Based on the available information, the Project does not or will not have an impact on Indigenous Peoples (IPs); therefore PS7: Indigenous Peoples is not applicable. Impacts linked to PS8: Cultural Heritage are not expected since there is no presence of known cultural assets or artifacts within the company’s current operational footprint. Averda will assess and manage any issues related to PS8, as needed, as part of its Environment and Social Management System (ESMS).

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012) as the project is expected to have limited adverse environmental and social risks and impacts that are few in number, short-term and site-specific, and can be avoided or mitigated by adhering to recognized performance standards, good international industry practice (GIIP) procedures, guidelines and design criteria as described in the following sections.

Key E&S risks and issues associated with the project are: i) further development and implementation of the company’s E&S systems at the corporate and site level and associated organizational capacity, in compliance with IFC Performance Standards (PSs) and according to GIIP, including applicable and relevant World Bank Group (WBG) EHS Guidelines; ii) E&S risk screening and assessment during early project identification and development; iii) systematically undertaking E&S due diligence assessments, including legacy issues, such as historical pollution, prior to mergers, acquisitions and/or taking operational ownership of an concession/asset; iv) assurance of fair, safe and healthy working conditions for workers and contractors alike and in compliance with PS2; v) community health and safety; vi) land acquisition for the proposed facilities and mitigation of associated social impacts in line with IFC PS5; and vii) stakeholder engagement and grievance management.                                                  

 Environmental and Social Assessment and Management System and Policy: Averda operates under a Group level Integrated Management System (IMS) that combines Quality, Health, Safety and Environmental (QHSE elements). The company’s IMS is underpinned by several policies (Occupational Health and Safety, Environmental, Human Rights, Management System, Risk Management, Asset Management and Complaints Management) and a Group QHSE manual. A periodical review of the policies effectiveness, applicability and implementation is undertaken across the different countries of operations. At most countries of operation Averda holds ISO 9001:2015 (Quality Management), ISO 14001:2015 (Environmental Management) and/or ISO 45001:2018 (OHS Management) certifications. At two locations (Abu Dhabi and Al Ain) Averda is also targeting for ISO 39001 (Road Traffic Safety Management), ISO 31000 (Effective Risk Management), ISO 55001 (Asset Management) and ISO 10002 (Customer Satisfaction).

Averda corporate will update and align their E&S management system (policy, management programs, procedures, key performance indicators (KPI’s), etc.) with IFC PSs and implementation of GIIP per applicable WBG EHS Guidelines. Concurrently, all waste management facilities will align their QHSE documentation, consistent with the updated corporate E&S management systems, and supplement them with national requirements where this are more stringent. The gaps relevant to PS1, identified as part of the ESDD undertaken, are highlighted throughout this section and will be addressed as per ESAP #1. Averda organization will also be reviewed to support ESAP closure and meet compliance with IFC’s PSs under the proposed investment.

Identification of Risks and Impacts: All countries visited (except India) operate under a QHSE Policy which requires identifying health, safety and environmental hazards/aspects arising from activities and reducing risks and impacts to the lowest practical levels. The IMS also includes a Risk Management Policy which states that risk management is an integral part of decision making and operational planning processes and requires risk assessments to be carried out for all new ventures and activities. The identification of environmental and social risks and impacts are mainly driven by legal (EIA/ESIA) or ISO certification requirements. An Aspects and Impacts Register is maintained at most operations.

IFC’s review identified that, at Makoula and Lifoula landfills in Congo and the waste transfer stations in Congo and Morocco, Averda had commenced construction, taken over a concession or commenced operations without a completed and/or approved ESIA in place. In those locations, the company has secured permission from the authorities for the waste facilities to be developed and operated, on the understanding that an ESIA is undertaken in parallel and the ESIA recommendations are implemented. The ESIAs are expected to be completed in 2022. Averda will prioritize ESIA completion and implementation at the locations where the company commenced operations without a completed ESIA in place and will supplement the ESIAs to align with IFC PSs, where necessary. At all other sites, aspects and impacts registers will reviewed and updated in compliance with IFC PSs and according to GIIP, including applicable World Bank Group (WBG) EHS Guidelines (ESAP #1).

