Grainpulse Head Office and coffee processing plant is located in Bugolobi in Kampala within the city and the site in Mukono is along the main highway Kampala – Busia on land that was previously used for subsistence farming. PS5: Land Acquisition and Involuntary Resettlement is not applicable as the project sites were acquired on willing buyer – willing seller basis and there has been no physical or economic displacement of people at both locations. Supply chain requirements in PS6 Biodiversity Conservation and Sustainable Management of Living Resources apply to Grainpulse. The specific geographic location of all suppliers and farmers for coffee is in the south eastern and south western regions of Uganda on modified habitat with no issues related to impacts to natural nor critical habitat. PS7: Indigenous Peoples and PS8: Cultural Heritage do not apply because the project will not cause any impacts on indigenous people and the presence of cultural artifacts is unlikely.

    There are no major adverse environmental or social impacts expected to result from the project and it is possible to avoid or mitigate any limited adverse impacts that may result by adhering to generally recognized performance standards, guidelines or design criteria. Hence, the project has been classified as Category B according to IFC’s Policy on Environmental and Social Sustainability.

The key environmental, social, health and safety risks associated with this project include: (i) development and implementation of the Company’s E&S management system - specifically organizational and technical capacity to effectively screen for and manage E&S risks in their operations; (ii) HR policies and procedures, working conditions, and occupational health and safety management procedures; (iii) resource (water and energy) consumption and management; (iv) dust management; and, (v) the Company’s supply chain risk management system for sourcing coffee and grains from suppliers.  

   Environmental and Social Assessment, Policy and Management System

Grainpulse is in the process of developing E&S policies and procedures. The company has completed the development of Hazard Analysis and Critical Control Points (HACCP) documentation for the grain processing operations and await certification. The company is developing documentation for compliance with ISO 22000, Food Safety Management System (FSMS) and an associated quality management system. The company shall implement an integrated Environmental and Social Management System (ESMS) at the processing facilities based on the FSMS ISO 22000 standard, consistent with the ISO 14001 (environmental management) standard, ISO 45000 (occupational health and safety) standard, the national laws in Uganda, and compliant with IFC’s PS1 requirements (ESAP 1). Specifically, the integrated ESMS will include (i) integrated EHS policy (ii) OHS procedures for field-based staff and agronomists (iii) procedures for stakeholder engagement (iv) procedures for tracking and managing key environmental and social performance indicators such as energy consumption, GHG emission from operations etc; (v) procedures for supply chain management.

Management Programs

As part of the FSMS documentation, the company has developed management programs to support its implementation. These include workplace hazard identification, risk assessment and control program, occupational health and safety program, contractor safety management, lockout-tagout-tryout (LOTOTO) program, working at heights, confined space entry, pest control, laboratory quality program, equipment calibration, waste management and emergency response plans.  Implementation is verified on a regular basis through an internal and external audit processes to identify non-compliances with procedures and develop corrective actions for follow up. Grainpulse will adopt the management programs at each of its new facilities going forward

Organizational Capacity and Competency

Grainpulse has established an organizational structure to handle environmental and social issues, which will include the chief executive officer (CEO), factory manager (FM), and the environmental, health and safety (EHS) manager. The chief executive officer shall have the overall authority for operational and EHS matters and take decisions on staffing and budget allocation. The factory manager(s) will be the designated Food Safety Management Team Leader. In compliance with IFC PS1, the company will appoint a qualified EHS Manager (ESAP 2) at corporate level. The EHS manager will be supported on day-to-day management of environmental, health and safety performance and implementation of the integrated ESMS by the factory manager, shift supervisors, human resources manager and quality assurance officers, as part of their responsibilities.

The company is developing a training plan for staff which addresses all the aspects included under the different certification schemes. The plan shall be made available to all employees depending on their job description and will include the following; statutory First Aid, fire safety training, occupational health and safety training, accident and incident reporting, personal protective equipment (PPE) usage, implementation of LOTOTO procedures, principles of food hygiene and Food Safety - Critical Control Point monitoring, among others. The implementation of the training plan will be monitored annually and reported in the Annual Monitoring Report (AMR). Additional topics in the training plan will be included to address all E&S risks and impacts associated with the operations.

