The land lots for both Toksun and Fuyang plants were purchased directly from industry parks. No new land will be required for the upgrades of Fengcheng and Xiangyang plants. All the plants are within established industrial zones. Therefore, PS5: Land Acquisition and Involuntary Resettlement, PS6: Conservation and Sustainable Management of Living Resources, PS: 7 Indigenous Peoples, and PS8: Cultural Heritage are not considered to be applicable to the project.

 Large scale lead-acid battery recycling plants include processes of waste acid neutralization/recycling and lead smelting/molding. Lead and other heavy metals in the wastewater need removal. The waste lead smelting and molding can generate significant lead fumes and dusts, which needs to be controlled for employee and community health. Without proper controls, these processes may cause potentially significant adverse environmental or social risks and/or impacts that are diverse, or irreversible.

The key E&S issues and risks and issues associated with this project include; i) corporate E&S management capacity to control E&S issues consistently at various sites, ii) proper design and operational controls to minimize lead fume/dust at working environment, iii) efficient occupational health/safety (OHS) controls to minimize cases with elevated blood lead levels for employees, and iv) point/fugitive emission and effluent controls to minimize lead spread to the environment and communities. This is therefore a Category A project according to IFC’s Policy on Environmental and Social Sustainability.                                                  

 Environmental and Social Assessment and Management System

Camel Group hires external experts to conduct E&S assessments for various new projects according to Chinese laws/regulations and its own technical standards. The company also has an established and robust corporate E&S management system that applies to all operations. All existing lead-acid battery assembling plants and recycling plants are certified to management systems of ISO 16949 (quality for automobile industry), ISO 14001 (environment), and OHSAS 18001 (occupational health/safety) standards. There are detailed environmental, occupational health/safety (OHS), and process safety requirements in Camel Group’s EHS management programs. Camel Group will apply these certification and internal management programs to newly acquired Gucheng and Fengcheng recycling plants.

For the proposed two new lead-acid battery recycling plants and upgrades of Fengcheng recycling plant and Xiangyang assembling plant, applicable IFC Performance Standards and WBG EHS Guidelines will also be applied in the E&S risk assessments and operations. Once such E&S assessment reports are finalized, the company will disclose those locally as well as on its website as part of its ongoing stakeholder engagement. As required in the ESAP 1, Camel will conduct a land acquisition review for two new projects in Xinjiang and Anhui in case previous farmer’s lands were acquired by local government, and propose mitigation methods in case the lands are not compensated sufficiently according to IFC Performance Standard 5, Land Acquisition and Involuntary Resettlement.

Policy

Camel Group E&S policy promotes Green Energy and Recycling Economy, which reflects its commitments for the sustainable development and the corporate social responsibility. The policy requires a health and safe working environment to minimize lead dust/fume levels and prevent accidents. Camel Group’s E&S policy is implemented though its EHS procedures, which include well-designed key performance indicators (KPI) to evaluate and improve E&S performances.

Identification of Risks and Impacts

EHS risks for any new projects are initially identified and mitigated during preparation phases by its Project and EHS Department. For new acquisition, the EHS due diligences focus on OHS and community safety as well as historical contamination. Mitigations and related cost should be proposed for management consideration before decisions made. During operational phases, EHS risks are identified through formalized auditing programs and informally frequent inspections. All these audits and inspections are summarized with corrective actions to mitigate the EHS impacts.

Management Programs 

EHS management teams at each plant are responsible for educating, training and motivating employees to understand and comply with EHS performance procedures and the EHS management systems have been set up to monitor and support the works throughout the organization. Camel Groups’ EHS management system is well developed and includes detailed technical standards, standard operating procedures (SOPs) and work instructions, internal codes for EHS performance, and an extensive inspection/audit program. Systematic monitoring of environmental performance and process safety measures are in place for workplace lead/dust levels, employee blood levels, point and fugitive air emissions, liquid effluent / contaminated rainwater controls, and waste management. Non-conformities to the technical standards are monitored and extensively followed up by the management.

