This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific E&S impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

Environmental and Social Assessment and Management System

At individual plant level, most of the subsidiaries have an established ESMS which is generally in line with IFC PS requirements. Some of the plants in Tunisia (Eleonetech, TTEI, Techniplastand FUBA) have a certified management systems based on ISO 14001 (environment), OHSAS 18001 (occupational health and safety), ISO 9001 (quality management) and ISO/TS 16949 (automotive industry) standards. At these plants, the E&S management systems are implemented to identify and manage EHS/OHS risks and impacts. For other operational plants, the E&S management system is established primarily to meet host country legislation and are commensurate with the risks and impacts of those operations. Moreover, at Tunisia Cables and OTMA facilities, relevant environmental and occupational safety procedures, such as provisions of personal protective equipment, incident investigation procedures are currently being developed. Going forward, those companies will complete developing the relevant written procedures and revise their ESMS documentation to finalize the ongoing ESMS development at Tunisia Cables and OTMA facilities, as per ESAP item#1.

Considering the growth in the company’s business through either constructing or acquiring/expanding new plants, OTH will develop a Corporate ESMS manual building upon the existing ESMS already developed at some plants as noted above. The corporate manual will also include the company’s commitment to comply with IFC’s Performance Standards provisions for all its operational plants. Furthermore, OTH is expected to implement systematic and consistent systems across all manufacturing facilities and subsidiaries, based on this corporate ESMS manual (ESAP item #2).

Policy

OTH’s Environment policy reiterates its commitment on pollution prevention including effective management of solid wastes through sorting, reduction at source and recycling, management of effluents and resource efficiency. As per ESAP item #3, the company will update its corporate ESHS policy to reflect the adoption of the company’s values and principles in compliance with IFC Performance Standards provisions, relevant WBG EHS Guidelines, and applicable local environmental and social laws and regulations. The policy will be applicable to all OTH’s facilities and subsidiaries. 

Identification of Risks and Impacts

OTH aims to increase its production through capacity expansion of existing facilities. Currently, OTH undertakes environmental impact assessment (EIA) for new greenfield plants, as well as plant expansions, according to applicable country regulation. The company works with local consultants to conduct full EIA studies, assess potential adverse E&S impacts and develop corrective actions to avoid and mitigate identified impacts. As part of its expansion program, the company is planning to purchase new machines or equipment for its existing plants in Morocco and Tunisia, which is out of the scope of local EIA requirements and considering a potential acquisition of R&D and design company.

As part of the expansion program, the company will develop and implement, as part of the corporate ESMS manual, EHS due diligence procedures for potential acquisitions/construction of new facility/company fully aligned with IFC PSs requirements, particularly with respect to identifying and managing impacts/risks related to OHS, construction contractors, land acquisition, historical contamination as well as biodiversity, as set forth in the ESAP item #4.

Organizational Capacity

EHS issues at OTH facilities are typically managed by the plant level Quality System Managers with the assistance of an EHS specialist. Each plant EHS team is responsible to oversee that EHS performance is compliant with local requirements and to ensure the correct implementation of occupational safety procedures OTH has appointed a qualified EHS/OHS personnel at corporate level tasked to develop and implement a corporate ESMS and oversee and coordinate its correct and consistent implementation across all the facilities and to ensure that consistent E&S and OHS management procedures and standards are implemented, monitored and reviewed at all OTH subsidiaries and facilities. As per ESAP item #5, the EHS coordinator’s reporting line to OTH’s top management, as well as reporting requirements from the subsidiaries, will be clearly defined in the ESMS manual, as this person can also serve as the management representative (MR) for the corporate level ESMS. 

Emergency Preparedness and Response

Each plant has documented emergency preparedness and response plans (EPRP) that identify risks associated with its activities. Overall, the plans include instructions on how to respond in emergency situations, and roles and responsibilities of emergency units in accordance with local laws.

