review – are in place. The OHS Department (“Seguridad Industrial”) comprise an OHS manager and two coordinators. Omarsa will hire an additional OHS coordinator to supervise construction and operation of the new processing mill in Las Brisas, Duran. 

Appropriate use of Personal Protective Equipment (PPE) was observed at most stations on the farms and in the processing mill. There was good attention to appropriate signage and evidence of training throughout all operations. An analysis of workers’ exposure to noise, extreme temperature, chemicals and ergonomic hazards, was conducted by qualified consulting firms at the processing mill in 2015, and shrimp farms in 2016.

Omarsa uses anhydrous ammonia in its refrigeration systems. At room temperature, ammonia is a colorless gas with a penetrating and pungent odor. The odor threshold is reported to be 5 ppm parts of air, which is well below the National Institute for Occupational Safety and Health (NIOSH) recommended exposure limit (REL) of 25 ppm as an 8-hr time weighted average (TWA). Potential exposure to dangerous levels of ammonia, and accumulation of ammonia within its explosive range of 16 to 22 percent, are more likely to occur in unsupervised compressor rooms. Omarsa has installed ammonia gas detectors in all compressor rooms and is equipped with adequate PPE and self-contained breathing apparatus to respond to ammonia leakages. No worker is allowed to enter a room without the adequate PPE if concentration is above 25 ppm.  Routine preventative maintenance of the ammonia refrigeration systems is regularly performed to avoid leakages. 

During IFC’s appraisal conducted in 2015, the processing plant appeared to be largely well organized.  Since then, the company has constructed a second flash chilling line, which has disturbed the original process flow and caused congestion points in process paths resulting in an increase in traumatic injuries. Hazards are expected to decrease once the new value added lines are operational, and a new overpass between the facilities is completed, by the end of 2017.  

Some deficiencies were observed at the shrimp farms during IFC’s appraisal conducted in 2015, which were largely the result of poorly designed product flow in the feed storage and mixing areas, and boat landings where there were elevated levels of feet and ankle injuries which could be addressed to lower the injury rate. As a requirement of the previous IFC investment, the company undertook an external OHS audit in shrimp farms to identify those areas where accidents were abnormally high. As a result, the company has installed several floating gangplanks at their farms which have reduced associated accidents.

The frequency of lost time accidents since 2014 remains unchanged overall, although there has been a decline in the severity of individual accidents.   The nature of the work on shrimp farms, and relatively high turnover rates of unskilled labor require continual attention and discipline to retain a safe work environment. Moreover, the corrosive marine environment requires that electrical equipment be routinely maintained and replaced to reduce the potential for failure and serious accidents.  The Company agrees to redouble its attention to management-approved procedures and operational spending to avoid safety hazards by improving routine attention to clear signage and hands-on safety training and increasing attention to infrastructure maintenance in order to avoid serious accidents and injury.     

Child labor - The US Department of Labor does not mention shrimp farming as a sector at risk of child labor and indicates Ecuador is at “moderate advancement” to eliminate child labor.  Omarsa does not hire people under 18 years old; age is verified through the person’s ID and recorded in the worker’s file.

Supply Chain - Currently the company purchases up to 70% of its processing throughput from about 200 third-party medium and large shrimp farmers through purchase orders. The company supervises the shrimp harvesting and transport but it does not monitor pre-harvest labor conditions or supplier compliance with all the standards Omarsa’s buyers may require. However, shrimp farming is a highly regulated sector in Ecuador, and purchase orders can be emitted only for suppliers who have obtained all the required authorizations, including certifications of labor legal compliance. The Ministry of Aquaculture monitors each supplier’s compliance with phytosanitary requirements, tax and social security provisions and only issues harvest/transport permits (“Guia”) to compliant suppliers. 

