PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. The land for the new site is located in an industrial zone managed by the Ministry of Industry. Gaselia will be one of the users and is leasing the land for a 50-year period. There are currently no claims to the land and there will not be economic or physical displacement.

PS6 (Biodiversity Conservation and Management of Living Natural Resources) is not applicable. All project sites are located in modified habitat, or in industrial zones, therefore there will be no impacts on biodiversity.

Similarly, no indigenous people or cultural heritage will be impacted by the project, therefore PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, because potential adverse environmental or social risks and/or impacts are limited, few in numbers, site-specific, largely reversible and readily addressed through mitigating measures aligned to generally recognized performance standards, guidelines, or design criteria.

The project will have two phases covering construction and operation activities, with specific E&S risks associated to these. Key E&S issues during construction include: i) occupational health and safety (OHS), ii) dust emission, noise, and vibration from vehicle transit and earth moving activities, as well as iii) the potential for soil erosion and associated land and surface water pollution. These impacts are expected to be temporary and will be minimized via implementation of the construction E&S management plan. Key risks and issues during exploitation relate to the company’s capacity to: i) adequately manage environmental and social impacts of the company’s operation and expansion; ii) maintain fair, safe and healthy working conditions for direct employees as well as for contract workers; iii) assess the availability of water for the new project, and implement measures to ensure efficiency and sustainability; iv) establish and maintain internationally acceptable food safety standards (e.g. HACCP) in preparation, storage, delivery of food products and beverage; v) manage solid waste and effluents in line with good international industry practice.

 Environmental and Social Assessment and Management System

Since the start of the first project in 2010, the client has made significant improvement in managing environmental and social risks and impacts. A Group level Quality, Environmental, Health and Safety (QEHS) Policy was developed and implemented. QEHS staff were hired in Mali, Senegal and Cote d’Ivoire and a Group QEHS Manager was also nominated.

Gaselia has also valid ISO 9000 certificates for operations in Senegal and Cote d’Ivoire, and is planning a FSSC 22000 certification for its packaging facilities in Cote d’Ivoire and Senegal, and for the new CSD plant in Guinea. Environmental permits delivered by national authorities are available in each country, including for the new facility in Guinea.

Identification of Risks and Impacts

ESIA or environmental audits have been conducted in all countries in compliance with national regulations. An ESIA and Environmental and Social Management Plan (ESMP) for the new beverage processing plan were drafted in 2016, as well as a hydrogeological study. One of the main impacts of this project will be water extraction in Guinea, as well as in Cote d’Ivoire and Mali where expansion will take place, and will entail increased water use. This impact is not assessed in the ESIAs nor through the company’s risk identification process. In order to mitigate the potential effect of water extraction on the water reserve and other users, the client will do an impact assessment, develop and implement a management program to mitigate this potential impact in all 3 countries (ESAP #1).  As part of the Environmental and Social Management System (ESMS), identification of risks and impacts will be regularly carried out throughout the life of the project.

Management Programs

As part of the Environmental and Social Management System (ESMS), management plans to ensure that gaps are closed will be implemented throughout the life of the project. All identified actions are assigned to specific staff along with a required implementation schedule. In case of major material changes to operations and changes to E&S risks and impacts, staff (quality, food safety, OHS management, environment, and others) should review and provide input prior to final design.

Construction phase

The ESIA for the new facility in Guinea includes a detailed ESMP with management programs related to air emissions, soil and water pollution prevention, noise and vibration, waste management, and occupational health and safety. It also includes provisions related to training (first aid, and emergency preparedness), fire safety, and access to the construction site.

Operation phase

Management programs for the new plant in Guinea will be implemented under the supervision of the Regional QHSE Manager and will be consistent with those of the other Gaselia facilities. Since 2010, the project has made improvement in managing environmental and social risks and impacts. Gaselia maintains fair, safety and healthy working conditions of direct workers. Aspects related to third party workers are analyzed under Performance Standard 2 below. Energy and resources are monitored. Effluents are analyzed quarterly. Wastes are sorted and managed by licensed operators.

The food safety component of the ESMS is to be improved. Beverage processing will be undertaken according to internationally recognized food safety standards consistent with the principles and practices of Hazard Analysis and Critical Control Points (HACCP). Key responsibilities for food safety have been defined. Furthermore, staff in charge of implementing the food safety management system have the appropriate knowledge and expertise. Food Safety Incident Management will be enhanced. Preliminary Tasks for the implementation of a HACCP system have been done but the Control of Allergens was not taken into account. Completion of the HACCP programs will be demonstrated through an audit performed by an external consultant in all countries (ESAP #2).

Organizational Capacity and Competency

Apart from the regional QHSE Manager, there is a Quality Officer and a HSE Officer at each facility.  Key responsibilities for EHS and food safety have been defined and communicated across the organization. Furthermore, staff in charge of implementing the EHS and food safety management systems have the appropriate knowledge and expertise. While the traceability system and the specifications (including product release) is not formally documented, they are in place to some degree. A training program is available for each company including topics such as health and safety, food safety, OHS and environmental issues.