Organizational Capacity and Competency

At corporate level, Camel Group has a Project and EHS Department, which is in charge of all technical upgrade and routine EHS management. The corporate EHS manager reports to the corporate project and EHS department director, who reports to CEO directly. The EHS team is responsible for ensuring compliance with the corporate EHS policy and management program implementation. The corporate EHS database is also managed by the corporate environmental team, which enables corporate management to quickly access the EHS performances at each plant directly.

At each plant, there is also an EHS team to manage the daily EHS operations according to corporate policies, programs, and procedures. The plant EHS head reports to plant general manager with dotted reporting line to corporate EHS manager. EHS performances are listed at each weekly corporate management meetings. Corporate project and EHS department director also chairs monthly EHS video conferences. All plant general managers and EHS heads are required to join the video conferences.

Emergency Preparedness and Response

There are sufficient firefighting equipment and firefighting water onsite, which are all properly maintained. The temperature and smoke sensors are installed at all battery charging/formation processes and connected to the central control room. Each plant has well documented emergency response (ER) plans as required by corporate EHS procedures. There is a voluntary firefighting team at each plant, which is trained by local fire brigades. Each workshop holds quarterly ER training/drills, while each plant holds annual fire/ER drill with participation of local fire brigades. 

Monitoring and Review

Camel Group has instituted comprehensive EHS monitoring programs. The key KPIs include employee blood lead levels, workplace lead/dust levels, noise levels, point source emissions, fugitive emissions, effluents, fence line air quality, waste handlings/disposals, recordable incidents, work permit review, etc.

Plant EHS teams conduct daily walk-throughs for EHS performances at each process. Corporate EHS team conduct monthly inspections for plants in Hubei Province and quarterly inspections at other plants. Due to more plants are being built or acquired outside of Hubei Province, corporate EHS team begins to implement mutual/cross inspections for all plant sites. Camel Group’s major automobile customers conduct their own EHS audits every one or two years or before any new product. As indicated in the ESAP 2, Camel Group will contract external experts to conduct annual third party EHS audits, with emphasis of minimization of workplace lead dust/fume and employees’ blood lead levels.                                                  

 Camel Group currently has approximately 6,100 employees and 1,200 service contractor employees. Approximately 300 new employees will be hired for this project. Third party workers are employed mainly in supporting activities including loading/unloading, security, warehouse, cleaning, canteens, etc. As part of this project, an undetermined number of construction workers will be hired by contractors for new lead-acid battery recycling plants and upgrade of Jingfeng’s two old recycling plants. Most of the construction workers will come from the local areas.

Human Resources Policies and Procedures

Camel Group has a corporate human resources (HR) policy that specifies the terms of employment and working conditions. These include procedures related to recruitment, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and firing, vacation, other leave, respectful workplace, including prevention of gender-based violence/verbal harassment, and retirement. The company has HR policy training that is part of the new employee induction, and all employees have access to this policy.

Working Conditions and Term of Employment

Under the employment terms that strictly follow the national labor law, workers are employed on fixed term contracts which are renewable subject to satisfactory performance and availability of work. Overtime work is uncommon and is usually only associated with emergencies. Staffs receive time-off or cash compensation in lieu of any overtime work at rates regulated by the national labor authority. Overtime work during holidays is compensated on the basis of 2 – 3 times of base salary. All employees have access to the insurance and pension funds as required by labor law. For employees of service or construction contractors who may work at Camel Group’s plant sites, Camel Group requires the contractors to fully comply with national labor laws and HR conducts periodic inspections.

Workers’ Organization

A worker union with elected union leaders is set up at Camel Group, as required by the All-China Federation of Trade Unions (ACFTU). Camel Group management is committed to keeping the union independent from management and allows collective bargaining.

