PS5: Land Acquisition and Involuntary Resettlement is not applicable to this project as the company has no plans to acquire more land to expand operations. Mali Shi secured the parcel of land on a willing-buyer-willing-seller commercial basis for which it paid market-related rates, and which did not entail the removal of tenants or persons using the land.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable as the project does not entail the cultivation of living natural resources nor the conversion of natural habitat.

PS7: Indigenous Peoples is not applicable as no Indigenous Peoples have been identified within the company’s operational footprint.

PS8: Cultural Heritage is not applicable as there are no cultural sites within the company’s operational footprint and no cultural heritage has been identified. In the event that issues anticipated by these PSs arise including any additional company expansions, Mali Shi will promptly inform IFC. Screening and assessment of these issues against the requirements of the PSs will be done through the company’s E&S management system (ESMS).

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

   This proposed investment is expected to have limited environmental and social impacts, which are expected to be site-specific and none is expected to be significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. The project is designed to avoid, minimize and manage E&S risks and impacts of the company’s operations in compliance with Malian legal and regulatory requirements, IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines.

Key E&S risks associated with this investment are: (i) the occupational health and safety risks associated with the construction of the greenfield shea butter processing facility; (ii) once operational, capacity and ability of Mali Shi to manage and monitor the EHS risks associated with producing shea butter; (iii) occupational health and safety during operations; (iv) life and fire safety risks related to the chemical extraction process; (v) working conditions and terms of employment; (vi) wastewater and waste management; (vii) road traffic safety associated with transport of shea nuts; and (viii) sustainable supply chain assurance including raw material quality.

 Environmental and Social Assessment and Management System

As a greenfield project, Mali Shi has not yet developed an integrated strategy and framework for addressing environmental, health and security, food safety and social (EHSS) issues across its operations. Moving forward, the framework is expected to be developed in compliance with this Performance Standard as outlined in ESAP action #1. This shall include: i) an overarching EHSS policy; ii) process for identifying risks and impacts across company operations; iii) implementation of the mitigation measures as identified in the ESIA and any additional aspects as contemplated under the principles of IFC’s Performance Standards (as identified in the ESAP); and iv) aggregated monitoring process of EHSS parameters (such as energy and water consumption and efficiency; solid and hazardous waste volumes and disposal; wastewater volume; injuries; community complaints, etc.) to track changes on a monthly/annual basis and assess the effectiveness of management programs in mitigating the identified EHSS risks across company operations.

Policy

The company does not currently have a written EHSS policy but has general awareness of EHSS issues, which will be formalized moving forward. Per ESAP action #1, Mali Shi will develop an overarching statement of the company’s commitment to the sound management of environmental, health and security, food safety and social issues, encompassing the processing plant and its procurement practices across its network of shea nut collectors.

Identification of Risks and Impacts

In accordance with Malian law, Mali Shi prepared an Environmental and Social Impact Assessment (ESIA, dated May 2018) for the processing plant, which was approved on 30 August 2018 by the Ministry of the Environment, Sanitation, and Sustainable Development. However, the ESIA was not undertaken according to the requirements of IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines. As such, the scope of proposed mitigation measures as stipulated in the ESIA and to be implemented by Mali Shi at the processing plant are limited. Gaps in mitigation measures are described in further detail in each of the sections below and will be reflected as action items in the ESAP.

The design for the set-up of the processing facility has considered the requirements of Hazard Analysis Critical Control Points (HACCP). The company will undertake the necessary steps for developing and implementing procedures to comply with HACCP requirements and aims to obtain ISO 22000 certification within 3 years (see section below on PS4: Community Health, Safety and Security).

Management Programs 

The construction of the processing plant will be undertaken under the oversight of Kumar technicians from India, making use of locally contracted construction staff. As per ESAP action #2, Mali Shi will ensure that the necessary contractual clauses are included in EPC contracts, stipulating that labor and occupational health and safety measures and controls are in place at the construction site to mitigate the risk of labor non-compliances, accidents and injuries. Furthermore, Mali Shi will require regular reporting on occupational health and safety statistics from contractors during the duration of the construction phase.

As part of the ESIA, Mali Shi will be required to implement general corrective measures for managing environmental and social aspects of operations in order to reduce impacts related to: ambient air quality, noise, chemical spills, waste, wastewater, occupational health and safety, traffic safety, and community outreach. Based on the requirements of each of the Performance Standards described in the following sections, Mali Shi will be required to develop additional management plans or to further expand the scope of the corrective measures listed in the ESIA as reflected in the ESAP.