Under the proposed investment, Averda will develop and implement a systematic approach to identify environmental and social risks and impacts which will be integrated in the company’s corporate ESMS, including: i) developing an E&S procedure to screen and categorize sites for land, biodiversity, social and cultural heritage sensitivities during early project development; ii) undertaking environmental, social (including presence of informal waste pickers) and land due diligence assessments prior to merger, acquisitions and/or taking ownership of sites or concessions and develop management measures (e.g., for livelihoods restoration and community development) to address key issues identified (e.g., where there is a potential for historical pollution such as land and groundwater contamination, undertake an investigation and assessment in accordance with GIIP, per Section 1.8 of the WBG General EHS Guidelines, and factor clean-up, remedial and closure costs); iii) establishing an environmental and social baseline for future monitoring, prior to starting operations or taking over operation of a newly constructed or operational third-party waste facility; iv) developing an ESIA and E&S management plans (ESMPs) specification, to ensure such studies are developed consistent with IFC’s PSs and prior to the establishment of a new facility; and v) developing a chance finds procedure, to be implemented in the event cultural heritage is discovered when undertaking earth movement operations (ESAP #1).

Management Programs: Averda has a defined “Mission Zero” aspiration for the prevention of incidents and elimination of risks at the workplace. To support this mission, Averda has developed QHSE manuals that constitute the umbrella document supported by Operating Procedures; Working Instruction and Guidelines; and Documented Reports, Forms and Standards. QHSE manuals are available at most countries of operation and/or operational assets. The QHSE Manual consists of 21 elements that shape the requirements and expectations to be met. Whilst the 21 elements that conform the QHSE manual are comprehensive, management programs and procedures to support the environmental and social components need to be fully developed and completed. Averda will develop a suite of environmental and social minimum specifications at the corporate level, to ensure standardization for the design, construction, operation and environmental monitoring of all their waste facilities across all countries of operations. Averda will develop a corporate annual Health, Safety, Security, Environment and Quality (HSSEQ) audit plan/schedule (internal and external) and perform corporate led audits for all operational sites, including an assessment of compliance with IFC PSs. Going forward, consistently monitor compliance to IFC PSs and applicable WBG EHS Guidelines, at all existent and future operational facilities (ESAP #1).

Organizational Capacity and Competency: Averda has a Group HSSEQ organizational structure led by a Vice President (VP) HSSEQ. The HSSEQ VP is ultimately responsible for managing corporate IMS across the Company. This is supplemented by a HSSEQ Manager responsible for the implementation of the systems and procedures in each country of operation. Depending on the number and complexity of the operations in each country, the HSSEQ Manager is supported by a number of HSSEQ representatives (Officers) assigned to the different facilities. At a Group level Averda also has a Global Head of Environment and an Environmental and Landfill Specialist.

The ratio of HSSEQ personnel per number of workers varies considerably dependent on the country of operation, with some countries having considerably lower ratios than others. Averda will assess and reinforce the HSSEQ organization to align with GIIP requirements. In the meantime, and as a matter of priority, their HSSEQ team in Morocco will be reinforced with a senior dedicated HSSEQ Supervisor for the Tangier Development (ESAP #1).

Emergency Preparedness and Response: Averda Safety Plan includes a system of classification of emergencies, identifies emergency response teams, has a warden system in place and is able to track and report on emergencies. For road related transportation emergencies, this can also be done at the Group level through a cloud-based software application system. The HSSEQ Committee at country level also ensures that the emergency response protocols are implemented at each project site and in the event of a major incident. Fatalities are investigated, with root causes identified and presented to corporate management, for lessons learned and corrective actions to be cascaded throughout the organization. At the Group level the following emergency management plans are included in the IMS: Handling and Disposal Chemical, Oil Spill and Asbestos Spillage; Fire; Medical; and Vehicle Accident. These plans are adequately structured, define roles and responsibilities, identify risks, and include emergency response activities for different risk scenarios. As most of the documents are now over four years old, the company will update and revise them to reflect the current company’s operations, including landfill fire and explosion risks. During the site visits it was also observed that the consistency, level of detail and implementation of the corporate level emergency response plans differ from one country to the other.

Averda will update their Group Emergency Response Plans (including landfill fire and explosion risks) and subsequentially their in-country Emergency Response Plans accordingly. Averda will extend the use of their software to also track and report on incidents like fires, security incidents, and loss of containment (ESAP #1).

