There are no impacts of concern associated with the following Performance Standards: PS4: community Health, Safety and Security is not applicable to the project because the company's activities are limited to within the physical footprint of their logistics facilities located within a commercial warehousing zone, and the facilities themselves do not present a risk to the neighbouring communities through operations or associated actions such as security services, transportation or storage of hazardous materials etc. PS5: Land Acquisition and Involuntary Resettlement is not applicable since all facilities are leased commercially, and IFC is not aware of any disputes, outstanding legal challenges or legacy issues related to land or property where the facilities are located; PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable since the company’s activities do not impact biodiversity resources or negatively influence sustainable use of natural resources. E&S risk of the traded commodities is low (mangoes, potatoes, tomatoes and onions). The company procures ingredients and intermediate products from local farmers. The company does not use or procure any products that are listed as threatened or endangered. PS7: Indigenous People – No indigenous people are known to have been in areas or affected by projects being considered for IFC financing; PS8: Cultural Heritage – The projects being considered for IFC financing are not located in areas of known historical or cultural significance.

Because IFC’s proposed investment in the company may be used to support future but, as yet, undefined projects in addition to the existing project, the principal Performance Standards (PS) to be applied to this investment are those listed above, a condition of IFC’s investment going forward will be that the company shall adopt IFC Performance Standards as part of the applicable legal and other requirements in all of its operations, and consider the issues identified in PS1 through PS8 when it is assessing any new business opportunities, acquisitions or mergers, or business models.

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.

 This is a Category B project in accordance with IFC’s Policy on Social and Environmental Sustainability because it may create a limited number of specific environmental and social impacts that can be avoided or mitigated by adhering to generally recognized performance specifications, guidelines, or design criteria. Key environmental, health and safety, human resources and social issues that were reviewed included the following: environmental and social management including oversight of supply chains; labor and working conditions; occupational health and safety – warehouse operations, collection, sorting, loading and unloading; emissions to the environment – air, water and subsurface; solid, and hazardous waste and materials management, including transportation; energy use and efficiency; community engagement and supply chain management.

Twiga Foods does not presently have an Environmental and Social Management System (ESMS), but manages relevant E&S aspects within its existing management system which is commensurate with its current scale of operations, and provides oversight of its corporate-wide practices, policies and procedures. As agreed in the ESAP action item #1, the company will develop and implement a comprehensive ESMS consistent with IFC Performance Standards (PS) requirements, with clearly defined lines of responsibility, monitoring and reporting functions, with Corporate ESG roles and responsibilities cascaded down to relevant operational levels. The combined ESMS will provide consistent oversight of environmental, social and health and safety for all its operations, sub-contractors and supply chain, as well as have provisions for screening of new opportunities, product lines and business models among others. The company will either hire or designate a qualified individual in the senior management of the company to ensure compliance with group policies and procedures, IFC and regulatory requirements and to ensure consistency with good international industry practice for ESHS performance. The individual will ensure there is a program of continuous improvement that includes training, monitoring, and reporting, and equally, communicating environmental and social aspects to external interested parties relating to the project.

Key stakeholders for the company are farmers, suppliers and distributors across various categories of farm products and commodities. The company procures products and ingredients from local communities. The company does not have long term procurement contracts with the suppliers, and hence engagement with suppliers so far has been limited to food safety, quality and commercial terms only. As the company expands its operations, there is opportunity to include good international industry practices on environmental and social performance in their procurement policies and procedures. As described in the ESAP action item #1, the company will develop and implement a Supplier’s Code of Conduct as part of a registration process for its suppliers. For existing contracts, these will be added as contracts are renewed. The company will also develop and implement a supplier review process to ensure that registered suppliers comply with company procurement policies and procedures as set forth in the Supplier's Code of Conduct, with special emphasis on elimination of labor risks such as child and forced labor, and are not engaged in prohibited activities.

The Human Resources department at Twiga has responsibility for overseeing matters related to labor, working conditions and health and safety. The company provides training to all staff to ensure they have adequate training to perform their work. Training of staff is done on a routine basis in compliance with local workplace regulations. Supervisors monitor that standards are met and any reportable incidents are reported and follow up action taken when required. Outcomes of training, monitoring and reporting complies with applicable national regulations, and largely consistent with IFC PS1 requirements.