Organizational Capacity and Competency

Mali Shi has not yet established an organizational structure that defines the roles and responsibilities for implementing the company’s EHSS framework. However, the Company has been working with an external consultant to identify overall company resource needs by functional area and develop an overall organizational structure. Mali Shi has already hired a quality manager and as per ESAP action #3, will recruit a suitably qualified EHS manager and establish an EHSS function within the company. Responsibilities will include development and day-to-day oversight of the implementation of the EHSS management system and assigning responsibilities to staff for implementing the necessary tasks required under the overarching EHSS framework. Additional responsibilities of the EHSS function will entail oversight of human resource management and worker welfare, worker safety, and outreach to shea nut collectors and cooperatives. Oversight of environmental aspects such as tracking water and electricity consumption, and waste disposal at the processing facility will be delegated to the production manager.

Emergency Preparedness and Response

The biggest risk associated with the operation of the processing facility is explosion due to the highly explosive nature of fugitive hexane gas emissions from the solvent extraction unit if proper safeguards are not in place. The design of the processing plant follows best international practices. All structures will be equipped with the necessary life and fire safety and emergency prevention measures. This includes the solvent extraction unit, which will be in a fully enclosed structure and incorporate design criteria for equipment to be used in a potentially explosive atmosphere as stipulated in the ATEX Directive 94/09/EC (describing equipment and work space in an environment with an explosive atmosphere).

As per ESAP action #4, Mali Shi will be required to retain the services of a qualified life and fire safety engineer to verify the design of the proposed life and fire safety systems, in particular related to the solvent extraction unit. Mali Shi will also retain the services of a qualified external company to complete a risk hazard assessment of the types of incidents to which the company may be exposed (ranging from power and water outages, fire, explosions, flooding to on-site intruders and suspected sabotage), identify required emergency response systems (alarms/detectors, fire extinguishers, pressurized water hose system, etc.), procedures to be followed in the event of an emergency, and the regular training. Once construction of the processing plant has been completed, Mali Shi will request an inspection by the national fire authorities to confirm the safety of the operations and compliance with national law.

Monitoring and Review

In compliance with Malian law, Mali Shi will be required to agree to undergo an environmental audit every 5 years by relevant authorities to ensure the renewal of the environmental permit. Furthermore, the main off-taker (Bunger Loders Croklaan) will undertake regular compliance audits to ensure that the finished product meets their quality requirements as well as some EHSS parameters. Per ESAP action #5, Mali Shi will develop procedures for monitoring EHSS aspects of operations, including a clearly defined plan for regular monitoring and inspection of hygiene conditions at critical control points of the processing facility as well as overall conditions of the building and equipment, operation of the wastewater treatment unit, accident statistics, and grievances related to labor. Water and energy consumption will be tracked to set consumption reduction targets. Trends in EHSS data will be assessed regularly to evaluate the effectiveness of efforts to manage identified environmental, health and safety, and social risks across company operations.

   Construction of the processing plant will be undertaken by EDT under the oversight of Kumar technicians from India, making use of local construction staff (contracted through EDT). It is estimated that it will take 9 months to construct the processing plant, requiring 30-60 local workers, and up to 3 foreign workers on site. It is not envisaged that worker accommodations will be required during this period; expat technicians will be accommodated in designated local hotels or guest houses as necessary.

The processing plant is expected to operate 10 months out of the year (300 days) and 24 hours a day (three 8-hour shifts) with a scheduled shut-down for maintenance for 2 months. Mali Shi has retained the services of a local human resources consulting firm, which will evaluate the company’s human resource needs, develop terms of reference by position, and assist in the recruitment process. Once operational, it is estimated that the company will employ initially 44 employees and subsequently a total of 83 employees, once full operating capacity is reached. The company will also employ workers on a daily basis based on operational needs to help with the unloading of raw materials. Work will be undertaken in 3 8-hour shifts per day (7 AM-3 PM, 3 PM-11 PM, and 11 PM-7 AM) and workers will rotate across shifts in 4 teams such that each team works 6 consecutive days followed by 2 days off, averaging 48 hours of work per week (which complies with the Malian Labor Code).