Resource Efficiency and Pollution Prevention - Shrimp production and long-term profitability are determined by efficient resource use including avoidance or minimization of mortality in hatchery operations, careful control of efficient feeding during grow-out, and the logistics associated with transporting, and processing shrimp. The company maintains elaborate systems to measure its efficiency in terms of water use, energy consumption, and its competitiveness in the conversion of feed to finished body weight of shrimp across all primary activities. The energy consumption for processing shrimp is well below the EHS Guidelines for Fish Processing (2007) of 350 MJ/ton of finished product owing to significant investments it new freezing tunnels, sorting equipment and very efficient harvesting.

Omarsa’s farming practices are considered “extensive” with a single daily feeding, stocking densities below 15 shrimp per square meter, and less than 10% of daily water exchange. The company’s use of water and energy, and its overall greenhouse gas emissions footprint, are in line with industry good practices and the IFC’s EHS Guidelines for Aquaculture (2007).    

To obtain ASC certification the principal fishmeal and fish oil and soy components must eventually originate from fisheries and farms (respectively) under sustainable management as recognized by international organizations. In Latin America, FishSource, is the organization which assesses fisheries management to determine if they have achieved or are on the path to achieve Marine Stewardship Council certification. The Roundtable for Responsible Soy (RTRS) is the best recognized standard for soy production. During its recent audit, ASC indicated that Omarsa needs to begin working with its feed suppliers to develop an Action Plan and ensure that feed is supplied through registered FishSource and RTRS suppliers. ASC certification results, and details on the sustainability of fishmeal and fish oil sources, will be included in the Annual Monitoring Report (AMR) to IFC.

Feed expenses often represent more than one third of total aquaculture costs thus Feed Conversion Rates (”FCRs”) are a determinant of financial success as well as sustainable production systems.  FCR’s are, in turn, dependent several factors including the quality and protein content of the feed, the quality of fry stock,  and the water management on each farm. Similar to other “precision farming” systems providing the correct feed at the correct time and correct location is critical.  Overfeeding shrimp can result in toxic conditions which can stress the growing stock and usher in pathogens while underfeeding them results in slower growth and higher costs. During appraisal it was noted that the company is diligently managing a wide range of innovations and monitoring multiple aspects of water quality and feeding practices. Omarsa has expanded its leadership in the testing and use of improved feeds and feed application systems to FCR’s.  The information across the shrimp lifecycle is complex and gathered by several systems which must be proven under Ecuador’s unique circumstances.  Similar to other precision farming systems, the company is developing management systems to integrate and calibrate its information on fertilization, feeding, aeration, and water exchange in order to identify, and scale as appropriate, those practices which have the best results in terms of FCR, total productivity, and sustainability and will report these results to  IFC within the Annual Monitoring Report.

Water Consumption –  On farms water is pumped from the estuaries and retained in the sedimentation area prior to release into the shrimp ponds through a central canal. Water is returned by gravity to the estuaries through large expanses of native mangroves. Water use in farming is insignificant relative to the total amount of water available and information provided by the company indicate that water consumption is in line with IFC EHS Guidelines and that nitrogen, phosphorus and suspended solids are lower at discharge than at water intake.

At the current processing facility approximately 1,000 m3/day of brackish water is abstracted directly from the Guayas River and subject to primary treatment prior to rinsing use or ice making. Processing water (approximately 9 m3/ton of finished product) is recycled within the various chilling and washing lines and then treated through a sedimentation/clarification system that passes then to an activated aerobic system (“MBBR”) prior to discharge to the Guayas River. Only kitchen facilities use fresh water which is trucked into the facility and discharged through the main system. The Company’s effluent records and 3^rd party laboratory analyses indicate compliance for national discharge requirements and IFC EHS Guidelines and a net reduction in suspended solids (TSS) and biological oxygen (BOD) of return water.  