Non-discrimination and Equal Opportunity

The HR policy specifies non-discrimination and equal opportunity. No procedures and/or practices have been identified as discriminatory. All the hiring and promotion are merit-based. When candidates have equal qualifications, preferences of hiring are given to local residents and females. Currently, approximately 26% of Camel Group’s employees are women. No gender-based violence/verbal harassment is identified during the appraisal. Camel Group plans to recruit more female employees in the new plants and increase the percentage of female employees.

Camel Group currently has a lead-acid battery assembling plant in Xinjiang Autonomous Region with approximate 10% minority employees. The hiring process in Xinjiang is strictly merit-based. As part of this project, Camel Group will promote hiring of more local minority residents for the new recycling plant in Xinjiang Autonomous Region.

Retrenchment

No retrenchment is also expected at any of the Camel Group’s plants in the foreseeable future.

Grievance Mechanism

Grievance mechanism is introduced during the new employee induction. The employees can report their grievances to either HR managers or labor union leaders. All the grievances and the mitigations are recorded. The HR managers/union leaders shall report to the senior management if they could not solve the grievance. HR email address and suggestion box are available for anonymous grievances.

Protecting the Work Force

Camel Group complies with national law and does not hire workers below the age of 18 years. HR checks birth and school certificates during the hiring process. The minimum age for Camel Group is 20.  No forced labor practices are used by Camel Group.

Occupational Health and Safety

OHS risks are one of the primary concerns for corporate management. There is no fatality or serious injury in recent operation history. There are effective OHS procedures and adequate personal protection equipment (PPE) is available for each position, and this is strictly enforced. 

For all Camel Group plants, the processes with acid fumes and lead fume/dust are within closed buildings with negative pressure. Wet surfaces are maintained, and ventilations are installed at all work places where there may be exposure to lead fume/dust with downdrafts. Separation/containment are installed wherever possible for potential high lead fume/dust workplaces, such as loading/unloading of lead smelters. Automatic controls are also installed at these workplaces to minimize employee exposures. The Company regularly monitors lead dust levels at all work places and these all meet local regulatory and IFC requirements, with the exception of Fengcheng plant. Mitigation is proposed according to ESAP 2.

All employees potentially exposed to lead fume/dust are required to wear full PPE, including hats, masks, gloves, and full body protection. The requirements are enforced strictly at all plants. Mandatory hand washing is required for tea and meal breaks. All the protective clothing is submitted to the respective plant laundry room after work. All employees are mandated to take showers including washing of hair before leaving the plants.

All employees potentially exposed to lead fume/dust are required to take blood tests every six months. If an elevated blood lead action level (400 µg/L) is identified, the employee is required to take medicine and transfer to non-lead position until blood lead drops below 400 µg/L; if an elevated blood lead suspension level (600 µg/L) is identified, the employee is required to take medicine and 15 paid leave or until blood lead drops below 400 µg/L; if one employee is identified repeatedly with elevated blood lead, he/she will be permanently removed to positions without contact of lead. As part of this project, Camel Group will target no case of blood lead suspension level and 1% or less of employees above action level.

The plant designs and OHS performances at two newly acquired recycling plants could not meet good international industry practices (GIIP). The PPE enforcement also could not meet GIIP. As a result, there are high percentage cases of blood lead action/suspension levels. As required in the ESAP 3, Camel Group will prepare technical upgrade and OHS enhancement plan with implementation timelines to improve the production processes at both Fengcheng and Gucheng plants and target to achieve no case of blood-lead suspension level and 1% or less of employees above action level. The plan will include, but not limited to, closing all processes with acid fumes and lead fume/dust in buildings with enough negative pressures, maintaining wet surfaces, installing ventilations at all work places where there may be exposure to lead fume/dust with downdrafts, setting up separation/containment wherever possible for potential high lead fume/dust workplaces, such as loading/unloading of lead smelters, installing automatic controls at these workplaces to minimize employee exposures, etc. There is no pending lawsuit for OHS issues at Camel Group.