Human Resources Policies and Procedures

Per ESAP action #6, Mali Shi will work with SAER (the external service provider, see below), to develop a human resources management policy and procedure in compliance with the national Labor Code, which describes the employment decision-making process based on equal opportunity and non-discrimination and includes the following: terms and conditions of employment; staff responsibilities, rights and benefits including working hours and rest time; overtime, annual and sick leave and gazetted holidays; minimum wages; equality of treatment; rules against sexual harassment and a respectful workplace environment; freedom of association; prohibition of forced and child labor; termination of contract and dismissal; right for collective bargaining; workers representation; and mechanism for workers’ grievances accessible to all workers (permanent and temporary). Mali Shi will also establish a monitoring procedure to ensure SAER is meeting all administrative aspects of HR management (such as reviewing and verifying, for example, that all salaries are paid on time, deductions are done correctly, and pension and healthcare contributions are made). Mali Shi will ensure that the human resources policy and procedures are accessible and clearly communicated to all workers (in French and local language as necessary) to ensure that employees understand their rights under national labor and employment law.

Working Conditions and Management of Worker Relationship

All Mali Shi workers will be employed through SAER, a human resource company active in the West Africa region, which is an external service provider that manages all administrative aspects of human resource management (contracts, payments, leave, etc.), which is a common practice for larger companies in Mali to outsource the administrative aspects of managing human resources. Through SAER, both open-ended staff (CDI, Contrat à Durée Indéterminée) and term staff (CDD, Contrat à Durée Déterminée) ranging from 3, 4, 6 and 12 months depending on the needed skills will be employed. All staff will have written contracts in accordance with the Labor Code in Mali, which specify the employment duration (several months) with a possibility for renewal, paid leave of 2.5 days per month worked, a trial period (15 days to 2 months for a 3-month contract), identification of job grade and salary, including a breakdown of amount to be deducted for contributions to the national pension (ITS, Impôt et Traitement sur Salaire) and social security (INPS, Institut National de Prévoyance Sociale) from the staff and from Mali Shi. In addition, term staff will be entitled to a fixed travel allowance and other indemnities in the context of work trips. A specific clause for dismissal and employment litigation will be included in the contract, which is signed by the prospective employee, SAER, the labor inspector (Inspecteur du Travail), and the physician (Médecin du Travail).

Mali Shi expects to pay salaries that are at least 20-25% above the minimum wage (which is 40,000 CFA per month), corresponding to approximately 50,000 CFA per month. Monthly salaries will range from CFA 50,000 (assistant machine operator), to CFA 75,000 (driver), CFA 100,000 (mechanic) and even CFA 300,000 (qualified administration job) hired under term contracts for specific duration.

The design of the processing facility includes basic changing rooms with lockers and blocks of toilets and showers (separate for male and female workers) in sufficient amount for the number of workers present on site. Mali Shi will ensure that the toilet facilities are provided with adequate supplies of running water, soap, and hand drying devices as per the WBG EHS Guidelines. There will not be an on-site canteen for the workers, but Mali Shi will ensure that there is an adequate where workers can eat.

Workers’ Organization

Mali Shi will not in any way prevent workers from seeking to join unions (such as Union des Travailleurs du Mali) or other workers’ organizations. Furthermore, Mali Shi will allow workers to select their own representative delegates from amongst themselves through elections to be held every year with a total of 2 delegates for the processing facility. Mali Shi management expects to hold regular meeting with union representatives or on an ad-hoc basis as might be requested by either party.

Grievance Mechanism

All workers will be able to voice concerns either to Mali Shi, the union (if workers are interested in establishing one at the site) or to SAER (if the concern is related to administrative aspects of employment, such as for example errors in payment). Mali Shi management also maintains an open-door policy for voicing all types of grievances. Suggestion boxes will also be located in strategic locations around the processing facility to allow for anonymous complaints. Workers will be informed of this process during regular meetings at the processing facility. Mali Shi will need to ensure that all grievances are systematically reported to Mali Shi management and recorded, tracked, and addressed. Per ESAP action #7, Mali Shi will design and implement a grievance mechanism accessible to all workers regardless of their types of contracts to ensure that a formal grievance process is followed. This will be communicated to SAER and needs to include: i) procedures for documenting, managing, and monitoring the resolution of grievances; ii) involvement at appropriate levels of management (including designated staff and accountability); iii) clear and timely management of grievances; iv) allowing for anonymous complaints to be raised and without fear of retribution; v) appropriate expertise to manage sexual harassment complaints; and vi) informing access to other judicial and regulatory mechanisms available under the Mali law for workers.