Greenhouse Gases – the primary source of Omarsa’s GHG emissions stem from diesel use in the pumping of brackish water into outgrowing systems. Each farm has two or more pumping stations with a total of twelve large diesel generators operating. Information provided by the client in terms of production and diesel use indicate that it’s energy efficiency is approximately 2.8 MWH per ton of shrimp produced which is within industry norms. The current processing facility purchases all its electricity from the grid which, when combined with the farming-based emissions equates to nearly 20,000 tCO2e/year [still be clarified] which is below IFC’s reporting threshold. Almost all Scope I emissions are from diesel powered pumping operations on farms and all emissions in processing are Scope II and purchased from a utility company. IFC will continue to use an amalgamated carbon footprint on a finished product basis and seek opportunities to work with Omarsa to improve its energy efficiency and reduce GHG emissions.     

Waste Management – Organic waste retained in the drained ponds after harvest can dry in place and is treated with Calcium carbonate to neutralize pH and accelerate decomposition before the ponds are refilled. Other solid waste composed of feed packaging, metal barrels for hydraulic fluids and petroleum, and general refuse is separated and transported to Durán for management and disposal by the city’s solid waste system. Organic wastes from processing are collected daily by various commercial enterprises and grease and sludge from the wastewater facility are dewatered and transferred to approved municipal sites by specialty contractors.

Pesticide Use and Management –- Omarsa makes minimal use of hazardous materials and uses no antibiotics or pesticides or chemical additives in its farming. The use of low stocking rates and disease resistant shrimp are key pillars of the company’s strategy to prevent disease outbreaks including the White Spot virus disease. These practices are complemented by breeding for vigor and resistance to disease and provision of probiotic supplements to enhance the capacity of shrimp populations to resist harmful viruses and bacteria. Regular monitoring of outgoing water ensures that water quality parameters are well within national limits and established industry standards. Rodent populations at the farms and processing mill are controlled by physical devices monitored by a specialty contractor.

Hazardous Materials Management – On farms the most dangerous substances used by Omarsa are petroleum-derived products: diesel and lubricants used in pumps, generators and vehicles. Risks and mitigation for diesel transport and stores at farms was covered in detail in the previous appraisal and was found to be continuing at owned farms and suppliers encountered. Processing facility hazards include diesel for stand-by power sources, transfer stores for some farming chemicals, and significant storage of anhydrous ammonia refrigerant used for chilling, flash freezing and frozen stores. The company utilizes licensed transport companies that are monitored by the Government of Ecuador’s Directorate of Hydrocarbons and all diesel is stored in properly bunded steel tanks that meet Government of Ecuador requirements and IFC requirements. Used oil and oil filters are temporarily stored on site and then transported to Duran for processing and/or disposal by companies licensed to provide these services. Fire prevention and suppression guidance and equipment are available at appropriate sites.  While present, the risk of significant spills is minimized by Omarsa’s use of specialized petroleum product transporters and handlers, and the use of appropriate storage facilities on land.

Community Health and Safety -The three shrimp farms, of approximately 1,000 ha each, are in areas populated with few villages or enclave. Community members at these villages are mainly fisherman, engaging in a variety of “wild caught” fishing or other harvesting of marine animals including conch, crab, shrimp, mussels, scallops and demi dorsal fish. One community (El Zapote) is within one kilometer of the Puna shrimp farm hosting around 350 people, and one community (Cerro Los Morritos) is within one kilometer of the Cachugran shrimp farm hosting around 100 people. No communities are found nearby to the Chongon shrimp farm. Potential risks to communities include accidents associated with transportation of materials, impact on ecosystem services resulting from farm operations, and use of security forces. These risks, however, are minimal. Mangroves have been minimally impacted by Omarsa’s operations, and community consultations in the context of the company’s Community Relations Plans (see Stakeholder Engagement section) has reduced the risk of confrontation with Omarsa’s security personnel.

The existing processing plant in Duran has been operating for more than 20 years and  the neighborhood has been increasingly densified and is now surrounded (50 m) by residential areas.  The potential risks to neighbors include accidents associated with transportation of materials and personnel. No nuisance odors were perceived at the boundary of the facilities and evidently no complaints have been  filed for several years regarding odors. Observations during the appraisal and results from regulatory and voluntary audits indicate that noise levels within and at the periphery of the plant are within IFC EHS General Guidelines and are largely confined to wastewater treatment and back-up power generators when operating. The new processing plant will be installed in an area declared as industrial zone by the Municipality of Duran. The closest residences to the proposed facility are beyond a radius of one kilometer.  