Monitoring and Review: Implementation of the IMS and its management programs is closely monitored by means of a HSSEQ dashboard system at the corporate and country level. Averda undertakes periodical internal and external monitoring and auditing of its IMS in accordance with ISO standards, both at the Group and country level.

Averda has established several mechanisms to monitor and review the effectiveness of its management system, including: Sustainability and Safety Committee at the Board level; Monthly Country Reviews at the Group management level; Weekly Global Delivery calls at the VP Level (e.g., HSSEQ VP); and HSSEQ committees at the country level, that meet on a periodic basis to review performance. As indicated, the company utilizes a cloud-based software for HSSEQ monitoring, action tracking and reporting, including OHS KPIs such as near misses, high-risk activities, safety training ratios (leading indicators) as well as fatalities, lost time incidents, RTA’s, injury trends (lagging indicators), which feed into a KPI dashboard used for the HSSEQ reviews. Although Averda has also established some environmental KPI’s like monthly energy consumption, emissions reporting, (leading indicators), and environmental incidents and timely closure (lagging indicators), these are still to be implemented and reported upon. Similarly, environmental monitoring at Averda’s waste management facilities (e.g., ambient air quality, noise, light, groundwater, leachate at landfills, landfill gas and other emissions) varies by country of operation (e.g., undertaken in Oman, South Africa but not in Congo and Morocco -Tangier).

As part of ESAP #1, Averda will update their E&S KPIs once they have aligned their E&S management practices with IFC PSs and applicable WBG EHS Guidelines and ensure that E&S performance is captured by their dashboard and included in the periodic management reviews.

Averda will design, construct, and operate the circular economy selected projects that will be financed by IFC, in compliance with IFC PSs, and aligned with GIIP such as the applicable and relevant WBG EHS Guidelines. Risk and impacts will be assessed as part of the project ESIAs, where these are required, or through focused E&S assessments (ESAP #1).

Waste Pickers: The Genesis landfill in South Africa has an active community of waste pickers. Based on the IFC review, waste pickers have operated at the site for around 20 years. In 2011, the company that managed the landfill at the time allowed waste pickers to access and work at the site on a controlled basis. Averda took over the site in 2016 and in June 2018, in response to an influx of waste pickers at the site and increasing threats of violence towards staff, the company served a court order to stop unauthorized site access. The waste pickers were subsequently evicted by a private company and in the process a number of them were injured and hospitalised and their belongings lost or destroyed. Since then, there have been a number of violent altercations between the rival groups of waste pickers and more threats of violence against Averda staff. In 2019, a group of 32 waste pickers successfully contested the court order. Following the conclusion of the legal process, Averda engaged with and offered full time employment to this group of waste pickers. However, during the consultation process, a much larger group became involved, and the offer was rejected on the basis that 32 jobs were not sufficient. Estimates of active pickers who continue to work at the site vary and makeup a number of ill-defined groups. Whilst Averda currently does not impede access to the site for the waste pickers, it has not been able to find a sustainable solution to address the issue as yet. Averda will engage with an appropriate entity (such as representative waste picker civil society organizations) in South Africa to assist in i) undertaking a social assessment to identify and enumerate waste pickers/groups operating at the site, understand the history of their presence at the site, establish a socio-economic baseline (including livelihood dependencies), identify any issues and grievances, and develop a Livelihood Restoration Framework; and, ii) brokering a dialogue with the relevant groups to address grievances and find viable ways to integrate them into the formal solid waste management system in a safe and secure manner. Should access to the site be restricted and the waste pickers are economically displaced, the company will develop and implement a Livelihood Restoration Plan in line with IFC PS 5 requirements, as specified in ESAP #1, with the objective of restoring livelihoods (ESAP #1).

 As of December 2021, Averda has 14,129 direct, permanent or fixed term employees across all its operations. These include management, professional, administrative and frontline (i.e., those working directly with waste) employees. In the UAE, Oman, KSA, and Qatar, frontline staff are all expatriate workers (mostly male) from South Asia. During IFC’s review, centrally collected data on the gender breakdown of the workforce was not yet in place. The development and operations of the circular economy projects will employ additional staff during construction and operation, the numbers of which are not yet known.