Occupational Health and Safety

Construction will be undertaken under the supervision of Kumar, the Indian engineering firm responsible for designing the processing facility, with locally subcontracted workers hired through EDT. Both Kumar and EDT have extensive experience in construction projects. Per ESAP action #8, Mali Shi will designate a health and safety officer who will be responsible for undertaking regular inspections of the construction site. EDT will also be required to designate a health and safety officer, who will be responsible for liaising with Mali Shi’s health and safety officer and oversee health and safety at the construction site. Their responsibilities will include identifying potential hazards and risks, providing regular health and safety awareness training and reminders to workers including job hazard analysis and associated procedures, use of appropriate personal protective equipment, and site rules concerning housekeeping matters such as waste management and safety related to the movement of equipment and vehicles on the construction site. In the event of accidents and injuries, health and safety officers are required to investigate causes of incidents to prevent recurrences and report to Mali Shi’s health and safety officer.

Once operational, Mali Shi’s health safety officer will have oversight of workers’ health, safety and welfare at the processing plant. Based on the Malian Labor Code, a representative from the Labor Inspectorate is expected to inspect the facility and measure indoor lighting and noise every year. The main health and safety risks for workers are expected to be related to the handling of heavy bags of shea nuts, improper handling of equipment and machinery parts, and slips and trips on potentially greasy surfaces on the floor of the processing plant. As per ESAP action #9, Mali Shi will develop occupational health and safety procedures for workers, which is to include a risk assessment matrix to identify types of hazards, likelihood of risk, and how to mitigate the risk through a combination of hazard signs, employee training on hazards, and use of personal protective equipment (such as gloves, face mask, and rubber boots). Procedures will also need to reflect steps to follow in case of an accident or injury, including documenting the occurrence of the injury and corrective measures to prevent reoccurrence, and tracking accident and injury statistics. Mali Shi will ensure that first aid kits are available on-site and that designated staff have received basic first aid training to provide immediate assistance in case of minor injuries and workers feeling ill. In addition, a doctor will be at the processing plant every 2 weeks to provide consultations for all workers requiring this.

In the context of the company’s food safety and quality management system (see section below on Community Health, Safety, and Security), Mali Shi will develop work instructions on personal hygiene for workers that will be posted throughout the processing plant and provide training.

Supply Chain

Shea trees (Vitellaria paradoxa in West Africa) grow naturally in the savannah of sub-Saharan Africa. In Mali, it is estimated that there are as many as 192 million trees occupying 90% of the agricultural land area, which alone accounts for 20% of the global supply of shea nuts. Shea trees depend on insects for pollination and start flowering once they reach 15 years of age: they produce fruit that can be used to extract butter 3 to 4 years later, with peak production occurring by the age of 50 and remaining productive for 150-200 years. Although shea trees propagate naturally, shea tree parklands are threatened by population growth and the need for increased land conversion for agriculture, destruction of trees due to wildfires and collection activities as a source of firewood (although shea trees are considered “protected” under local rules and customs governing resource access in Mali), soil erosion, and varying rainfall patterns as a result of climate change negatively affecting flowering and fruit production rates. Furthermore, fallows, which are vital for natural forest regeneration (through existing rootstocks or as newly established seedlings) are shrinking; the widespread use of herbicides is stunting plant growth; and insecticides—coupled with natural habitat loss for insects—is reducing insect populations, especially bees, which are vital in the shea tree pollination process. Finally, current land tenure and tree usufruct arrangements do not encourage the protection and planting of new shea trees, which further threatens the extent of shea tree parklands.

Once ripe, fruit fall to the ground and can be collected. A tree produces on average per year 15-20 kg of fruit, equivalent to 3-4 kg of nuts. It is estimated that up to 40% of shea nut production remains uncollected (100,000 tons), which can be due to a lack of buyer demand but likely also due to access challenges (for example, remote location/distance from villages or isolated trees). Production is concentrated in the southern part of Mali, in the regions of Ségou, Koulikoro (Dioïla), Sikasso (Bougouni), and Kayes (Kita). With increasing demand for shea nuts, it is likely that the tree will also be increasingly recognized for its economic value and thus more likely to be protected. Collection activities are undertaken primarily by thousands of women in rural areas between May and August to meet both self-consumption needs and as a means of supplementing their own source of income. Upon collection of the fruit, these are traditionally buried before roasting nuts over a fire, which reduces the oily content of the nut and releases carcinogens that tarnish the odor of the butter once it is extracted. Good fruit and shea nut handling and storing practices entail de-pulping fruits, boiling nuts as soon as they are collected, drying these in the sun, and removing the kernel from the nut for additional drying. Dried kernels are then pressed into shea butter. The quality of the shea butter therefore depends on the preliminary drying process. On average, it is estimated that a woman can collect 150 kg of shea nuts during a season. Women typically spend a few hours (2-3) early in the morning collecting fruits within a walkable radius from their village before they attend to other household chores and activities. The greatest risk to women is exposure to potential snake bites as they typically wear sandals when collecting shea nuts. Shea kernels are then sold either on local markets or through cooperatives (which resell larger aggregated quantities to traders and exporters) or transformed into artisanal shea butter and sold on the local market from July to January with a peak in October. The kernel contained in the almond (the nut) of the fruit is transformed into shea butter for use as a food oil (90%) for the food industry, and an ingredient in skin or hair care products (10%) for the cosmetic industry.

