PS5 (Land Acquisition and Involuntary Resettlement) is not applicable as the project does not involve any land acquisition. Similarly, no indigenous people or cultural heritage will be impacted by the project, therefore PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, because potential adverse environmental or social risks and/or impacts are limited, few in numbers, site-specific, largely reversible and readily addressed through mitigating measures aligned to generally recognized performance standards, guidelines, or design criteria.

The environmental and social impacts that are expected to occur are those related primarily to agricultural production. The most significant of these potential impacts are related to labor practices, including child labor, forced labor, and occupational health and safety. Other E&S issues include food safety, potential impacts on biodiversity, and emergency preparedness and response.

Environmental and Social Assessment and Management System

Biovanilla has a corporate E&S management system (ESMS). It includes an Environmental and Social Policy, as well as a Labor Policy signed by management. Biovanilla has identified the basic E&S risks and impacts of its activity, but mainly for plantations. The risk identification process includes screening against the relevant legislation, identification of potential risks, analysis and assessment by competent staff. Key E&S issues are related to risks of injuries and snake bites for plantation workers, child labor, soil and water pollution by pesticide use, waste generation, use of hazardous materials, and risks of deforestation. Building on the plantations ESMS, Biovanilla will expand its risk identification process to operations at the 2 packaging facilities, where main risks and impacts are related to OHS, food safety, and emergency preparedness and response (ESAP #1). 

Management Programs

Biovanilla has developed and implemented management programs mostly for plantation operations and farmers operations supplying the cooperative. These management programs are related to occupational health and safety (OHS), child labor, soil and water pollution, waste management, hazardous materials management, and biodiversity conservation at vanilla plantations. There are no management programs implemented for the packaging facilities in Sambava. Biovanilla shall implement the following programs at the plant: OHS, food safety, and emergency preparedness and response (ESAP # 1). In plantations, all identified actions are assigned to specific staff along with a required implementation schedule and a budget. In case of major material changes to operations and changes to E&S risks and impacts, staff should review and provide input prior to final design. There is a basic grievance mechanism for external stakeholders in a written form.

Organizational Capacity and Competency

Biovanilla has an organizational chart including management and sustainability positions in line with requirement of this Performance Standard which includes a Sustainability Manager, an E&S Coordinator, an Environmental Assistant, a Social Assistant, a Training Officer, a Certifications Officer, and Community Liaison Officers. Current staff have the skills and training to effectively manage E&S risks and impacts at Biovanilla operations. In 2018, training programs were conducted and covered the following topics: Rainforest Alliance principles, Sustainable Agriculture Network standards, certified vanilla traceability, occupational health and safety, first aids, and conflict resolution.

Emergency Preparedness and Response

Major risk for emergency situations for Biovanilla include fire at their headquarters and packaging facilities. No major incidents have occurred since beginning of operations.

Biovanilla will develop and implement an emergency preparedness and response plan, which will include the following elements: identification of emergency scenarios; specific emergency response procedures; training of emergency response teams; emergency contacts and communication systems/protocols (including communication with affected communities when necessary); procedures for interaction with government authorities (emergency, health, environmental authorities); permanently stationed emergency equipment and facilities (e.g., first aid stations, firefighting equipment,  personal protection equipment for the emergency response teams); protocols for the use of emergency equipment; clear identification of evacuation routes and muster points; and emergency drills and their periodicity based on assigned emergency levels (ESAP #1).

Monitoring and Review

Biovanilla does not have a structured EHS monitoring and reporting system for the E&S aspects of its operations. Biovanilla will develop and implement a procedure to monitor Key Performance Indicators against set E&S goals, including: a) Safety in the plantations and in the packaging facilities– Lost Time Injury Frequency Rate, Accident Free Days; b) Resource Efficiency – water usage, energy usage, and others; c) Waste – quantity per type. Monitoring frequencies and methodology will be specified considering the risks and impacts. The monitoring data will be compiled in a centralized database for development of summary reports, and regularly presented to senior management for review against set targets. Corrective measures will be defined, and implementation will be agreed upon (ESAP # 1).