Emergency Preparedness and Response

Grainpulse has recently developed an Emergency Preparedness and Response Plan (EPRP) to respond to accidental and emergency situations associated with the company operations. The EPRP identifies fire risk and oil/chemical spillage as the key risks in their operations. Grainpulse indicated that annual fire safety audits will be done to update the risk register. The EPRP has the following procedures; emergency drills (twice a year); communication during an emergency; evacuation plans and muster points for the two facilities; handling emergencies; handling injuries of personnel during an emergency; reporting and emergency equipment monitoring and inspection. Grainpulse will appoint emergency response team (ERT) members, train the ERT and staff to operationalize the EPRP.

Monitoring and Review

Monitoring and review of operational/ production performance are done in a formal and informal manner. Internal audits are carried out in accordance with the internal audit and inspection procedures developed by the company. External audits are done routinely in compliance with regulatory and customers’ requirements.

Formal management review of the management system is to be done periodically according to FSMS procedures. The review considers, among others, findings from the management system audits, customer complaints, status of corrective actions, status of preventive actions and follow up actions from previous management review. This shall include discussions of EHS related issues.

   Human Resources Policies and Procedures

Uganda has ratified all eight ILO Conventions related to Freedom of Association, Forced Labor, Equal Remuneration, Discrimination and Child Labor. The Employment Act in Uganda recognizes the worker’s rights to form and join worker’s organizations of their choosing without interference and to bargain collectively. The national law also has provisions for equal opportunity and non-discrimination of workers.

Grainpulse has developed and implements a Human Resources (HR) Policy and procedures manual generally aligned to national legislation. The company will revise the Human Resources (HR) policy and procedures manual in accordance with both the national law and IFC PS 2 requirements (ESAP 3). The HR policy and procedures will include clear procedures related to contractual arrangements for temporary, seasonal, casual workers; workers’ organizations, anonymous grievance mechanism, compliance with new minimum wage law and conditions for workers engaged by third parties. 

Working Conditions and Terms of Employment

At appraisal, Grainpulse had 81 employees, of these, 20 (25%) female and 61 (75%) male. Permanent employees sign a contract with the company at the time of employment. The contract describes the role or function of the employee, working conditions and terms of employment. The employees are provided all statutory benefits due to them including medical insurance cover, social security fund as per local laws and pension. The working hours and overtime for non-management staff are based on the national legislation. All employees are entitled to annual leave, sick leave and compassionate leave. Female employees are entitled to paid maternity leave of 60 working days.

Grainpulse also engages temporary or casual workers ranging from 70-90 workers depending on seasonal demands to support operations such as unloading of trucks or movement of bags of produce. The company does not have systematic or formal policies or procedures, no defined wages or overtime payments and no systems for monitoring this category of workers. In line with ESAP 4, the company will develop and implement policies and procedures to include specific provisions in contracts for temporary, contract and daily wage workers, including payment of wages, overtime payment and other applicable benefits. The company will also establish a procedure to monitor the compliance with applicable labor laws with respect to such temporary, contract and daily wage workers.

Workers Organizations

Although there are no unions in the coffee and grains sector in Uganda, the company is in the process of revising the HR Manual (ESAP 3) to include a statement or clause that recognizes workers’ rights to form and to join workers’ organizations of their choosing without interference and to bargain collectively in accordance with national legislation.

Non-discrimination and Equal Opportunity

The company is an equal opportunity employer as elucidated in the HR manual. The manual explicitly states that access to jobs is based strictly on an individual’s competencies for the job. The principle of equal opportunity in the policy applies to every aspect of employment including recruitment, hiring, training, promotion, discipline and termination. The Company does not discriminate against any applicant because of their gender, ethnicity, race, culture or religion. In addition, sexual harassment is not tolerated by the company and a sexual harassment policy is in place.

Grievance mechanism

Grainpulse has a grievance handling policy as part of the HR manual and supports the right of every employee to lodge a grievance formally or informally to their direct supervisor, departmental head or the human resources manager. According to the policy, grievances must be handled objectively, discreetly and promptly. According to ESAP 5, the policy will be revised to allow for anonymous complaints to be raised by workers and addressed by management and may include for example, provision of suggestion boxes at strategic locations at the workplace. The grievance mechanism will be extended to the temporary and casual workers on site as well as workers contracted by third parties and providing services on site.

Protecting the Work Force

Grainpulse’s HR policy manual provide a clear eligibility criterion for employment which is for persons above the age of 18 with requisite qualifications and competencies. The company policies prohibit forced labor.

