While all Performance Standards are applicable to this investment, IFC’s environmental and social due
diligence indicates that the investment will have impacts which must be managed in a manner consistent with
the following Performance Standards.

PS1: Assessment and Management of Environmental and Social Risks and Impacts
PS2: Labor and Working Conditions
PS3: Resource Efficiency and Pollution Prevention
PS4: Community Health, Safety and Security

EFC is already operational for several years now and no new construction or greenfield/brownfield developments are
foreseen under the project. No new land is therefore required. Similarly, as EFC’s fertilizer plant is in the existing
industrial zone in a highly modified habitat and far away from any residential community; IFC’s review concluded that
risks and impacts as anticipated by PSs 5, 6, 7 and 8 are not present.

This is a Category B project, in accordance with 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.
Key E&S issue and risks associated with the project include: (i) the company’s HSE, quality and process safety management systems; (ii) management of labor and working conditions, and occupational health and safety (OHS) procedures and practices; (iii) monitoring and management of air emissions, waste, wastewater and hazardous materials, and iv) and community health and safety in case of potential emergencies.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

The company has an established and robust E&S management system that applies to its operation. EFC's production sites are certified to ISO 9001, ISO 14001 and OHSAS 18001, and EFC is also compliant with the requirements of the European Chemicals Agency (ECHA) regulations and European Fertilizer Manufacturers Association (FE). There is detailed process safety and occupational health/safety (OHS) requirements in its plant.
Policy:
EFC has an HSE policy covering its fertilizer activities that describes the company’s principles and commitment in relation to HSE management. As per the policy, the company commits to comply with applicable laws, regulations, codes and standards, and achieve continuous improvement in its HSE management.
Identification of Risks and Impacts:
As part of its certified management systems (ISO14001, OHSAS18001) the company has documented procedures to systematically identify HSE related risks and impacts on an ongoing basis. The identified risks and impacts are further assessed for their significance and appropriate mitigation measures are identified and implemented.
Management Systems and Programs:
HSE management at EFC’s operational fertilizer plant is conducted through the implementation of plant specific HSE management systems, established after the initial IFC investments in OCI Group project # 30974. As per these systems; the company has dedicated qualified environmental, health and safety (EHS) personnel, identified E&S risks in its operations and possesses a formal documentation with structured EHS and Social organization and responsibilities, E&S policy, procedures, and supporting monitoring and recording systems and training programs. In addition, EFC also follows the sponsor’s corporate E&S policies and applicable management system requirements.
During review of EFC’s documentation, it was observed that EFC has strengthened its HSE implementation, monitoring and reporting capacity, as evident through the HSE related key performance indicators (KPIs) that are tracked and reported. Regular training programs address emergency response, EMS awareness, occupational health and safety, and waste management. Standard operating procedures (SOPs) and work instructions were clearly displayed in the production areas, with adequate signage and messaging together with information on KPIs. The management systems regularly undergo internal and external audits and the results are reviewed by the senior management.
Organizational Capacity and Competency:
There is a corporate Health, Environment, Safety, and Quality (HESQ) department in OCI to oversee HESQ related issues across all the group companies. The HESQ department establishes EHS goals and standards, and carries out internal EHS audits to ensure that corporate E&S policies are fully implemented. There is also a Health Social, Safety and Environment (HSSE) Director at EFC that reports to the Managing Director of EFC. There are 71 employees in the HSSE team, including Sr. Safety Engineers, Sr. Firefighter Specialists and OHS team leads.
Monitoring and Review:
EFC has developed environmental monitoring and measurement plans for its operation in line with applicable regulatory requirements. The monitoring parameters include air emissions, workplace air quality for ammonia and CO, hazardous wastes, recyclable wastes, KPIs related to electricity, natural gas, water and diesel consumptions, maintenance related parameters for equipment such as lifts, boilers, tanks and compressors; employee health and safety related KPIs among others. Monitoring results are reviewed by the EHS director, while the top management reviews the KPIs including incidents and accidents, monthly.