Workers Engaged by Third Parties

HR and OHS performance are considered when evaluating potential contractors for construction or other major works. In line with the ESAP 4, Camel Group will develop a contractor E&S management plan to review and manage HR issues, OHS performances, and other legal aspects of construction contractors and other third parties hired for the project. The contractor management plan will specify the EHS requirements to be met by the potential contractors and third-party vendors. It will be used to evaluate all bids for construction contractors of new recycling plants and upgrade of Fengcheng and Xiangyang plants, and specific clauses will be included in the signed contracts. Only qualified contractors can submit their bids. Once contracted, all contractors are subjected to the same OHS management procedures as Camel Group employees, and the contractor employees also have access to Camel Group HR grievance mechanism.

Supply Chain

Used battery collectors are the main supplier for Camel Group’s lead-acid battery recycling business. Camel Group only signs purchase contracts with licensed collectors. The Company has a strict EHS audit program for its used battery suppliers. All suppliers are subjected to quarterly E&S audits by Camel Group’s EHS teams. The audit scopes consist of EHS compliances with local regulatory requirements and child/forced labor inspections.                                                  

 Resource Efficiency and Efficiency Projects

The main raw materials for lead-acid battery recycling industry are used batteries, and the main energy sources are electricity and natural gas, mainly for smelting process. Limited water is used in the process.

There are three energy/resource efficiency levels for lead battery industry in China regulations: Level I (<100 kg of coal/ ton of lead recycled), Level II (<120 kg of coal/ ton of lead recycled), and Level III (<130 kg of coal/ ton of lead recycled). All battery industries have to meet at least Level III requirements and are encouraged for Levels I and II. All battery assembling plants at Camel Group meet Level I efficiency requirements. Chukai recycling plant meets Level II requirements. Other new and planned battery recycling plants are expected to meet Level I or at least Level II efficiency requirements based on estimations from design criteria.

The newly acquired Gucheng and Fengcheng recycling plants can only meet Level III efficiency requirements. Camel Group has prepared energy/resource efficiency improvement projects for both plants to meet Level I or at least II requirements.

GHG Emissions

After Fengcheng and Xiangyang plants are upgraded and two new recycling plants in Xinjiang and Anhui are put into full production, this project will generate approximately 174,000 tons of equivalent CO2, mainly from fuel consumption of smelting process.

Pollution Prevention and Compliances

At Chukai plant, all the ventilation airs and smelter emissions from battery recycling processes are collected for wet scrubbing and electrostatic precipitation to remove lead dust, and the air emissions meet both regulatory requirements and WBG EHS guideline limits for Base Metal Smelting and Refining. Air emissions from new recycling plants at Xinjiang and Chukai are expected to achieve the same emission levels or better based on the design criteria. The air emissions from both Gucheng and Fengcheng plants meet local regulatory requirement and generally meet WBG EHS guideline limits, except dust. It is expected that the air emissions will fully meet WBG EHS guideline limits after the upgrades.

The outdoor surfaces at all plants are hardened and sprayed by water trucks four times a day to keep the surface wet and void fugitive emissions. The fence line lead dust monitoring shows compliances with local regulatory requirements.

There is no wastewater discharge at lead-acid battery recycling plants. All the wastewater is treated onsite and recycled back to processes, mainly for smelter quenching process. The sanitary wastewater goes to the municipal sewer system. All plants have rainwater collection system to collect the first 15 minutes contaminated rainwater, which is treated at the onsite wastewater treatment plant. Based on the monitoring data, the rainwater runoffs after 15 minutes meet both local regulatory and WBG EHS guideline limits. In case of emergency of large contaminated water generated (e.g. firefighting), the additional contaminated water is stored at onsite emergency retention ponds.