Mali is among the West African countries with the highest occurrence of child labor, which is the most prominent in the agriculture sector. Although the Ségou, Koulikoro (Dioïla), Sikasso (Bougouni), and Kayes (Kita) regions are believed to have the highest prevalence of child labor, typically children are not involved on a large scale in shea nut collection activities, as per ILO studies (Child Labour and Education in Mali published in 2012), given that women prefer to go on their own at their own (fast) pace during the early morning hours. Furthermore, shea nuts are collected from May to August (once they are ripe and have fallen off trees), which typically overlaps with school vacations (July to October). Therefore, the involvement of children, if any, would take place only during vacation periods and not entail dangerous conditions such as carrying heavy loads and potential exposure to snake bites.

Mali Shi plans to purchase shea nuts from SOATAF and through its own network, which it plans to develop. Of the total need for 16,420 tons of shea nuts in the first year, SOATAF will supply 20%; moving forward, Mali Shi will ensure that at least 20% of the plant’s needs are sourced from SOATAF and at full capacity, the plant is expected to need 30,000 tons of shea nuts. SOATAF sources shea nuts from a network of women cooperatives located in the Kayes, Sikasso, Koulikoro, and Ségou regions and plans to expand the number of women in its network from 25,000 to 40,000, organized into 200 cooperatives (currently 25) by 2019. SOATAF provides services to members of the network (see section below on Stakeholder Engagement), in the form of trainings on good handling and storage practices, processing equipment (for example, large cauldrons for boiling the nuts), and pre-financing during the shea nut collection season, which helps improve the daily living conditions of women. Mali Shi has a procurement contract in place with SOATAF; this stipulates the quantity, price, and quality of shea nut.

Mali Shi plans to develop its own network for procuring shea nuts in areas where SOATAF is absent (different districts in the zones of Bougouni, Siby, and Koulikoro). This will entail renting warehouses in each of the zones, each with a capacity to store 100 tons of shea nuts, and procuring a pick-up truck and two motorcycles for each zone to transport shea nuts. Furthermore, the company plans to work with an external service provider (see section below on Stakeholder Engagement) to help structure cooperatives, formalize record-keeping for better traceability, and provide training on good shea nut handling practices to ensure quality. Outreach activities for members of the cooperatives may also entail providing access to fertilizers for use in other livelihood-generating activities. The company plans to have written buyer contracts with cooperatives to purchase an agreed upon volume of shea nuts annually.

As per ESAP action #10, Mali Shi will develop, with the support of IFC’s advisory team, a supply chain management system including a responsible sourcing policy reflecting the company’s commitment to good shea nut handling practices, procurement log book to identify the procurement of shea nuts by cooperative, and a system allowing for traceability.

    Energy and Material Efficiency Projects

Mali Shi operations (processing facility) will primarily be powered by electricity from the national power grid, which for the most part is considered to be reliable except for occasional power outages during the rainy season (May to October). There will be 1 backup generator (1250 kVA), which will be used when power outages occur (expected to be of short duration). The largest energy needs are expected to be for operating equipment in shea butter extraction process (mechanical press and chemical extraction). There will be one boiler used for generating hot steam and hot water used as part of the production process and clean-in-place cleaning processes, which will be powered by biomass (briquettes obtained from the oilcake of pressed shea nuts, see section below on Solid Waste Management). This will operate continuously (to avoid additional energy requirements associated with frequent shut down/start up activities) and will be equipped with a heat recovery system to improve energy efficiency.

The company has made energy consumption projections and the annual total energy consumption is expected to be 2,505,000 kWh (once fully operational, processing shea nuts at the rate of 100 tons per day). Mali Shi is also in the process of exploring options for generating electricity on-site from renewable sources (solar and steam-generated power from the boiler) to reduce its dependency for electricity from the municipal power grid. The company has not yet undertaken any benchmarking studies to compare projected energy consumption efficiencies against other processing facilities in the same sector. As per ESAP action #11, Mali Shi will develop, with the support of IFC’s advisory team, an energy management plan to: i) monitor energy consumption; and ii) identify opportunities for reducing energy consumption (including energy efficiency initiatives as well as possible alternative energy sources).