Hazardous Materials Management and Safety – As described under section PS 3, Omarsa makes minimal use of hazardous materials and uses no antibiotics. While present, the risk of significant spills is minimized by Omarsa’s use of specialized petroleum product transporters and handlers, and the use of appropriate storage facilities on land. Hazardous materials pose a low risk to communities.

Ecosystem Services - The most important ecosystem service to local communities is the production of fish, mollusks and crustaceans by mangrove ecosystems. Mangroves have been minimally impacted by Omarsa’s operations. The prior appraisal provided a review of risks and impacts to ecosystem services associate with farm operations. The proposed facility will have limited impacts on services beyond extracting and returning water from the channel for processing purposes.  

Security Personnel –Theft is a serious problem and the company has agreements with four professional security firms –  licensed by the Government of Ecuador  –  for protection against theft on the farms and during transportation to mill and export area. Detailed discussions with Omarsa’s Security Manager and the security contractors revealed good coordination and communication. Security guards undergo a comprehensive government-approved training program before they are deployed to Omarsa’s operations. Omarsa’s own security personnel – an overall Security Manager and two field-level coordinators –  monitor the performance of the security contractors and ensure that they adhere to Omarsa’s security forces policy. Omarsa’s security approach includes the following: 1) it works closely with the National Federation of Fishing Cooperatives of Ecuador to engage with local fishermen; 2) it helps local artisanal fishermen maintain their fishing licenses and improve visibility of their boat’s registration; 3) it has installed infrared detection and video cameras on its farms to deter theft and monitor the movement of vessels and vehicles; and 4) has engaged specialty marine security contractors for protection and recovery of assets. The overall goal is to deter illegal activities at its farms before they take place, and thus avoid confrontation. Security forces are also trained in progressive use of force. Omarsa’s security arrangements are in line with the requirements of this Performance Standard.

As a requirement of ASC certification, Omarsa has developed Community Relations Plans with directly affected communities adjacent to all its farms.  These plans are based on sequential consultations with the communities who have appointed representatives (interlocutors) as “official” liaisons with the company. Importantly, these plans and consultations have identified several projects aimed at improving the protection of the mangroves and identifying common security problems and encroachment issues.   The plans must be updated with input from the communities every three years.  A Social Development Fund has been established and fund development activities, which include internet access, sports teams’ sponsorship and most recently a the construction of a borehole well and pipeline to bring drinking water into the community of El Zapote from a borehole located more than 1 km away.

Most interaction between Omarsa’s workers and community members occurs during transport of inputs, products and workers as described below under PS4. It is worth noting that all employees are from the greater Guayaquil area and few, if any, are from neighboring communities.  Omarsa recently conduct an extensive Biodiversity Assessment and Action Plan on Puna Island where it owns nearly 5,000 ha and has authorization for up to 600 ha of shrimp farms.  The action plan included extensive surveys of the biology, social ecology, and economy of Puna and provides broad direction as to how the company can direct conservation of land under its control.    

External Communication and Grievance Mechanism - Regular communication between adjacent fishing communities and Omarsa as described above are is used to relay grievances and dissatisfaction.  The community-appointed interlocutor and the head of the Certification Unit communicate freely as needed. Open community meetings are held as needed, usually once or twice per year. There have been no grievances since IFC’s first loan. Commercial channels and the company’s traceability system are used to elicit feedback from the companies’ buyers.

Paul Barreiro

Certification Coordinator

OMARSA

Lotización Industrial Al Rio Solar 3.

Guayas - Durán, Ecuador

Tel. +593 4 371 3035

mailto:pbarreiro@omarsa.com.ec