Occupational Health and Safety

Grainpulse’s operations pose some OHS risks to workers and the company has developed management programs outlined under PS1. The company’s OHS policy, which covers all workers, identifies potential hazards and risks in the coffee and grain processing plants and provides mitigation and protective measures for each hazard. These include hazards from falling and rolling objects; cuts and punctures; slips, trips and falls on slippery or wet surfaces; lifting; repetitive work; posture injuries, explosion in the grain silos and risks of fire. For field-based staff, potential risks are related to transportation, insect and snake bites, and walking on uneven terrain and associated injuries. Over the past 3 years, there has only been one recorded accident in the company operations. In compliance with the national legislation requirements, the company maintains a General Accident Register and has developed procedures for handling and reporting accident and incidents at the workplace. The company ensures that both grain and coffee processing areas are properly ventilated, maintained free of dust by following routine cleaning schedules.

Supply Chain

According to the US Department of Labor, Uganda has ratified most of the key international conventions concerning child labor. The government has established laws and regulations related to child labor. However, gaps exist in Uganda’s legal framework to adequately protect children from the worst forms of child labor, including the minimum age for work, which is established as 16 years and a low compulsory education age of 13 years.

Grainpulse does not have any supplier contracts with farmers but applies ethical trading practices as per SEDEX guidelines (SEDEX is a global membership organization that promotes responsible supply chains). The company sources its key trade inputs; coffee, grains and pulses from local farmers through aggregators, traders, commercial farmers, small scale farmers and farmer co-operatives or associations. Fertilizer is supplied amongst others by K+S AG. Food fortification premixes are procured through tenders with registered suppliers, mainly suppliers linked to the Global Alliance for Improved Nutrition. The company continuously engages with the farming community through their agronomists, agents, aggregators and sub agents. The ownership title of the coffee, grain or pulse is only passed to Grainpulse after delivery and quality approvals at the factory. If a consignment does not meet the required quality approvals, the supplier is provided with a rejection note at the factory gate.

As part of its evolving supply chain strategy, Grainpulse plans to have remote aggregation centers either mobile or static installations. In addition, the company plans to cascade the SEDEX practices instituted by their customers in the grain business to assure the social performance of their supply chain. To address potential risks in the primary supply chain as the demand for coffee and grain increases, the company will develop and implement a supplier code (ESAP 6) to ensure that children under the age 18 will not be involved or employed in hazardous work and that the suppliers will comply with the applicable laws and regulations relating to the protection of the environment.

  Resource Efficiency

Grainpulse undertakes periodic energy audits. As a result of the energy audits, the company has installed new motors, dryers, graders and pre-cleaners that are more efficient and consume less energy. In addition, through the agronomists and extension officers the company has conducted training for farmers on post-harvest handling and drying of coffee and grains. The company has instituted incentives to suppliers who deliver properly dried and handled coffee and grains.

Power is sourced from the national grid through a 500kV transformer. The coffee and grain facilities each have a 500kV standby generator and the fertilizer facility has a 250kV standby generator for back up in-case of power outage. The average power consumption is 55kwh/ton of maize. The company has installed solar panels for office and security lighting at the Mukono factory with plans to do the same at the Bugolobi plant.

Air emissions and Greenhouse Gases

Air emissions from the plants is mainly spent air from the driers. Dust from the conveyors and/or elevators is managed through the cyclones and collected in bins.

GHG emissions from the Grainpulse facilities are limited to the indirect emissions caused by the electricity used at the facilities.  The company does not own any transport logistics fleet as this is outsourced to third parties whenever required and most instances clients off take products from the factory using their own transport. Fertilizers are not produced at the facilities rather, the different components are imported and blended at the fertilizer blending plant. At project completion, Grainpulse will have an estimated fertilizer production of nearly 20,000 metric tonnes per year. This will result in a preliminary estimated total GHG emissions of approximately 62,300 tons/year, as CO2 equivalent.

Water Supply and Wastewater

The processing plants get treated water from the national water utility company and further purifies it through filtration and UV exposure to eliminate microbes before use. The average water usage in the processing plants is 0.15litre/kg. The company also has a borehole at Mukono. The water from the borehole is used for general cleaning and irrigation of the demonstration plots used for farmers’ training. There is no process wastewater generated by the plants. Sanitary wastewater for the Bugolobi plant is discharged through the city sewerage system whereas the Mukono plant is discharged into septic tanks.

Solid Waste Management

Grainpulse uses limited packaging material in its operations. Grain and fertilizer storage bags are re-used. Most of the imported fertilizer inputs is handled in bulk. Export of coffee and grain is done in bulk and/or Jute bags. Minimal waste is generated by the pre-cleaners and this includes; broken or shriveled grain which is collected and used as raw material in the feed mill or sold to the market for animal feed production. Broken coffee beans are sold locally to the coffee roasters and the coffee husks are sold to industries that have furnace. Small stones discarded from the de-stoner is used in the facility gardens. Broken glass, metallic items, office waste and spent fumigants are disposed through a contracted waste collection contract.