Water

Water at the processing plant will be sourced from one on-site borehole; raw water will be stored in an above ground storage tank (with a capacity of 150 cubic meters) prior to being treated on site (chlorination, filtering, and UV treatment for water used in processing) to potable water quality level, which will be stored in another above ground storage tank (with a 50 cubic meters capacity). The raw water storage tank will also serve as the reservoir connected to the fire hydrants (see section above). Mali Shi expects to use initially 15,000 cubic meters of water per year (for processing 50 tons of shea nuts per day) and subsequently 27,000 cubic meters (once fully operational, processing shea nuts at the rate of 100 tons per day). Water will primarily be used for generating steam needed as part of the shea butter extraction process as well as in cleaning activities of the facility. The company plans to use clean-in-place (CIP) practices for cleaning equipment, which reduces water consumption.

The company has not yet undertaken any benchmarking studies to compare projected water consumption efficiencies against other processing facilities in the same sector. As per ESAP action #12, Mali Shi will develop a water management plan to: i) monitor water use; and ii) identify opportunities for reducing water consumption (such as reuse of treated water).

Air Emissions

The main source of air emissions from Mali Shi operations are from the boiler (estimated 8.5 MW), the fleet of 2 pick-up trucks, fugitive emissions of hexane gas (used in the solvent extraction process), and operation of the back-up generator (only during power outages, expected to be used on average less than 500 hours per year). Hexane gas will be used in the solvent extraction process, which will be equipped with sensors to monitor ambient hexane concentrations. Annual GHG emissions are estimated to be 1,321 tonnes of CO2 equivalent.

As per ESAP action #13, Mali Shi will develop and implement a written maintenance plan for the generator and the boiler to ensure that they are regularly serviced and continue to meet air emissions quality standards as reflected in WBG EHS General Guidelines for point source emissions to air. Furthermore, Mali Shi will keep a log of hours of operation of the generator such that if it is operated for more than 500 hours per year, Mali Shi will conduct air emissions measurements at the stack and compare parameters with WBG General EHS Guidelines for emissions (particulate matter limit (PM10) of 50mg/Nm³; NOx of 460 mg/Nm³; SOX of 2,000 mg/Nm³). If measurements exceed WBG limits, Mali Shi will propose corrective measures and a plan to bring all emissions into compliance with WBG limits.

Wastewater Treatment

The processing facility is expected to generate wastewater primarily from steam generation and factory cleaning activities. Mali Shi projects to generate an estimated 25 cubic meters of wastewater per day (equivalent to approximately 7,500 cubic meters per year). Wastewater effluent associated with shea butter processing operations typically contains high levels of fatty acids, COD, and BOD, which will be treated on-site and is expected to meet the WBG General EHS Guidelines standards for effluents. Per ESAP action #14, Mali Shi will install an on-site wastewater treatment system, which will consist of a series of interconnected water basins (for coagulating fatty substances, reducing the dissolved oxygen capacity, microbial breakdown, and filtration through active charcoal and a porous substrate), which will discharge into an on-site evaporation pond and also be available for reuse in boiler operations and for cleaning activities to reduce overall water consumption. Furthermore, Mali Shi will develop a wastewater management procedure, which will include periodic testing of the quality of the effluent to ensure the on-going effectiveness of the wastewater treatment unit.

Sanitation wastewater (from employee toilets and showers) will be connected to an on-site septic tank, which will be emptied as necessary by an external contractor.

Solid Waste Management

Mali Shi operations are expected to generate primarily large volumes of organic waste (in the form of oilcake, the residue from extracting shea butter from the shea nuts and sludge from wastewater treatment). The company plans to transform oilcake into briquettes for use as a combustible material in the boiler or as an alternative to charcoal. Mali Shi projects that during the first year, 3,750 tons of briquettes will be produced and as the capacity of the processing plant is ramped up to full capacity by year 9, this will increase to 15,000 tons of briquettes. The company estimates that only 20% of the briquettes will be needed for fueling the boiler even at full operational capacity. The remaining 80% of the briquettes will be sold locally primarily to women involved in supplying the shea nuts to Mali Shi, and at a lower price than charcoal. Besides the cost savings for women and the environmental advantages of using biomass briquettes over charcoal, the company also hopes that this will encourage women to boil the shea nuts after collection rather than burying and roasting them, which improves the oily content of the nuts. Annual revenues generated from the sale of briquettes compared to shea butter will be insignificant (less than 5%). Approximately 30 cubic meters of sludge are expected to be generated per year from treating wastewater, which will be disposed of through an external service provider although this could be used as fuel in the boiler or as an organic fertilizer for agriculture.