Fire detection and suppression systems established at each plant varies according to the type of operations. In general, the plants have automatic fire detection systems, sprinkler and/or dry fire extinguishing systems. In FUBA, some areas of the production plant have smoke detectors while others do not. In addition, there is a high concentration of wood particular matter (potentially highly flammable), both in ambient air and surface deposits, in the production areas. Therefore, as per ESAP item #6, FUBA will carry out a fire risk assessment in the production area at FUBA plant and agree with IFC on a time - based action plan to implement corrective measures if required.

At the plants visited, portable fire extinguishers, hoses, valves and hydrants were clearly marked, and accessible and fire safety equipment maintenance is carried out by a third-party contractor, routinely. OTH’s subsidiaries production plants are located inside industrial zones that can provide additional firefighting/emergency response (ER) support if required. Each site convenes one or two fire/emergency response drills per year depending on the operational risks. There have been no major accidents or ER incidents in the past three years. At each shift, there are designated employees responsible for firefighting who undertake relevant trainings.

Monitoring and Review

The plant level EHS team oversee facilities EHS performance via internal inspections and environmental monitoring and measurement plans developed and implemented in accordance with local regulatory requirements. The monitoring comprises OHS parameters (incident records, PPE use, trainings, workplace conditions etc.), air emissions, solid and hazardous materials and waste management, wastewater quality, and energy consumption. As part of ESAP action item #2, the company will develop a corporate ESMS manual that will entail a corporate level benchmarking process.  This will include, but not limited to, specific key performance indicators, internal monitoring procedures, schedule, and standards, reporting procedures and review mechanisms to correct any identified gaps aimed at maintaining effective ESHS performance at all manufacturing plants and subsidiaries.

OTH currently employs close to 4,525 employees spread over seven production facilities in two countries. Almost 50% of total employees are females working as operators, supervisors and senior managers. Third party workers (about 160) are employed in supporting activities such as cleaning, canteens, maintenance services etc. All employees either have fixed term or open-ended contracts.

Human Resources Policies and Procedures

OTH’s current HR policies and procedures are developed and implemented at the plant level to meet host country labor laws which are generally consistent with IFC PS2 requirements. Subsidiaries’ HR policies and codes of conduct typically specify terms of employment and working conditions including procedures related to recruitment, training, performance review, salary levels, working hours, overtime compensation, paid holiday and levels, ethic code, equal employment opportunity, non-discrimination, prevention of any kind of harassment, respectful workplace and other fringe benefits. At some facilities, including OTMA and Tunisia Cables, an employee handbook is available and provided to staff at onboarding along with their appointment letter and contract. Furthermore, OTH has an intranet where HR policies and procedures and other related documents are available for easy access if needed.

At OTH corporate level, a HR Director is responsible for the development and implementation of corporate HR policy, programs, and procedures consistent with local labor laws of respective countries. Building upon the site level HR policies, the company is in the process of developing a corporate level HR policies and relevant procedures to ensure consistent HR management across all the facilities.

The corporate HR policy and procedures will be provided in French and local languages and will be incorporated in new employee induction and refreshment trainings.

Term of Employment

All workers, including contract workers, sign a contract at the time of employment. The contract defines terms of employment (e.g., salary, working hours, holidays and leaves, health benefits etc.) following national labor laws and regulation of the country where the operating plant is located. Employees work in shifts and overtime work is within permitted limits and paid in line with respective local labor laws.  Transportation services are offered to employees living in nearby cities.

Local labor law does not have any restriction on the right to freedom of association. According to OTH’s management, there is no restriction or discouragement of freedom of association; however, this provision will be articulated in corporate HR policy. All OTH subsidiaries have active unions that meet once a month to discuss employees matters and occasionally with the CEO of the subsidiaries

Non-discrimination and Equal Opportunity

OTH is committed to promoting equal opportunities and negating all forms of discrimination. All hiring, and promotion is merit-based. When candidates have equal qualifications, preferences of hiring are given to local residents and females. Moreover, the company is closely working with GIZ (German development agency) to improve gender diversity in the workforce by encouraging more female employees and aiming to increase the proportion of female at managerial and supervisory positions from 19% to 30% by end 2022. Furthermore, OTH will include clauses in the corporate HR policy and employee handbook to include clauses to prohibit of gender-based discrimination and harassment (ESAP item #7).