Human Resource (HR) Policies and Procedures: Averda has a comprehensive set of Group Human Resources (HR) policies and procedures including Human Rights, Code of Conduct, Frontline Recruitment, Onboarding, Training, Learning & Development, Performance Management, Disciplinary Management, Grievance Management, and Separation Management. Averda has also formally committed to United Nations Global Compact (UNGC) which consists of 10 principles on human rights, labor, environment and anti-corruption. Averda Group policies and procedures are applicable to all Averda employees (both frontline and office based) and communicated during employee onboarding. Averda will establish a separate Sexual Harassment policy and update the Disciplinary Management procedures to account for this policy and an Expatriate Worker policy. All key HR documentation (including HR policies and procedures and the Labor Grievance Mechanism) will be communicated to employees at onboarding and refresher sensitization sessions and made easily accessible (such as being displayed in areas where workers biometrically sign-in as well as at accommodation facilities) (ESAP #2).

A Group HR Manager based in UAE oversees the development and implementation of Group HR policies and procedures. This is supplemented by a HR and Line Managers team responsible for the implementation of national legal requirements and relevant group policies, in each country of operation. The strength and capacity of the HR team at Averda is sufficient for the size and nature of Averda operations.

Working Conditions and Terms of Employment: All Averda employees including expatriate workers and those employed by third-party agencies are required to have written contracts or agreements that state the contract type and duration, wages and benefits, hours of work, overtime, breaks, leave, etc. Specific parameters of working conditions and terms and condition of employment are set by local laws in each country of operation. The lowest level of basic wage at Averda subsidiaries is aligned to the statutory minimum where this is applicable. Wages are reviewed annually based on performance and inflation. The remuneration and benefits package of expatriate workers also includes health care, accommodation, meals, and annual travel home to see their families. Whilst not a Group wide policy, Averda imposes fines related to a schedule of defined disciplinary violations as allowed by the law in the UAE, KSA, Qatar and Oman. Although such fines should not exceed five days of wages for a single violation, a monthly cap is not set in law. Averda will review and update its disciplinary procedures to be more incentive based linked to individual performance as opposed to fines based on disciplinary violations (ESAP #2).

Expatriate workers are housed in a number of accommodation facilities that are either owned and operated by external contractors or by Averda. Based on the ESDD site visit to accommodation facilities in Abu Dhabi and Oman (latter a virtual tour), whilst the quality of accommodation and provision of basic services were generally observed to be good, a number of concerns related to adequacy of floor space, storage and privacy were noted. Averda does not yet have an Accommodation Policy in place. Facilities are generally built, in accordance with local requirements (where these exist). Averda will develop a Group Accommodation Policy that defines the minimum standards on quality and management of accommodation and provision of basic services in line with the IFC/EBRD Guidance Note on Workers Accommodation: Process and Standards, conduct a gap analysis of all Averda worker accommodation to identify shortfalls and, implement appropriate improvement measures (ESAP #2).

Workers Organizations: Averda recognizes the rights of freedom of association and collective bargaining, subject to local laws in each country of operation. Rights of expatriate workers to join or form a union in the UAE, Oman, Qatar and KSA are limited or restricted by local laws. Averda will develop a separate freedom of association and collective bargaining policy that includes alternative mechanisms (for countries with legal restrictions on freedom of association) for representation, expressing grievances, and protecting workers rights, in line with PS2 requirements (ESAP #2).

Non-Discrimination and Equal Opportunity: Averda has a Group level Diversity and Inclusion policy that sets out the company’s commitments on diversity, inclusion and non-discrimination. This is elaborated further within the Human Rights policy with a statement promoting inclusion of all people and not discriminating against any gender, race colour, religion, national or social origin.

Retrenchment: Averda has a Group policy and procedure on Separation Management/ Off-boarding that makes provisions on retrenchment in line with PS 2 requirements. In 2020, Averda, undertook retrenchment of some employees in South Africa as a result of the closure of two units and the completion of a contract. There has been no retrenchment undertaken to date as a result of the COVID-19 pandemic.