Mali Shi operations will also generate limited quantities of packaging material (plastic, cardboard, empty containers, and defective product packaging), used lubricants (grease, oil, and solvents), office waste (paper and ink cartridges), which will be removed on a regular basis by an external service provider and disposed of at a site designated by the municipality. Wooden pallets used for storing shea nuts off the ground are expected to degrade over time and will be used as fuel in the boiler; however, the company will review alternatives to using wooden pallets, which would not need to be replaced over time.

Per ESAP action #15, Mali Shi will develop a waste management plan, which will reflect the company’s commitment to reduce the impact of its operations on the environment through proper disposal of its waste streams. This will include proper handling and storage (in dedicated bins to avoid dispersion through wind), record-keeping to track volumes of waste generated, and evaluating alternatives to disposal such as recycling (for example, for glass, metal, plastic and paper).

Hazardous Materials

Mali Shi expects to use the following types of hazardous materials in its operations: i) hexane; ii) diesel (as fuel for the back-up generator when in operation); and iii) limited quantities of caustic soda (for clean-in-place process). Hexane is used as the solvent in the chemical extraction process to remove the remaining butter from the oilcake after it has already undergone mechanical pressing. The company estimates that 10,000 liters of hexane will be needed annually (during the initial phase for processing 50 tons of shea nuts per day) and a total of 40,000 liters once the processing plant is operating at full capacity (100 tons of shea nuts per day). Although the bulk of the hexane will be recuperated through distillation for reuse, fugitive gas emissions are likely to occur (see section above on Occupational Health and Safety). Liquid hexane will be supplied by an external service provider and stored on-site in underground storage tanks in a secured area. Diesel for the back-up generator will be stored in an integrated 1,500-liter fuel reservoir.

Per ESAP action #16, Mali Shi will ensure that hazardous materials are adequately stored with measures to prevent and contain spills. This will include keeping an accurate inventory of chemicals used, estimated quantities, and keeping Material Safety Data Sheets for all chemicals on-site.

Pesticide Use and Management

Per ESAP action #17, Mali Shi will develop a pest control and prevention procedure to fight insects and rodents. This will entail implementing an integrated management approach for maintaining a clean environment inside the facility (by preventing the accumulation of organic matter and removing all waste immediately), preventing entry (screened windows and keeping doors/windows closed), monitoring and repairing all potential cracks in walls, and keeping the exterior of the factory clear of vegetation. Pest control devices will include the use of glue-based traps, UV fly killers, and mechanical traps inside the factory and traps with poisoned bate only outside. Mali Shi will retain the services of an external service provider to undertake regular monitoring of traps to identify early on the potential need for more aggressive pest treatment.

     The design and lay-out of the processing facility will integrate the principles and practices of Hazard Analysis Critical Control Points (HACCP) to reduce the risks related to hygiene and food safety, which will mitigate potential impacts to the community. As part of HACCP requirements, the design of the processing facility will be organized such that products move from “dirty” to “clean” areas to avoid contamination and the packaging of the finished product is done through automated filling machines, thus removing the potential for contact between workers and the finished product. Per ESAP action #18 and with support from an IFC Advisory Services project, Mali Shi will undertake the necessary steps to obtain HACCP certification as soon as the processing plant is operational and aims to obtain ISO 22000 certification within 3 years. It is also expected that off-takers will undertake regular audits of the facility to confirm the quality of the finished product.

Mali Shi will have an on-site laboratory for undertaking daily microbial and chemical analyses of product samples, which will be logged according to batch code numbers and kept in case of a product recall. Per ESAP action #19, the company will develop procedures for product traceability to quickly identify and recall a product in case it does not comply with the company’s standards.

Transportation Safety

During the construction phase, there is a potential for accidents related to the circulation and movement of heavy vehicles belonging to the subcontractor accessing the construction site. Once operational, Mali Shi will use a combination of its own trucks and drivers (7 drivers) and the services of externally contracted drivers to transport shea nuts from collection points to warehouses and the processing facility. The company plans to purchase a fleet of vehicles, which will entail 2 pick-up trucks and 13 motorcycles by the time the processing facility is fully operational. During the shea nut collection season, shea nuts will be transported from cooperatives to the warehouses through externally hired vehicles and drivers.