Grievance Mechanism

The company does not have a formalized grievance mechanism although an open - door policy allows employees to raise and register their concerns freely. As set forth in ESAP item #8, a formal and documented corporate grievance handling procedure will be established as per IFC’s PS2 requirements. This will include channels for receiving grievances (including anonymous grievances), recording, methods for escalation and resolution within a fixed timeframe, and feedback to the employees about resolution. Plant level HR personnel will be responsible for addressing worker grievances while the effectiveness of grievance mechanisms at each facility will be evaluated by the corporate HR team and reported to senior company management. Direct employees as well as contractors and service provider’ workers will be made aware of the grievance mechanism procedure during the induction training session.

Protecting the Work Force

Minimum hiring age at all OTH subsidiaries and facilities is 18 years. HR checks birth and school certificates during the hiring process. These requirements also apply to all the temporary workers hired by third party contractors. No evidence for the presences of child or forced labor was found during the appraisal visit by IFC.

Occupational Health and Safety

Most operations are automated using modern machines with adequate safety features and limited moving parts. Potential risks come from lifting, repetitive work, posture injuries, and falls on slippery surfaces. All employees are provided with general health and safety trainings prior to commencement of work activities and OHS trainings is conducted once a year. Staff also undergoes pre-employment and annual medical examination.

While there have been no fatal or serious accidents in the past three years at any of OTH’s subsidiaries operational plants, Tunisia Cables and FUBA have high Lost Time Incident Frequency Rate (LTIFR - number of lost time injuries per million work hour). LTIFR at FUBA and Tunisia Cables in the past two year has been an order of magnitude bigger that than international industry benchmark for this sector. The most frequent types of accidents are injuries to hands, arms and feet (cutting, pressing/squeezing, struck by objects). Other OHS non-compliances (e.g., PPE, safety practices, equipment safety, etc.) were observed at these two plants during IFC appraisal visit. As per ESAP item #9, FUBA and Tunisia Cables will conduct a comprehensive, plant wide OHS assessment against Good International Industry Practice and PS:2 provisions. Based on the findings agree with IFC on a time-based action plan to implement corrective action as identified and develop a time-based mitigation action plan to ensure that all manufacturing plants/subsidiaries are taking preventive or corrective measures, commensurate with their operational risks.

OTH monitors workplace parameters like air quality, noise and light intensity etc. Measurements are conducted by a third-party laboratory. Overall, they are in compliance with national requirements and relevant limit values outlined in the WBG General EHS Guidelines Table 2.3.1, noise limits for various working environments, and Table 2.3.3 minimum limits for workplace illumination intensity. Inhalation of the dust is an important occupational health concern and requires appropriate engineering controls in processing areas along with work practices, medical surveillance and PPE usage. FUBA uses air conditioning to minimize or eliminate dust exposure.  As per part of the ESAP item #10, FUBA will monitor dust levels and develop a detailed action plan which will include budget and completion dates to bring PM10 values within the applicable limit values.

OHS issues are managed by plant level OHS teams. OTH's plant level OHS management includes systematic daily and monthly inspections and walk through/observation. Furthermore, HSE and Quality teams organize internal meetings to discuss OHS related issues and report directly plant managers. Records of incidents, including relevant corrective actions, are kept at plant level.

Furthermore, EHS trainings including PPE requirements, fire safety and emergency evacuation are provided to all employees during onboarding and regular refreshment trainings are also organized.

Resource Efficiency and GHG Emissions

OTH recognizes that resource and energy efficiency is an important aspect of its subsidiaries operations. The company has several initiatives to promote waste streams segregation at floor level and recycling of materials (e.g. plastics, metal, solutions contain high value metals). Energy audits were conducted at few plants to identify potential saving areas in the production processes and in the offices. Some of the resource efficiency actions taken following energy audit included: LED lightening, installment of active-passive filters to equipment consume high energy, air conditioners in some plant upgraded. Furthermore, in FUBA a reverse osmosis unit was installed to eliminate the use of HCL and caustic soda.

