PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. The lands for the new sites are located in the port area, and in an industrial zone managed by the Guinean authorities. There are currently no claims to the lands and there will not be economic nor physical displacement.

PS6 (Biodiversity Conservation and Management of Living Natural Resources) is not applicable. All project sites are located in modified habitat 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 (ESMP). Key risks and issues during operations 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) establish and maintain internationally acceptable food safety standards (e.g. HACCP) in preparation, storage, delivery of food products; iv) ensure that the design and construction of all facilities accords with recognized building codes and life and fire safety standards, including dust explosion controls; v) pesticide use and management; and, vi) manage traffic safety in line with best international practice.

Environmental and Social Assessment and Management System

Sonoco does not have a corporate E&S management system (ESMS) but has started the process for ISO 22000 certification in its flour milling facility, which the company expects to obtain in the 24 months following IFC’s investment. Sonoco has an EHS policy for the flour mill only. A standalone group level EHS policy is yet to be drafted and implemented.

As outlined in ESAP #1, the Group will develop and implement a corporate ESMS, including i) an overarching E&S policy defining the environmental and social objectives and principles that guide diverse company operations to achieve sound environmental and social performance; (ii) identification of risks and impacts through an E&S due diligence procedures to screen each new project; (iii) management programs/procedures for environmental aspects, occupational health and safety, and fire safety; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) monitoring and review; and (vii) a community grievance mechanism in order to manage communication with customers and outside communities.. This ESMS, including the E&S policy, will be submitted to management for approval; then it will be fully institutionalized in the wheat storage facility, and in the seasoning cubes processing unit.

Identification of Risks and Impacts

According to the Guinean Environmental Law (Decree 199/PRG/SGG/89 of 8 November 1989), none of the projects to be financed are subject to an Environmental and Social Impact Assessment (ESIA). In its existing flour mill, the EHS Officer develops an action plan annually, and is assessing occupational health and safety risks and impacts at each work station twice a year. According to Sonoco, all permits are up to date but they were not sent to IFC for verification. For the new facilities, all relevant E&S permits will be duly emitted before construction.

For the new facilities, environmental and social risks and impacts 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. Key risks and issues during operations 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; iv) establish and maintain internationally acceptable food safety standards (e.g. HACCP) in preparation, storage, delivery of food products; v) ensure that the design and construction of all facilities accords with recognized building codes and life and fire safety standards; vi) pesticide use and management; vii) manage traffic safety in line with best international practice. These impacts are site-specific, largely reversible and readily addressed through mitigating measures that will be developed in the ESMPs and implemented throughout the project life. EPC contracts will include the ESMP provisions.

Management Programs

Sonoco has already developed and implemented the following management programs for its flour mill: OHS, waste management, hazardous materials management, quality and food safety. These management programs are fully in line with requirements of this Performance Standard. For the new facilities, management programs will be developed and implemented. All identified actions will be 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 should review and provide input prior to final design.

Construction phase

For each facility to be financed, there will be a construction ESMP related to air emissions, soil and water pollution prevention, noise and vibration, waste management, and occupational health and safety. It will also include provisions related to training (first aid, and emergency preparedness), fire safety, and access to the construction site (ESAP #2a).

Operations phase

Management programs for the seasoning cube processing unit and the wheat storage will be implemented under the supervision of an EHS Officer and will be consistent with those of the flour mill. The following management programs will be developed and implemented: OHS, food safety, waste management, pesticide management, air emissions, fire safety, and traffic safety. Moreover, because of the variety of risks in the wheat storage facility (e.g. self-ignition, dust explosion, OHS), Sonoco will develop a specific risk analysis procedure to evaluate the conditions and ensure that the silo and associated equipment (grain elevator, dryers, electrical equipment, and others as applicable) are operated in accordance with good international industry practice. Following the analysis, other relevant management programs may be identified, developed, and implemented (ESAP #2b).

Seasoning cube processing and wheat storage will be undertaken according to internationally recognized food safety standards consistent with the principles and practices of Hazard Analysis and Critical Control Points (HACCP). In the case of the existing flour mill, 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.

Organizational Capacity and Competency

The Sonoco Group currently has an organizational chart that does not include specific EHS staff and a responsibility matrix. However, the flour mill has its own EHS team developing and implementing a set of environmental and OHS procedures. Hence, as set forth in the ESAP #3 Sonoco will amend the chart such that to create well-defined EHS roles in the overall organization with appropriate reporting lines. Each new facility will have a designated EHS Officer responsible to develop and implement the management programs discussed above.

None of the existing construction sites have a designated EHS Officer responsible to implement an ESMP. Before start of construction of the seasoning cube processing unit and the wheat storage facility, Sonoco will hire an EHS Officer responsible to develop and implement an ESMP. During operations there will be designated staff responsible to develop and implement environmental and social related procedures, including processes to periodically evaluate compliance with laws and regulations, permits requirements, and to meet the applicable Performance Standards (ESAP #3).

Emergency Preparedness and Response

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 employees are aware of procedures and emergency instructions.

For the new facilities, Sonoco 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 (including communication with affected communities when necessary); 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 #4).

Monitoring and Review

As part of the Environmental and Social Management System (ESMS), Sonoco’s flour mill 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. A similar system will be set up for the new facilities.

Human Resources Policy and Procedures

Sonoco has about 400 full time direct employees, among which 100 with open-ended contracts and 10% women. There are 200 daily workers used mainly for unloading/loading trucks, and other basic tasks on construction sites. Third party contractors are hired to carry out transport, maintenance works, fire equipment inspection, and security.  For the construction of the new seasoning cube processing plant and wheat storage facility, a maximum of 50-80 workers per site will be hired. During operations of the seasoning cube processing plant, 30 to 50 workers will be hired, and 5-10 workers will be needed for the wheat storage facility.