 Twiga Foods currently employs 342 as full-time employees, and an additional 110 as contracted staff. Full-time employees comprise: corporate/HQ staff (Senior Management Team, Finance, HR, Tech and Admin staff), Field staff (Scouts, Harvest Coordinators and Sales Representatives), Pack House staff (Operations and Logistics staff) and depot staff (Area Sales Managers and Depot Clerks). Contracted staff comprise: Harvest staff and casuals at the depot (loaders and off loaders). The company has a human resources policy that follows local labor laws, and this policy is included in employment contracts, and addresses working conditions, terms of employment, and wages and benefits. Subcontractors, including housekeeping staff are required to comply with statutory labor requirements. Twiga Foods group has a formal human resources policy document and an employee handbook that includes terms of employment, rights and responsibilities of the employees, policies on grievance, non-discrimination, etc. The company follows national regulatory requirements, and has not been the subject of any violations of applicable labor laws, or labor strikes or disputes.

The company ensures that child labor or forced labor is not employed directly or by subcontractors through verification of relevant documents. Hiring practices and employment relationships recognize the principals of non-discrimination and equal opportunity, freedom of association and grievance redress. There is currently no workers union at the company. However, employees are aware of their right to freedom of association and can collectively represent to the management any issues or grievances that they may have. All employees have the right to be part of a trade union or collectively organize, and may choose to do so at any time during their employment with the company. Wages paid are above prevailing minimum wage requirements, and working conditions are similar to others in the same business in the country of operation.

Occupational health and safety (OHS) risks to employees are similar to others in food and beverage and associated logistics sector, which are managed satisfactorily at the company's facilities, with areas of improvement identified for safety in enclosed spaces such as refrigerated containers, signage, training, and use of personal protection equipment (PPE). Other OHS considerations include management of ergonomic impacts on labor from loading/unloading of some heavy material, physical hazards such as slip/trip/falls, electrical shocks, cuts and wounds; and chemical and biological hazards because storage and handling of fruits and vegetables. The company has an incident reporting system where incidents are reported up to management as they happen, and follow up corrective action undertaken after review. All employees in the company undergo a full training program at induction and subsequently on worker health and safety relevant to their job activity. Human Resources department maintains permanent records of participation to ensure compliance. Facilities are subject to annual audits by regulatory agencies to monitor compliance with labor regulations. The company follows regulatory requirements for occupational health and safety requirements and has recorded no significant lost time incidents or fatalities in its operational history. As agreed in ESAP action item #2, the company will review and update its existing HR policies and procedures to ensure formal documentation and communication to workers of its policies and procedures to ensure operational consistency with IFC Performance Standard 2 on Labor and Working Conditions.

Effluent generated at Twiga’s storage facilities include sanitary wastewater from toilets and food preparation areas, and limited quantities of wastewater from cleaning activities in the container storage areas. Commingled wastewater is discharged to the warehouse zone (Katko Complex) sewer which connects to the city sewer. Occasional solid waste primarily comprising of discarded packaging materials are disposed to recyclers. Minor maintenance and associated activity from routine operations is expected to produce limited quantities of hazardous waste which include used batteries, motor oils etc. These wastes are disposed by licensed waste disposal companies in a manner consistent with local regulatory requirements. Emissions to the atmosphere from the cold storage facilities will primarily include emissions from diesel fuelled generators that provide emergency backup power.

Refrigeration of fruits and vegetables is in containers equipped with individual CFC free refrigeration units. Electricity is bought from the local electricity distribution grid. The consumption of electricity for the facility is estimated to be about 350,000 kWh/ year, resulting in indirect emission of about 100 tons of CO2 equivalents annually. All water used at the facility is obtained from the municipal water supply system and is mainly used for housekeeping and sanitary usage. Annual water usage is estimated to be about 4,200 m3 per year.

No local community have been significantly affected by environmental risks or impacts from Twiga Food’s ongoing operations, and the company has not been the subject of any public complaints or litigation with respect to its environmental, social or health and safety performance. In Kenya, dialogue and communication with affected communities including public consultation and disclosure of environmental and social impact assessment occurs through procedures established by local authorities. Additionally, as the company's operations do not have any negative impacts on the surrounding community, no formal community engagement plan on Twiga Foods environmental and social performance has been undertaken by the company to date. As part of its environmental and social management program, as agreed in ESAP action item #1, Twiga Foods will establish methods for communicating environmental and social aspects to stakeholders and maintain procedures for receiving, documenting and responding to stakeholder concerns and grievances relating to their activities, in full collaboration with local authorities.

For more information contact:

Grant Brooke (Co-Founder and CEO)

Twiga Foods Limited

9 Riverside Drive

Nairobi, Kenya

+254 746 793669

info@twigafoods.com