Kobo360 is is a tech-enabled long-haul B2B digital platform company. The only physical assets are office facilities which are leased commercially. There are no impacts of concern from company’s direct operations and associated with the following Performance Standards: PS3: Resource Efficiency and Pollution Prevention; PS4: Community Health, Safety and Security; PS5: Land Acquisition and Involuntary Resettlement; PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources. PS7: Indigenous People; PS8: Cultural Heritage.

 Kobo360 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 #1, the company will either hire or designate a qualified individual in the senior management of the company to review and align company’s policies and procedures with IFC Performance Standards, to ensure compliance with the same policies and procedures, IFC and regulatory requirements and to ensure consistency with good international industry practice for environmental, social, health and safety performance.

As a digital platform company that connects demand for cargo transportation services to suppliers of such services, the key stakeholders for the company are businesses that are participants in the Kobo360 platform, primarily cargo owners (demand for services), truck owners (supply of services), and drivers (employed by truck owners or self-employed). While Kobo360 has no direct employment contracts with drivers employed by truck owners on Kobo360's platform, the company’s management system (policies and procedures, as upgraded under ESAP Action #1) will ensure and monitor compliance by the drivers/transporters, and adopt Good International Industry Practice (GIIP). Truck owners are required contractually by Kobo to comply with applicable labor regulations for its drivers. As described in the ESAP Action #1, the company will develop and implement a Code of Conduct as part of a registration process for its truck owners. Existing contracts will be amended to include acceptance of the Code of Conduct. The company will also develop and implement a drivers/transporters review process to ensure that registered drivers/transporters on the Kobo360 platform comply with company policies and procedures as set forth in the Code of Conduct, with special emphasis on elimination of labor risks such as child and forced labor, payment of wages and overtime, working conditions, road safety, transport emergency, preventive maintenance of vehicles, use of security forces, and are not engaged in prohibited activities.

Kobo’s offices are in commercial office space that are compliant with local requirements for life and fire safety. Company employees are made aware during training of emergency response and relevant health and safety aspects. For contracted services, Kobo has formal procedures to verify compliance prior to signing of contracts, scope of which includes security and safety aspects of vehicles as well as those related to truck owners and drivers.

Currently, Kobo360 has 25 direct employees, and intends to potentially hire 15 more direct employees by December 2018. Indirectly, there are about 400 active drivers on the platform that work through the truck owners. Kobo360 pays the truck owners via the platform. Truck drivers are not employees of the company. Although the company does not yet have a formal human resources (HR) policy, employment and human resources practices at Kobo360 follow local labor laws. The company's Human Resources Associate is responsible for HR and personnel management issues. 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 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 like others in the same business in the country of operation. 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 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 #2, Kobo360 will develop and implement a human resources policy to ensure operational consistency with IFC Performance Standard 2 on Labor and Working Conditions for its own employees and its contractors. The policy will be included in employment contracts, and address working conditions, terms of employment, wages and benefits, rights and responsibilities of the employees, policies on grievance, non-discrimination, etc. Also, as described in ESAP Action #1, as part of the Code of Conduct, Kobo360 will conduct a review of applicable legal and contractual requirements to identify specific environment, health and safety (EHS) requirements (including but not limited to road safety, preventive maintenance of trucks and prevention of child and forced labor) which it is required to ensure implementation by the transporters. Based on the review, the company will develop an action plan which would describe any changes to be made in the current empanelment and trip monitoring processes to ensure compliance with these requirements and their implementation timelines. The company will include in its contracts with transporters, specific provisions that are responsive to IFC Performance Standard 2 on Labor and Working Conditions where applicable, considering materiality of Kobo360’s engagement in the underlying transportation and logistics business.

Kobo360 does defensive driver training (DDT) for drivers which is consistent with international standards and taken from the National Safety Council’s Defensive Driving course program. DDT is a set of driving skills that allows drivers to defend themselves against possible collisions caused by bad drivers, drunk drivers and poor weather.

No local community have been significantly affected by environmental risks or impacts from Kobo’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 Nigeria, 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 Kobo 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 #1, Kobo 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:

Obiora Ozor

Kobo360 Inc

Chief Executive Officer/Co-Founder

22 Ikorodu Road, Jibowu Yaba

Lagos, Nigeria

Tel: 0818 678 0000

Email: info@kobo360.com