At the time of appraisal in 2018, the company had 798 direct employees and 208 contractor employees. The contractors are engaged in landscaping, catering, housekeeping and transportation of solid waste. All direct employees are Egyptian nationals. The reported female employment number was 14. EFC established and maintained contractor management plan to manage contractor’s working activities.
Human Resources Policies and Procedures:
EFC has an HR department headed by HR Director and a comprehensive set of HR policies and procedures. The key elements of EFC’s HR management approach are articulated in its code of conduct, manpower recruitment policy, performance management system, employee relations policies and procedures, and HR assessment policy.
Working Conditions and Terms of Employment:
Employment contracts clearly specify each employee’s position, detailed job description, functional and behavioral competencies, annual performance assessment and promotion processes, rights and responsibilities of the employee and the company, contract duration, salary and benefits, and feedback and grievance procedures. All employees receive copies of these documents during their induction training. The company has policies and procedures for talent identification, career path planning and training, and promotion from within.
Workers’ Organization:
According to OCI N.V.’s corporate HR polices, EFC does not impede workers’ freedom of association and right for collective bargaining. Workers can organize among themselves and are not intimidated, punished or discriminated against for doing so. Currently, however, EFC workers are not unionized.
Non-discrimination and Equal Opportunity:
As per its Business Ethics policy, EFC commits to ensure a fair work environment, being an equal opportunity employer, respecting privacy of employees and confidentiality of their information, and expressing intolerance for any discrimination based on language, race, sexual and political orientation, belief, religion, sect, age, physical disability and other reasons whatsoever.
Protecting the Work Force:
EFC has a corporate policy to forbid hiring of workers below the age of 18 years and forbid forced labor. HR department checks birth certificates during the hiring process. These requirements also apply to all EFC’s contract labors.
Grievance Mechanism:
The company strives to maintain a good working environment by encouraging open and direct communication between employees and their supervisors. The grievance mechanism includes clear procedures to receive, register, and address grievances. Employees who have work-related concerns, or feel that they have been treated unfairly, are encouraged to speak with their immediate supervisors. If the employee and supervisor are unable to resolve the issue, the employee is encouraged to go the next higher level of management or to HR. All the grievances are formally recorded, processed and closed within an established timeframe, based on the nature and urgency of the complaint.
As per ESAP action item #1, EFC shall develop a formalized grievance mechanism and procedure to allow for its employees to raise workplace related grievances or queries with the management, including anonymous grievances. The mechanism should include channels to raise the grievances (including anonymously), a process and timeline to receive, review and respond to grievances and queries, and a grievance database. The availability of such a grievance mechanism should be widely communicated to all the employees through internal memos, employment contracts and induction trainings.
Occupational Health and Safety:
Workforce health and safety (“H&S”) is a key component of EFC’s HSE management system - OHSAS 18001. Project related activities are subject to hazard identification and risk assessment to ensure that H&S controls are in place prior to starting the activity and that the workforce, including sub-contractors, are all suitably aware of the work hazards present, the correct use of equipment, the procedures to be followed and protective gear to be worn. The company provides HSE training during induction for all the employees, and sub-contractors. On-site HSE supervisors and HSE site officers are present across the facility, to ensure implementation of H&S procedures, equipment safety and the safe use of equipment and to monitor performance. EFC has a clinic on-site staffed by a full-time doctor, equipped
with an ambulance and fire truck during every shift.
The strict enforcement of HSE procedures by EFC is reflected in the excellent safety statistics reported by the company with no fatal or major reportable accidents. To strengthen its OHS practices, the client will update its existing OHS committee with elected worker’s representatives to support monitoring and addressing worker’s related issues.