All regular employees receive a contract approved by the “Inspection Régionale du Travail et de la Sécurité Sociale” (Labor Ministry). Sonoco 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 work category type of work. Sonoco’s minimum salary is more than twice the minimum legal requirement. Sonoco contributes to medical insurance for employees and their families. Each employee is registered at the ‘’Caisse nationale de sécurité sociale’’(CNSS) in case of work accidents.  In Guinea, the minimum age for work is 16 (‘’Code du travail de la Guinée du 10 janvier 2014’’), but Sonoco does not hire anyone under the age of 18 years.

Sonoco formulated a HR internal rules (‘’Reglement intérieur’’) in line with the national labor law. There are no provisions related to working conditions, non-discrimination and equal opportunity, harassment (including sexual), and grievance redress. As required by this Performance Standard, provisions related to the above requirements will be developed and implemented (ESAP #5). In addition, HR procedures will also ensure that the management of 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 law and regulations, all regular employees have the right to freedom of association. According to the national legislation, 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. At the time of the due diligence, none of the facilities had elected workers representatives due to the recent start of activities. The HR Manager confirmed that workers representatives will be elected during the next year.

Occupational Health and Safety

In the flour mill, 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, dust inhalation, and falls on slippery surfaces. In the future seasoning cube processing plant, risks will be similar to those in the flour mill. In the wheat storage facility, other OHS risks will be related to risks of burying, moving parts, work at height, and dust explosion. To minimize OHS risks and incidents at the flour mill, the EHS Officer and his 2 assistants currently conduct job hazard analyses twice a year, implement job instructions, and provide necessary PPE such as hearing protection, uniforms, masks, foot wear and gloves. Tool box meetings are conducted weekly. There is an infirmary on site with a full-time nurse. A similar system will be developed and implemented for the new facilities.

During construction of the new plants, Sonoco 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 will be included in the ESMP for construction mentioned above under PS 1.                                                  

Energy efficiency and Greenhouse Gases (GHG)

Energy is provided by the national grid in all existing facilities with back-up diesel generators.  Approximately two million kWh of electricity and 1,000 tons of diesel are consumed annually. There are 4 generators (1,500 kVA) at the flour mill. Sonoco owns light and large delivery trucks (25 X 40 tons), and maintenance is not carried out on site.

Annual GHG emissions of the operations are estimated at around 4,000 tons CO2 equivalent per year. For the new project, including the wheat storage facility and seasoning cube processing plant, only 1 large delivery truck will be used and GHG emissions of the future operations are estimated at around 2,000 tons CO2 equivalent per year.

Water and Wastewater

Water for the flour mill comes from 5 boreholes (extraction rate estimated at 4m3/hour and total annual consumption of 12,000 m3/year) and is tested at the laboratory to assess compliance with World Health Organization guidelines values. The water extraction permit is up to date.  There are two water tanks on site (a 156 m3 tank for potable water, and a 120 m3 fire-fighting retention tank).

There is no process wastewater in any of the existing facilities. The water for the flour mill is used to humidified bulk wheat (7-13L/ton) and there is no residual wastewater. For the new project, no process water will be used. Septic tanks will be installed for sanitary water. Stormwater is discharged in the municipal drainage system.

Wastes

Solid wastes generated by the company’s operations include empty cardboard boxes, plastic wrapping and wooden pallets. The latter is sold to local entrepreneurs. Plastics are reused by the workers. Other wastes are disposed to a local landfill by a license operator. 

Hazardous material Management

At the flour mill, fuel tanks are not equipped with proper secondary containment. In line with requirements of this Performance Standard, Sonoco will build appropriate secondary containment structures containing the larger of 110 percent of the largest tank or 25% percent of the combined tank volumes in areas with above-ground tanks with a total storage volume equal or greater than 1,000 liters. Sonoco will also develop a procedure for the management of secondary containment structures, specifically the removal of any accumulated fluid, such as rainfall (ESAP # 6).

Pesticide Use and Management

The risk of pest infestations is a reality of wheat storage, and insecticides and fumigants will be used extensively in the wheat storage facility. Sonoco will formulate and implement an integrated pest management (IPM) procedure targeting significant pest infestations. The IPM will integrate coordinated use of pest and environmental information along with available pest control methods, including biological, and as a last resort, chemical means. Pesticides will be handled, stored, applied, and disposed of in accordance with the Food and Agriculture Organization’s International Code of Conduct on the Distribution and Use of Pesticides (ESAP # 7).                                               

Community Health and Safety

All new facilities will be located in the industrial zone or at the port, but most suppliers and clients are located in urban and semi-urban areas where traffic could be heavy and risks of accidents high. Transport employees and sub-contractors are required to produce a validated driver license. Sonoco has already developed and implemented a safe driver and transport safety vehicle procedure, including training session for its own and third-party haulage contractors.

Security Personnel

Security is provided by private and public agencies. On site, there are 5 guards and 6 policemen permanently stationed. Sonoco 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), Sonoco 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. Sonoco will also assess, document, and propose management measures for risks arising from the project’s use of government security personnel deployed to provide security services.

Stakeholder Engagement:

Communities are not likely to be significantly affected due to this project. Going forward, as part of its ESMS, Sonoco will develop and implement a procedure for external communications that includes methods to (i) receive and register external communications and complaints from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) adjust the management program, as appropriate (ESAP action #9).

Contact Person: Alphadio Idriss HANN

Company Name: Sonoco

Address: A KA032 Ave. William Tubman - Conakry - BP.1492 - Guinea 

Email: alphadio.hann@sonoco-sa.com 

Phone: + 224 621 00 57 00