Solid and Hazardous Waste Management

Waste sulfuric acids from used battery are normally neutralized with caustic soda or caustic lime. However, the products are either with low commercial value or have to be disposed as solid wastes. For resource efficiency and minimization of waste generation, Camel Group developed two new technologies to treat waste sulfuric acids: 1) Membrane separation of impurities and evaporation concentration processes are used to recycle the waste acids to reusable sulfuric acid. 2) After heavy metal removals, the waste sulfuric acids are also used to react with ammonium bicarbonate to produce ammonium sulfate, a useful nitrogen fertilizer.

The smelting slags are checked for lead contents. If lead contents are larger than or equal to 2%, the slags are sent back to smelter for reprocessing; if lead contents are less than 2%, the slags are industrial solid wastes and are utilized in cement industry. After battery breaking, the plastic covers and separator papers are crushes and washed for decontamination. The plastics and separator papers are also recycled.

  Community Health and Safety

According to Chinese regulation, no residents are allowed within 1,000 m of any lead-acid battery plants. The normal operations at Camel Group plants have limited impacts to the communities outside of the industry zones. All Camel Group’s raw materials and products are transported by road trucks on average of 15 tucks per day for each plant. The road conditions are good, and there are no communities along the main transportation routes. There has been no major transportation accident in Camel Group’s operation history. As part of this project, Camel Group will provide blood lead test services for children of selected employees and employees who do not expose to lead but live in nearby communities.

Hazardous Materials Management and Safety

Used battery and lead ingot transportations are in the category of hazardous material transportation according to Chinese regulations. Camel Group only contracts licensed hazardous material transportation companies that have defensive driving programs, acceptable safe driving records, and sufficient emergency response methods. All the used battery and lead ingot transportations are under hazardous material manifest controls to avoid loss of any hazardous materials. All the trucks are equipped with GPS geoinformation system. Both transportation companies and Camel Group logistic teams can track the real-time movements of all trucks through GPS geoinformation systems. The logistic controller can reach out to truck drivers anytime. The transportation routes are pre-approved by local governments. If any truck is off the planned route or speed, an alarm will sound in the control room. The controller can then reach out to the driver for clarification. Camel Group conducts annual reviews for all transportation contractors.

Security Personnel

Camel Group hires an external agency for plant site security that conducts routine ID check at the gates and security monitoring.

  Stakeholder Engagement, Communications, and Grievances

Camel Group systematically analyzes its stakeholder structure and views the good relationship with key stakeholders as a benchmark of corporate success. The community liaisons at each plant reach out to communities near the industry zone regularly for general communication and grievances. Each plant has community open-days, at least once per year, to invite community leaders and activists to visit the plant, normally before Chinese New Year, for their better understanding of Camel Group’s production and EHS controls.

For plants located in economically less developed areas, the plants typically identify vulnerable residents (mainly families with disable people) and provide certain financial assistances, jobs, or educational supports. As part of corporate policy, Camel Group purposely recruits disable persons for feasible positions as part of their community engagement program. Currently, Camel Group has approximately 4% disable employees.

 Information Disclosure and Ongoing Reporting to Affected Communities

E&S assessment report for each new or expansion project will be disclosed locally according to local regulatory requirement. Besides, Camel Group also display real-time air emissions and fence-line monitoring data at electronic bulletin board outside of plant gates. As part of this project, Camel Group will publish sustainability information on its website, such as related sustainable development information, corporate E&S policies, point emission and fence line monitoring summary, transportation safety, etc.

   Camel Group will disclose this document in Chinese at its website (http://www.chinacamel.com). For inquiries or concerns about the environmental and social impacts of this project please contact:

Contact Person: Ye Xiaolong

Company Name: Camel Group Co., Ltd

Address:    No. 65 North Hanjiang Road, Fancheng District, Xiangyang City, Hubei  Province

Email:    yexiaolong@chinacamel.com

Phone:    +86-0710-3269011

Facsimile:   +86-0710-3269009