Policy
The company is in the process of finalizing, formalizing and adopting overarching policy statements that, when combined, will define their environmental and social objectives and principles to guide the project to achieve sound environmental and social performance. For example, policies on fair labor have already been developed (that are required as part of the SIZA certification, the Sustainability Initiative of South Africa, https://siza.co.za/) along with those that address principles of environmental planning and land development, wildlife conservation, efficient use of energy, water and other natural resources, and human resources. These policies will provide a framework for the environmental and social assessment and management process; they specify that the project will comply with the applicable laws and regulations of the jurisdictions in which it is being undertaken.
Identification of Risks and Impacts
The company has in place a process for identifying, and keeping current, assessments of those environmental and social risks and impacts associated with the project. The combination of South African laws and regulations and the on-going requirements of GLOBALG.A.P and other recognized standards (e.g. SIZA and valid customer requirements such as Field to Fork) ensures that the scope and level of effort devoted by the company to this process is commensurate to that of the risks and impacts of a project of this type. For example, for existing operations, the GLOBALG.A.P risk assessment requires identification of the hazards found on site that could harm both the environment and farm/pack house workers as well as visitors, and contractors; these hazards are then assessed for the risks associated with them and measures to avoid or manage them implemented. SIZA requires assessment of risks associated with the following 8 principles: commitment to implement management systems, no forced and bonded labor, no child labor, freedom of association and collective bargaining, no discrimination, harassment and abuse, health and safety, wages, benefits and terms of employment, and working hours. For new projects, of those undergoing expansion, the processes in place ensures that the company only acquires suitable land; i.e. land that was previously used for agricultural purposes, that is obtained in willing buyer/willing seller transactions, and that has associated water rights sufficient to irrigate the blueberry plants that will be put into production.
Example risks and impacts discussed during the site visit included those related to labor and working conditions, worker health and safety (including fertilizer and pesticide management) appropriate use of natural resources (including soil and water management and integrated pest management), waste and pollution management, and community relations, including complaints management. Further, this activity showed that there are no individuals and groups that may be directly and differentially or disproportionately affected by the project because of their disadvantaged or vulnerable status.
As such, the combination of the above processes considers all relevant environmental and social risks and impacts of the project, including the issues identified in Performance Standards 2 and 3, i.e. those relevant to this project.
Supply chains
The main inputs required by Mbiza operations are the genetic material (i.e. the blueberry plants), fertilizers, soil enhancement and micro elements, pesticides irrigation equipment and packaging materials. Additional inputs include parts for mechanical equipment. Inputs are sourced from reputable suppliers within South Africa; inputs sourced from outside South Africa (such as the genetics of the new blueberries) emanate from Australia. As such, risks and impacts associated with the company’s supply chain are considered to be managed.
Management Programs
The company has established management programs that describe mitigation and performance improvement measures and actions that address the above identified environmental and social risks and impacts of the project. Evidence of their efficacy can be found in ongoing successful certification to recognized international standards and compliance with host nations laws and regulations. For expansion projects, the company is integrating new initiatives into their operations, such as a solar plant at the farm level, designing adequate on-site staff accommodation, rest areas and training rooms, a bespoke pump house and office building (to include safe and secure areas for chemicals management/storage and fertigation inputs), and a cooling and refrigeration/processing and bulk packing building also at the farm level.
To better manage information regarding operations, including that of E&S matters, the company has launched an online knowledge portal. Policies, procedures, audit results and proprietary know-how will be housed therein. Some information will be made available to customers to allow them to track company performance on E&S matters.
Organizational Capacity and Competency
The company has established and maintains an organizational structure that defines roles, responsibilities, and authority to implement the management of environmental, OHS and social matters. Specific personnel have been so designated at both the farm level and at HQ.
Matters of E&S management are overseen by those responsible for a technical discipline (such as the HR manager at HQ) and further implemented by designated farm-level HR personnel, such as the HR practitioner and liaison officers or use of HR consultants while permanent HR personnel are hired. Individuals responsible for obtaining and maintaining GLOBALG.A.P certification, such as the production managers found on each farm, have other individuals responsible for specific functions, such as irrigation, stores and equipment, workshop and maintenance, nursery and research, reporting to them. Overseeing the entire certification process are personnel at HQ, including those responsible for managing and implementing the internal audit function.
The pack house managers are responsible for E&S matters as they pertain to those operations, including elements of HR management, and aspects of relevant certifications and quality control. Pack house operations are relatively straightforward and include receipt of berries, storage (if necessary) basic sorting, packaging and loading them on to trucks.
During the appraisal, IFC held conversations with the above managers at HQ and at the respective farms; such provided IFC with assurance that the managers and their reports were very experienced in farm management and associated activities and were competent with respect to E&S aspects as contemplated by the performance standards.
Emergency Preparedness and Response
The project does not involve specifically identified physical elements, aspects and facilities that are likely to generate impacts resulting from emergency situations beyond those in the pack house that may be associated with life and fire safety. As such, emergency preparedness and response activities are limited and address issues such as fires and the need for associated evacuations. Medical emergencies (such as those that may be experience by workers on the farms) are addressed by local emergency services (through them sending ambulances) on an as needed basis.
Monitoring and Review
The company has established procedures to monitor and measure the effectiveness of the management programs, as well as compliance with related legal and/or contractual obligations and regulatory requirements. Central to this are the internal audits that review both regulatory and voluntary requirements. Outcomes are evidenced by the certification to recognized standards and the successful compliance to regulatory audits (such as from the Department of Labour) that require such measures to be in place. Copies of current certifications to GLOBALG.A.P, current water permits and operating licenses from respective local municipalities were reviewed by IFC during the site visit.
With regards to material inputs to farming operations, prudent water use (and associated fertilizer application through fertigation) is achieved using drip irrigation. Soil moisture levels are monitored using potentiometers; only the required amount of water is then administered. See PS 3 below for more initiatives regarding reducing water usage. Fertilizers are introduced into the irrigation network (i.e. fertigation is the standard practice). Pesticide application rates are minimized through use of an integrated pest management program that monitors for the presence of economically significant infestations before specific control measures are considered. Therefore, the extent of monitoring is deemed commensurate with the project’s environmental and social risks and impacts and with compliance requirements such as permitted use of water.
Additional key performance indicators (KPIs) are further being developed at the farm level to track corporate responsibility activities and their associated budgets. Example projects include borehole development for communities, support to sports teams and ethical initiatives tied to SIZA certification.
Senior management within the company receive periodic performance reviews of the effectiveness of the management of material environmental risks and impacts. These reviews take the form of review of certifications, status of compliance with laws and regulations (which are audited by the internal audit team), and quarterly technical farmer’s meeting which allow best practices to be shared among farms. Based on results from such reviews and activities, senior management takes the necessary and appropriate steps to ensure the operations are run in a way that supports the intent of the client’s policies with regards to E&S matters.