Emergency Preparedness and Response

Currently, there is a documented emergency preparedness and response plan for the facilities in Senegal and Cote d’Ivoire (NBCI). Major risks for emergency situations for the Group’s operations include fire and explosion, and hazardous materials spills. No major incidents have occurred since beginning of operations and all employees are aware of procedures and emergency instructions.

For the facilities in Mali and Guinea, Gaselia will develop and implement an emergency preparedness and response plan, which will include the following elements: identification of emergency scenarios; specific emergency response procedures; training of emergency response teams; emergency contacts and communication systems/protocols; procedures for interaction with government authorities (emergency, health, environmental authorities); permanently stationed emergency equipment and facilities (e.g., first aid stations, firefighting equipment, spill response equipment, personal protection equipment for the emergency response teams); protocols for the use of emergency equipment; clear identification of evacuation routes and muster points; and emergency drills and their periodicity based on assigned emergency levels (ESAP #3).

Monitoring and Review

As part of the ESMS, the Group has already adopted a structured EHS monitoring and reporting system for the E&S aspects of its operations. The procedure incorporates monitoring of Key Performance Indicators (KPIs) against set E&S goals, including: a) Safety – Lost Time Injury Frequency Rate, Accident Free Days; b) Resource Efficiency – water usage, energy usage, cleaning products consumption, and others. c) Waste – quantity per type. Monitoring frequencies and methodology are specified considering the risks and impacts. The monitoring data is compiled in a centralized database for development of summary reports, and regularly presented to senior management for review against set targets. Corrective measures are defined and implementation is agreed upon.

External Communications

Gaselia has a product recall procedure describing methods to log grievances, process for assessing grievances, and responsibilities for proving feedback and track any required corrective measures.

Human Resources Policy and Procedures

The Group has 738 full time employees, among which 83% (619) with open-ended contracts and 11% (82) women. There are 84 daily workers used mainly for unloading/loading trucks. Third party contractors are hired to carry out maintenance works, and fire equipment maintenance.  For the new plant in Guinea, it is expected that 75-100 new workers will be hired over the next 5 years.

All regular employees receive a contract registered at the “Inspection Régionale du Travail et de la Sécurité Sociale” (Labor Ministry). The Group is in compliance with all local labor codes governed by a commerce convention, which defines the various work categories, employee benefits, as well as minimum salary to be paid for each type of work. Gaselia contributes to medical insurance for employees and his/her family as well as to the ‘’Caisse nationale de sécurité sociale’’(CNSS) in case of work accidents.

In Senegal, the minimum age for work is 15 (‘’Code du travail du Senegal du 1 decembre 1997), in Mali 14 (‘’Code du travail du Mali du 18 aout 1992), in Cote d’Ivoire and in Guinea, 16 (‘’Code du travail de la Cote d’Ivoire du 15 septembre 2015; Code du travail de la Guinée du 10 janvier 2014’’).  Gaselia does not hire anyone under the age of 18 years.

Gaselia formulated a Human Resources (HR) policy and procedures and hired a Group’s HR manager to harmonize its HR procedures and practices. Each country has its own policy (‘’Règlement intérieur’’) in line with national regulations. At the Group level, there is a HR policy adopted by management containing provisions related to working conditions, non-discrimination and equal opportunity, performance, salaries, and training. As required by the ESAP, provisions related to promotion, recruitment, harassment, workers grievances are pending (ESAP #4). In addition, HR procedures will also ensure that the management of contract labor including daily and third-party workers is fully aligned with the requirements of this Performance Standard. This will include provisions included in third party contracts related to access to: personal protective equipment (PPE), a grievance mechanism, and OHS training and workplace safety measures.

Workers’ Organizations

As per local labor laws and regulations, all regular employees have the right and freedom of association. According to the different national legislations, workers’ representatives have the following tasks: ensure that workers grievances are communicated to management and to the Labor Ministry; ensure implementation of OHS preventive measures; and propose measures to improve work organization and productivity. Each facility has 3-6 elected workers representatives.

Occupational Health and Safety

Most of the operations are automated using modern machines with adequate safety features and limited moving parts. Potential risks come from lifting, repetitive work, posture injuries, falls on slippery surfaces, and burns from hazardous material.  To minimize OHS risks and incidents, the Group conducts job hazard analyses, implements job instructions, and provides as needed necessary PPE such as hearing protection, uniforms, masks, foot wear and gloves.

Each plant has an established Health and Safety Committee, which oversees performance. The Group maintains records of accidents and discuss all instances in regular meetings of the Health and Safety Committees. Regular meetings are also held with the management to discuss health and safety, quality and environmental issues. 

During construction of the new plant, the Group will ensure that the EPC contractor complies with all applicable national safety and site requirements and this Performance Standard for construction of the new facilities. These requirements are included in the ESMP for construction.