Human Resources Policy and Procedures

Biovanilla has 236 full time employees, among which 129 women (55%). These include employees working with the Cooperative Exotic. There are 53 daily workers used mainly for packaging during the peak season. Third-party contractors are mainly hired to carry out maintenance works, and fire equipment maintenance.  There are 40 collectors with individual contracts.

Biovanilla is in compliance with the local labor code, which defines the various work categories, employee benefits, as well as minimum salary to be paid for each type of work. Biovanilla contributes to the ‘’Caisse nationale de prévoyance sociale’’(CNAPS) (insurance in case of work accidents). In line with legal requirements, daily workers are equally entitled to CNAPS. There is also a health insurance for all workers, independent of work category. Although in Madagascar, the minimum age for work is 15, Biovanilla does not hire workers under the age of 18 years.

Biovanilla has major international clients which suppliers are required to prevent discrimination based on race, gender, ethnicity, nationality, or religion, and any form of physically or mentally abusive workplace practices.

The existing HR Policy (‘’Règlement intérieur’’) and Environmental and Social Policy include working conditions, working hours, OHS, non-discrimination, disciplinary measures, and provisions related to sexual and moral harassment, child and forced labor. There is no formal grievance mechanism.  Biovanilla will ensure that the management of contract labor including daily and third-party workers is fully aligned with the requirements of this Performance Standard. This will include provisions related to access to: personal protective equipment (PPE), a grievance mechanism, and OHS training and workplace safety measures (ESAP # 2).

Workers’ Organizations

As per local labor laws and regulations, all regular employees have the right to freedom of association. According to the Malagasy labor law, workers’ representatives have the following tasks: ensure that workers grievances are communicated to management and to the Labor Ministry; ensure implementation of OHS preventive measures; propose measures to improve work organization and productivity; and opine on potential retrenchment. At the time of the appraisal, no union representation was active and no workers’ representatives had been elected. Biovanilla will discuss with workers the best channel to assign workers’ representatives.

In addition, Biovanilla complies with good international industry practices requirements for suppliers and recognize workers’ right to form or join trade unions, provide wages that support the purchase of basic necessities for an individual or family; and ensure that working hours are in line with legal mandates.

Occupational Health and Safety

Biovanilla’s operations pose few OHS risks to workers. During Due Diligence, IFC identified that potential risks in the packaging facilities come from lifting, repetitive work, posture injuries, falls on slippery surfaces, and risks of fire. In plantations, potential risks identified by Biovanilla are related to transportation, insect and snake bites, and walking on uneven terrain and associated injuries. However, at the time of appraisal overall OHS performance did not seem to be an issue given the low risks. Proper OHS will be addressed through management programs defined under ESAP # 1 described above. To minimize OHS risks and incidents, Biovanilla conducts job hazard analyses and provides as needed necessary PPE.  Biovanilla does not maintain records of accidents for reporting to social security services.

Moreover, Biovanilla complies with international clients’ requirements related to safe and healthy working conditions and at a minimum: potable drinking water, clean restrooms, adequate ventilation, fire exits, and essential safety equipment including training, an emergency aid kit, access to emergency medical care, and appropriately lit work stations. Facilities are required to be constructed and maintained in accordance with applicable laws.

Supply Chain

According to the US Department of Labor, children in Madagascar are engaged in the worst forms of child labor, including hazardous activities in agriculture, including production of vanilla. In 2016, Madagascar made a moderate advancement in efforts to eliminate the worst forms of child labor. The Government increased the number of child labor inspectors from 4 to 15, launched a study with UNICEF to assess violence and exploitation of children in Madagascar, and expanded the implementation of the Government of Madagascar’s Code of Conduct for the Protection of Children This Code has been signed by Biovanilla management. Moreover, 44% of Biovanilla’s production is Rainforest Alliance certified, providing clients confidence that child labor is not likely. Contracts of vanilla collectors include provisions against child labor but alludes to the legal age for work in Madagascar (15 years).