Pesticides Use and Management

Fumigation is outsourced to a local subsidiary of an internationally accredited pest control company. The pest control and management procedure consistent with the WBG General EHS Guidelines is under development and will be implemented as part of the ESMS including the list of appropriate food grade fumigants to be used and schedule of application.

   Community Health and Safety

Grainpulse is developing company policies and procedures, that will ensure that all products are quality tested in an on-site laboratory. When coffee or grains arrive at the factory, they are not immediately cleared for entry until random samples are taken from each lot or consignment and tested for aflatoxin, foreign matter, pests and moisture content. Samples which do not meet the required specifications are rejected at the factory gate.

The company plans to apply HACCP systems for the grains and nutrition pillars of the business. HACCP is a preventative food safety system in which every step in the manufacture, storage and distribution of a food product is scientifically analyzed for microbiological, physical and chemical hazards. Hygienic practices are enforced throughout the factory. Employees working directly with grains, coffee beans or nutrition products in the factory are trained in food safety issues and follow established procedures for hand washing, working attire (clothes, shoes, gloves and hair coverage), and how to handle injuries and diseases. The relevant government departments that are associated with matters of health and labor undertake regular inspections to assess food handling procedures, certification of food handlers and to test if product quality meets legal requirements. As part of the ISO 22000 management system, a procedure will be developed for product coding and traceability for the nutrition products. Some of the company’s key clients who are SEDEX members such as Diageo audit the gains and nutrition plant on a regular basis. 

Security Personnel

Grainpulse has two sets of security personnel – internal and external. Internal security personnel, a total of six staff of Grainpulse (three at each facility per shift), perform inspection of documentation and maintain logs of deliveries and dispatches. External security is outsourced to a private security company who deploy armed security personnel, four guards at (two guards per shift per facility) each facility to guard the gates and conduct surveillance around the premises. In line with ESAP 7 and following the provisions of the Security Guarding Contract, the company will assess risks posed by its security arrangements to those within and outside the project site and develop a Security Policy and a Security Management Plan (SMP), including a training module for management and security personnel. This SMP shall be aligned with the Voluntary Principles on Security and Human Rights and with the requirements of Performance Standard 4.

   Supply Chain

Arabica coffee in Uganda is produced at high altitudes (over 1,500 m above sea level) in the Mount Elgon areas in the East, the Highland areas of Nebbi in the North and the mountainous areas of amongst others Kisoro, Kasese and Rukungiri in the Southwest. Robusta coffee is grown around the Lake Victoria basin and they account for about 85 % of Uganda’s total annual production.

Grainpulse’s agronomy and extension team conducts seasonal training to selected lead farmers (training of trainers) in different regions and provide pocket books and information materials to the trainees. Training includes land preparation techniques, seed application, fertilizer application, pest control, crop quality assurance and post-harvest handling. The company is considering trading in certified coffee and is planning on developing procedures as part of the ESMS (ESAP 1). For both coffee and grain business, as per ESAP 6, the company will develop a supplier code to address the potential risks of child labour and risk of conversion of natural or critical habitats.

   The company does not have a formal stakeholder engagement plan but tends to hold quarterly informal meeting with local area leadership in Mukono and Bugolobi; semi-annual engagement with farmers at the field jointly with Uganda Breweries Limited (UBL); semi-annual meeting at the Mukono plant with the key customers in grains supply and trading; is cooperating with AGRA on blended fertilizers; meetings with regulators and annual meetings for coffee traders and aggregators.

The company, in line with the ESAP 8, will develop a Stakeholder Engagement Plan (SEP) that identify key stakeholders and provides a procedure for external communication. The SEP will include a community grievance redress mechanism (GRM) to address any concerns that stakeholders may have. The main objective of the GRM will be to provide a mechanism to mediate concerns. The SEP will be reviewed periodically during implementation and will be updated as necessary to ensure effective ongoing engagement with stakeholders. Appropriate channels will be used to inform the stakeholders of project issues and will be part of the SEP.

   Contact Person: Hannington Karuhanga

Company Name: Grainpulse Ltd

Address:  Plot 6/8 Nyondo Close, Industrial Area, Bugolobi, Kampala

Email: hk@grainpulse.co.ug and info@grainpulse.co.ug

Phone: +256392174758