Workers engaged by third-party

As per the ESAP (ESAP #5), Gaselia will include EHS provisions into the EPC contract and other third-party contracts providing services to the company’s operations. These provisions will include as a minimum:  compliance with labor legislation, terms of OHS management, and access to a workers’ grievance mechanism including review and response to anonymous complaints. Gaselia will monitor third-party compliance with approved EHS requirements.  

Greenhouse Gases (GHG)

Energy is provided by the national grid in all facilities with back-up diesel generators.  In total, approximately twenty-four million kWh of electricity and 1,200 tons of diesel are consumed annually. Fuel tanks are equipped with proper secondary containment. The existing fleet is composed of delivery trucks (5 and 30 t), and forklifts. Annual GHG emissions of the operations are estimated at around 14,000 tonnes CO2 equivalent per year for all countries.

Water and Wastewater

Water comes from boreholes for all beverages facilities.  Water is treated before being used for processing (micro-filtration, chlorination, dechlorination, and ultra-violet desinfection). Total water consumption in 2016 was 280,000 m3 for all facilities. Consumption ratio is about 4.0 m3/t, which is below the industry benchmark (6.5 m3/t). As stated above under PS 1, and given facilities are located in water stressed areas, the expansion project will include an assessment of water extraction and potential impacts on groundwater and other users for all three countries. Mali is a Sahelian country that has been severely affected by past droughts; the site in Cote d’Ivoire is close to numerous other facilities extracting water for their operations, including the city of Abidjan; in Guinea, communities living in periphery of the site could potentially be affected by Gaselia’ s water extraction.

In all facilities, wastewater streams are separated. In Mali and Cote d’Ivoire, wastewater is mainly produced at the beverage processing plants and is characterized by high biochemical and chemical oxygen demands resulting from organic wastes, and from the use of chemicals and detergents. Wastewater is treated in all beverage processing plants. Treatment plants are composed of a rotary screen, a concrete pond, a concrete water recirculation tank, a submerged aerator, and an oxidation pond. In Mali, a bio-reactor was added to reduce the organic charge. In Cote d’Ivoire during appraisal, biological oxygen demand of treated effluents was not within the WBG EHS Food and Beverage Guidelines value. In Mali, treated water is discharged in the Niger River and the sludge is used as fertilizer. In Cote d’Ivoire, treated water is discharged in a nearby creek and the sludge is disposed by a license operator.

For the existing plants, and in order for effluents to be in line with WBG EHS Food and Beverage Processing guideline values, Gaselia will: (i) assess water usage and ensure efficiency gains are implemented; (ii) refurbish existing treatment plants if necessary; and (iii) implement a wastewater monitoring program. For the new plant in Guinea, a wastewater treatment plant will be built and design to meet WBG EHS Food and Beverage Guidelines effluent values (ESAP #6).

Pollution Prevention

The main sources of pollution are air emissions generated from the furnace oil-fired steam boilers, providing heat and hot water, and from the diesel-fired generators to produce electricity. The boilers and generators undergo quarterly maintenance inspections to optimize efficiency. The oil and grease trap at the wastewater treatment plant is emptied regularly and cleaned weekly.

Caustic soda and nitric acid used in the cleaning in place system are stored in separate areas and have proper containment.  Procedures are available for each hazardous material and include Material Safety Data Sheets (MSDS), training of workers in the use of MSDSs, safe work practices, and appropriate use of PPE.

Wastes

Solid wastes generated by the company’s operations include empty cardboard boxes, plastic bags and bottles, and small drums. The latter are either reused by the company or sold to private operators who clean and reuse them. Plastic is sold to local companies who reprocess it. Other wastes are disposed to a local landfill by a license operator.

Infrastructure and Equipment Design and Safety

Life and Fire Safety audits were conducted in the following facilities: Senpack, Senegal; NBCI, Cote d’Ivoire; and NBB, Mali. For Iplast in Cote d’Ivoire and Gaselia in Guinea, the Group shall provide a formal statement from a suitably qualified fire safety professional acceptable to IFC that the life and fire safety-related aspects of the building and fire safety system comply with an internationally recognized standard, and local life and fire safety regulations; and if needed, identify corrective actions and an implementation timeline.  Moreover, following completion of construction of the new facility, Gaselia shall provide a report from a suitably qualified professional acceptable to IFC that the facility and its fire safety systems were designed and constructed according to an internationally recognized standard, and local life and fire safety regulations (ESAP #7).

 Security Personnel

 Security arrangements are variable across countries. To be in line with requirements of this Performance Standard, Gaselia will ensure that security service providers makes reasonable inquiries into employment records and other available data, including any criminal record of individuals and will not employ any persons that have abused or violated human rights in the past. As set forth in the ESAP (action #8), Gaselia will review contracts with the security providers and ensure that they include adequate provisions related to vetting of personnel, training, procedures in the event of any incident or alleged violation to ensure effective oversight and accountability for the guard force.

 Contact Person: Boubacar Pona

Company Name: Gaselia Group

Address: Immeuble Simpara, B.P 2989, Bamako, Mali

Email: b.pona@gaselia-group.com

Phone: 223-20-22-35-09

Facsimile: 223-20-22-35-04