The company will be required to develop a traffic management plan as well as procedures for the safe operation of vehicles per ESAP action #20. During the construction phase, this will entail erecting road signs on the access road to the site to indicate construction activities and setting a speed limit of 20 km/hour. The subcontractor will be required to ensure that all drivers obey traffic rules and provide awareness training as necessary. Once operational, Mali Shi will develop a process for screening drivers prior to hiring including verification of valid driver license and past driving record; providing driver safety training to respect speed limits, not use a cell phone while driving, use of a fire extinguisher, and vehicle maneuvering skills; procedures for limiting trip duration, duty roster to avoid overtiredness, avoiding dangerous routes and times of day to reduce the risks of accidents, use of speed control devices on vehicles; inspection of vehicles at the processing facility after each delivery for any evidence of having been in an accident; and overall truck maintenance to ensure good working conditions. The same requirements will apply to sub-contracted drivers.

Security

The site of the processing plant is surrounded by a 2 to 2.5-meter high, concrete perimeter wall with a grid on top. Mali Shi plans to employ 7 security guards through an external service provider. Security guards will be on-site for 24 hours/day, 7 days/week and rotate every 4 months. Security guards will carry only batons and will receive training through their employer. Per ESAP action #21, Mali Shi will review the screening procedures of the external service provider to confirm that security guards have been properly vetted (at a minimum, background check to verify criminal record) and are suitable for the job. Mali Shi will develop a security procedure, which will include: i) description of responsibilities of security guards such as controlling access and verification of people entering the site; ii) interactions with the Mali Shi workforce; iii) interactions with the surrounding community; iv) duties in case of an emergency at the site; and v) regular reporting to Mali Shi management in case of incidents or grievances received from the surrounding community.

  In the context of the Environmental and Social Impact Assessment (ESIA), which was undertaken in May 2018, meetings with local communities were held in the presence of the Mayor of Sénou to discuss land use and employment opportunities. Furthermore, Mali Shi and SOATAF held multiple outreach activities with shea nut cooperatives to inform them of the upcoming project and procurement needs. Stakeholder consultations will continue throughout the implementation of the project and engagement activities will be documented. Per ESAP action #22, Mali Shi will designate staff with oversight of stakeholder engagement activities and to develop and implement a procedure to: i) map stakeholders; ii) undertake and record stakeholder engagement activities; iii) receive and register external communications from the general public and potentially affected communities; iv) screen and assess the issues raised and determine how to address them; v) provide, track, and document responses, if any; and vi) adjust aspects, as appropriate, of company operations.

Through the existing operations of Omnium Mali, the Sponsors have already established a relationship with local communities through activities such as organizing a soccer tournament and sponsoring youth organizations, cultural events, and public events of the fire department. SOATAF already has established partnerships with leading development organizations specialized in shea, such as the Inter-Church Organization for Development Cooperation (ICCO) and the Global Shea Alliance (GSA). ICCO is a non-profit, which supports small-scale farmers, farmer organizations, and SMEs by providing technical advisory services on agri-food value chains and linking them to markets, with the objective of securing sustainable livelihoods. In Mali, ICCO has been involved in formalizing and building the capacity of women cooperatives involved in the shea nut trade. ICCO has been involved in building 38 warehouses and developing a traceability system including a database of women (currently a total of 25,000) involved in the collection of shea nuts. The Global Shea Alliance (GSA) comprises 390-member companies from 30 countries and groups together the key stakeholders of the shea sector. Its focus is to promote good practices for shea nut handling and storing while also supporting the livelihoods of the women involved, to ensure the high-quality requirements of international off-takers are met. Furthermore, with funding from USAID, GSA is implementing a project in Mali in cooperation with ICCO, SOATAF, and ICRAF to plant 100,000 trees and protect 1 million trees to begin tackling issues related to shea parkland preservation and production.

In the context of Mali Shi operations, the company will also engage with ICCO and GSA to promote efforts among women cooperatives to promote among other: i) good practices for shea nut handling and storing including the use of briquettes as an alternative to charcoal; ii) awareness of the risks related to wearing sandals when collecting shea nuts and the exposure to potential snake bites; iii) continued awareness of the mandatory education of children age 7-16 to limit the involvement of children in family-related agricultural or other livelihood generating activities, which may interfere with their education; and iv) efforts to protect and regenerate shea trees. Per ESAP action #23, Mali Shi will develop an outreach program for women cooperatives reflecting programmatic areas and targets, and including a process for monitoring and evaluating progress made toward achieving targets.

    Contact Person: Simballa Sylla, Director General

Company Name: Mali Shi

Address: Rue 408 Porte 10, Niaréla, Bamako, Mali

Email: simballa@omamali.com

Phone: +223 76 40 84 48

Facsimile: +223 20 21 90 93