For all the plants, electricity is supplied from the national grid and diesel generators are only used as emergency back-ups. For the current operations, GHG emissions from all combines plants, primarily due to electric consumption, is estimated at about 30,000 tonnes CO2 equivalent/year in 2018. Going forward GHG emissions associated with the existing and new acquisition/plants will be monitored by OTH and reported to IFC annually.

Air Emissions

OTH’s subsidiaries monitor key emissions parameters from its facilities such as particulate matter (PM10), NOx, SOx, Ozone etc. A licensed third-party laboratory conducts air emission measurement at all facilities. The main emission sources are boilers and standby generators.  As part of this investment, potential expansion plants are expected to be in compliance with local regulations and WBG EHS Guideline requirements.

Water and Wastewater

Process water is supplied from the industrial zone authorities at all operational plants.  Except for FUBA, all plants utilize water for domestic use, while in FUBA, the total water consumption, comprises both process and domestic water use.

FUBA’s processes include Printed Circuit Boarding (PCB) coating, etching of developed film, electroplating and other coating operations, chemical removal of metals (principally copper and tin) from plates, and multiple washing operations. While some water from etching- water is recycled, most process wastewater is collected and pre-treated by the on-site wastewater treatment facility and then discharged to the public sewage system. According to the information provided, the discharged parameters at FUBA are above the limits of local regulations (e.g. copper, chlorides etc.). As per part of the ESAP item #12, the company is in the process of developing a detailed technical design and plans (with performance guarantees), including budget and completions dates for each item to upgrade wastewater treatment systems and ensure the FUBA wastewater discharges is in compliance with Tunisian standards and those defined in the WBG EHS Guidelines for Semiconductors & Other Electronics Manufacturing. FUBA will obtain performance guarantees on the selected equipment and complete wastewater treatment system in accordance with the technical design and plans referenced above that ensures compliance with Tunisian standards and WBG EHS Guidelines for Semiconductors & Other Electronics Manufacturing.

Tunisia Cables uses a closed-circuit system for its process water is and no discharges occur.  When needed, process water is collected by a certified contractor and disposed accordingly. At all OHT facilities, domestic wastewater is discharged to sewage network for further treatment, in compliance with local regulatory limits and the WBG General EHS Guidelines. Drinking water is supplied in bottles by third- party vendors at all the plants.

Solid Waste and Hazardous

Solid wastes generated by plants’ operations include papers, plastics, scrap boards, tin, aluminum, copper etc. These waste streams are segregated on site and recycled by licensed third parties. Hazardous wastes, such as waste painting, sludge from wastewater treatment, toners, and different chemical solutions used in productions processes, are also separately collected, recovered and disposed, or recycled when possible, by third-party licensed companies. FUBA has in-house recycling equipment for the recovery of the etching solution as well as copper and other high value metals from the etching process.

Hazardous Materials Management

Some of the facilities have above ground diesel storage tanks, with adequate secondary containment. Chemicals used in production, such as solvents and paint, are stored in dedicated and secure locations. All chemicals are also labeled and stored appropriately with relevant material safety data sheets (MSDSs). Appropriate fire extinguishing and spill prevention equipment is provided at designated areas.

 The company’s operations are located in industrial zones and not in close proximity to any stakeholders, except other users of the industrial park. In current practice, the company does not have a defined formal engagement procedure with the businesses within each industrial zone or any of the residential areas located nearby. Going forward, at a corporate level, the company shall develop and implement external stakeholder engagement procedure applicable for all plants as per ESAP item#11.

 Jalel Dammak

Email: jalel.dammak@onetech-group.com

Phone: +216 39 140 108

Address: 16, rue des Entrepreneurs

Z.I. Charguia II- 2035 Tunis- Tunisia