EFC’s existing fertilizer manufacturing facility consists of 1.55 MTPD of ammonia and 2,000 MTPD of urea production lines, a urea granulation plant, a product warehouse, bulk loading and bagging facilities, ammonia storage, and associated utilities such as the demineralization water, effluent treatment plant etc. The main raw materials for EFC are natural gas and water, which are used as both raw material and energy source. Main sources of wastes and emissions include emissions from granulation vent stacks, boilers and reformers stacks, process wastewater and solid waste such as iron barrels, iron scrap, which is handled as described in the following sections.
Resource Efficiency:
In 2017 EFC has replaced its waste heat boiler and process gas cooler as part of its resource efficiency effort. The replacement was done by the Egyptian Projects Operation and Maintenance (EPROM), as per international codes and standards.
To identify opportunities to reduce its water consumption, as per ESAP # 2, EFC will undertake a study to identify ways to reduce the water consumption at EFC and propose an action plan. The action items may include process modifications, condensing and re-use of steam, recirculation, etc.
GHG Emissions:
Greenhouse gas (GHG) contributions from the facility are routinely calculated and recorded during operations. Based on the available information and considering all energy efficiency measures implemented by the company, the annual GHG combined emissions of the project are estimated at about 390,000 tons CO2eq. in 2016.
Air Emissions:
EFC established and maintained its control procedures to manage all the main sources of air emissions such as granulation vent stacks, boilers and reformers stacks. EFC has also adopted online Continuous Emissions Monitoring system (CEMS) and measurements for ammonia concentration on urea vent stacks and EFC plant fences. Based on the review of the 2016 EFC’s annual environmental monitoring report for particulate matter at boiler, NOx and SOx stack emissions were found to be compliant with the requirements of WBG EHS Guidelines Table 3.3.2 (Point Source Air Emissions Monitoring).
Water and Wastewater:
The water for domestic and industrial use is supplied by the city water utility with annual consumption estimated at about 8,685,000 m3. The water permit received confirmed the availability of adequate water. The raw water is treated to produce deionized water for boilers and process water requirement, while the water for cooling system is treated by chlorine dioxide as antibacterial, anti-scaling agent, dispersing agent and caustic soda.
Regenerated water from water treatment units are neutralized prior to using in internal landscaping. EFC generates about 450,000 m3 process wastewater annually. This wastewater undergoes the following
treatment; the waste water from process units including high-volumes of the cooling towers blowdowns flow to waste water pit for precipitation after adjusting PH.; Waste water from DM regeneration is neutralized in neutralization tank (dosing pumps: Caustic soda and HCL) where and heavy solid precipitate. An online PH analyzer is installed to monitor water quality prior to pumping to outside the plant to the irrigation pond. Two big ponds are constructed with HDPE liner for sedimentation and then water pumped through gravel filter to another pond provided which pumps the treated waste water to the irrigation network. Any waste oil is collected in oil pit. The precipitated sludge is being removed by municipal vacuum truck and sent to designated area by licensed contractors
The treated wastewater is used for irrigating plantation of non-edible trees near the facility location. The treated wastewater is tested against the Egyptian maximum Levels used in irrigation (Egyptian code # 501/2005 table (4.2) & (4-3) for short term use. All monitored parameters were observed to be within maximum allowable limits of the above-mentioned code. In addition, about 2,200 m3 sanitary waste water is discharged annually through the septic tanks as per the permit condition. Related to the ammonia plant, it includes contaminated de-oiled water and waste water from the chemical drain
around the boiler. From the urea plant, it includes de-oiled water and water from the chemical drains and floor washings generated on a periodic basis.
Solid and Hazardous Waste:
EFC has an established solid and hazardous waste management program. Accordingly, solid and hazardous wastes are stored separately at designated areas within the plant and disposed of through licensed contractors as per the environmental permit conditions.

As described earlier EFC’s fertilizer plants in Egypt are in the existing industrial sites that are far from residential areas, although Bedouin (nomadic Arab peoples who have historically inhabited the desert regions) are living near the industrial zone. All major risks to the population are considered in the design of the fertilizer plants. The plants are designed and built based on internationally accepted practices, with technologies selected for the process units that are proven to be safe. Risks are evaluated using quantitative risk assessment to consider equipment positioning and plant layout with the results of the assessment used in Front End Engineering Design.
Hazardous Materials Management and Safety:
EFC has detailed procedures to manage all hazardous materials. All ammonia is stored as liquid in double layer tanks. All other liquid chemicals are stored at tank farms with secondary containment dykes. Risk assessments are conducted for all ammonia storage facilities.
In accordance with international industry standard design codes, specific facility safety measures include; hazard emissions and leakage detection systems; automatic and manual shutdown systems; emergency isolation valves; secondary containment and, alarm systems.
Emergency Preparedness and Response:
The fire detection and suppression system established at the plant has automatic and manual fire detection systems; sprinkler or dry fire extinguishing systems. Emergency equipment including manual alarm, extinguishing equipment, detectors, fire hydrants are controlled and necessary maintenance is implemented regularly. Fire and emergency drills are also conducted regularly.
Toxic gas sensors are installed at appropriate locations. Certified reliable firewater pumps are adopted and adequate water storage is always made available for firefighting. EFC fertilizer plants are located inside existing industry zones, and the industry park can provide additional firefighting/emergency response (ER) support if required. There have been no major accidents and emergency response incidents in the past few years of operations.
Security Personnel:
EFC facility security procedures & its plans are kept in place. EFC does not employ any armed security personnel, the industrial zone security staff (external to EFC) are employed by industrial zone authority. Additional security measures currently include magnetic cards for employees for entrance upon recognition at the plant gates. All the security personnel are under EFC’s payroll and subject to relevant company procedures and regulations.

EFC’s stakeholder engagement activities are coordinated as part of OCI’s corporate responsibility initiatives. OCI’s commitment to communities includes a number of corporate social responsibility programs. In 2000, the company launched the OCI Foundation, which invests in educational programs designed to improve the communities in which OCI operates. The Foundation has provided scholarships to Egyptian graduate and undergraduate students to attend world class universities in the US and Europe. At the local level, OCI contributes to sustainable development by providing training, infrastructure development and sponsorships across Egypt, including construction of schools and clinics.
For all EFC’s operations, EFC management puts special emphasis on providing employment at local level, especially to people from close-by communities and women, by establishing collaboration with local authorities

Corporate Headquarters
OCI N.V.
Honthorststraat 19
1071 DC Amsterdam
The Netherlands
Tel: (+31) 20 723 45 00

Broad Community Support is not applicable for this project.