Also, international purchasers expect their suppliers to adhere to employment practices as stated in its Global Supplier Code of Conduct related to: child labor; forced labor, slave labor, and human trafficking; working hours and wages; compensation; non-discrimination; and workplace conditions.

As outlined in ESAP #3, Biovanilla will develop and implement an internal audit system to assess, monitor, and mitigate risks of child and forced labor, and significant safety issues in its primary supply chain. This will translate in undertaking a mapping of the supply chain, including identification of suppliers/farmers, identification of the potential significant adverse risks and impacts associated with the supply chains (e.g. child labor), and priorization of suppliers by level of risks. Tracking of suppliers’ performance will be integrated into the overall management system. If child labor, forced labor or significant safety issues are identified the company will work with the suppliers to take corrective action. In the event that corrective action is not feasible the company will change to suppliers that are managing the risk of child labor, forced labor and safety issues adequately. Moreover contracts of vanilla collectors will be modified to include provisions against child labor below 18 years of age.

Energy efficiency and Greenhouse Gases (GHG)

For the office and packaging facilities, energy is provided by the national with back-up diesel generators.  Approximately two million kWh of electricity and 1,000 tons of diesel are consumed annually. Biovanilla owns light delivery trucks, and maintenance is not carried out on site. Annual GHG emissions of the operations are estimated at around 4,000 tons CO2 equivalent per year.

Water and Wastewater

Water at the packaging facilities comes from 2 boreholes (extraction rate estimated at 1m3/hour) and is used only for firefighting and sanitary (2 tanks of 3.5 m3). There is no process water and sanitary water are sent to a septic tank.

Wastes

Solid wastes generated by the company’s operations include empty cardboard boxes, plastic wrapping and wooden pallets. The latter is reused by the company. Plastics and cardboard are disposed to a local landfill by the company. The municipality does not provide any disposal facility for waste.

Community Health and Safety

Food safety is a key risk and Biovanilla does not currently have a Food Safety Management System. Biovanilla will assess options to address food safety risks and intends to acquire a steam sterilization system for vanilla in the next year.

Security Personnel

Security is provided by a private agency and a CCTV system. On site, there are 5 unarmed guards permanently stationed. Biovanilla will ensure that security service providers make reasonable inquiries into employment records and other available data, including any criminal record of individuals and will not employ any persons that have abused or violated human rights in the past.

Although all producers are currently located in agricultural areas and none are closed to protected areas, Madagascar is renowned for its high biodiversity and high degree of endemism, and agriculture is a driver of deforestation.

International clients recognize that the protection of biodiversity and conserving significant natural habitats is critically important to global terrestrial and aquatic ecosystems and to the company’s long-term business success. Where applicable, international clients expect agricultural suppliers to avoid any actions that lead to deforestation or degradation of wildlife habitat and freshwater systems, and to respect protected and high conservation areas as identified in the Ramsar List (wetlands) and the IUCN Category I-IV areas. This applies to both ongoing operations and potential new production areas.

An important proportion (40%) of Biovanilla’s production comes from Rainforest Alliance certified land, which contains biodiversity conservation provisions. To ensure that biodiversity is not likely to be impacted by any suppliers, the Company will ensure that for all plantations (i) it identifies where the supply is coming from and the habitat type of the area; (ii) provides for an ongoing review of the client’s primary supply chains; (iii) limits procurement to those suppliers that can demonstrate that they are not contributing to significant conversion of natural and/or critical habitats (this may be demonstrated by delivery of certified product, or progress towards verification or certification under a credible scheme in certain commodities and/or locations); and (iv) where possible, require actions to shift the client’s primary supply chain over time to suppliers that can demonstrate that they are not significantly adversely impacting these areas (ESAP #4).

Communities are not likely to be significantly affected due to this project. Going forward, as part of its ESMS, Biovanilla will develop and implement a procedure for external communications that includes methods to (i) receive and register external communications and complaints from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) adjust the management program, as appropriate.

Contact Person: Eric Sinikely Platine

Company Name: Biovanilla

Address: Rue du Commerce, Sambava, Madagascar

Email: eric@biovanilla.fr

Phone: 261-32-05-437-29