Labor Grievance Mechanism: Averda has a Group Grievance Management policy and procedure applicable to all Averda employees. The policy defines the type of grievances that could be lodged and provides a structured process for timely grievance management. The application of the Group policy and procedure and the level of worker awareness of it differs by country of operation. The policy at present does not allow for anonymous complaints to be raised and addressed and grievance registers have not been sighted for any subsidiaries. Averda will update its Group Grievance Management policy and procedure in line with IFC PS2 requirements and implement this at all sites including accommodation facilities. Averda will also appoint dedicated personnel at each site to manage labor related grievances and issues. The procedure will allow for anonymous filing of grievances, to be accessible to all Averda employees and workers employed by third parties and actively disclosed as part of onboarding as well as refresher training (ESAP #2).

Protecting the Workforce: Although Averda has formally committed to the UNGC, a separate policy on Child Labor and Forced Labor does not yet exist. Minimum age requirements are set by local laws and vary by country of operations. No instances of child or forced labor were identified as part of the ESDD. Averda will develop a policy on Child Labor (with a Group level minimum age) and Forced Labor, in line with PS2 requirements (ESAP #2).

Occupational Health and Safety (OHS): The identification of occupational health and safety risks and impacts is well developed with a high level of management commitment and a strong safety culture to avoid and/or minimize OHS incidents. Averda has a clearly defined “Stop Work Policy” and a “Mission Zero” aspiration for the prevention of incidents and elimination of risks at the workplace. Nevertheless, serious accidents including several fatalities are still occurring. As noted under PS1, a contributing factor could be the ratio of HSSEQ personnel per number of workers. This varies considerably in the eight countries of operation, that may in turn impact, the consistent implementation of OHS procedures across the different countries where Averda operates. As an example, at the Tangier landfill in Morocco, control of work was observed to be insufficient. Similarly, 24-hour operations undertaken at the Averda operated landfills in Congo, requires to be assessed, to ensure appropriate control measures are in place. As per ESAP #1, Averda will assess and reinforce the HSSEQ organization to align with GIIP. In addition, Averda will undertake a corporate OHS audits to all its facilities with priority given to countries of operation where fatalities occurred and where the ratio of HSSEQ personnel to workers is the highest.

Given the nature of company’s activities, a high proportion of their OHS risks relates to road traffic hazards and accidents, given the nearly 3700 fleet of vehicles that company owns and operates and due to the considerable challenge of Control of Work, where there is an interaction with third parties, beyond the boundaries of their worksites. Averda OHS management commitment is also supported by safe operating procedures; behavioural based programs to enhance company OHS culture; measures for safe truck driving to minimise traffic safety risks including reverse cameras and blind spot management of trucks and equipment; fleet management; driver training; route risk assessments; medical check-ups; breathalysers; etc. Averda also constantly seeks innovative technologies to minimize risks and impacts via pilot projects like on-board cameras to monitor fatigue in drivers, automated fire suppression in some heavy equipment, installation of a cross arm at the front of their trucks (to avoid pedestrians walking into blind spots), etc. Averda has developed a training program based on matrices that cover all aspects of HSSEQ for employees and key contractors. Averda HSSEQ training and issuance of Personal Protective Equipment (PPE) makes no distinction between direct employees and workforce supplied by third parties. Averda policies also allow for a midday break during the summer months to protect workers against the heat where relevant.

Averda has digitized their fleet with in-vehicle real time GPS monitoring systems. As indicated, Averda also utilizes a cloud-based software for HSSEQ monitoring and reporting. This allows tracking of employee and fleet safety. It includes KPIs for both leading and lagging indicators and action tracking system for reporting, which are all centrally monitored in their data hub in Dubai, for all countries of operation. This system allows to track all company waste cleaning and transportation operations, routes driven, unsafe acts (speed limit exceedances), unsafe conditions and to identify opportunities to increase efficiencies and drive continuous improvement, in real time. Averda utilizes country level and corporate level HSSEQ dashboards to review their KPIs on a weekly and monthly basis.

The risks related to COVID-19 pandemic are well managed with a COVID-19 corporate response team which was established at the beginning of the pandemic to closely monitor cases across the workforce, and to ensure mitigation measures are in place, including raising awareness and a vaccination program.

Workers engaged by Third Parties: In a number of countries, Averda engages with third-party contractors or labor agencies to provide services or temporary workers. All such third-party entities are required to go through a robust procurement process based on Averda’s Vendor Procurement policy and procedure, which includes an assessment of vendors legal status, labor and HSE capacities and documentation, prior to appointment. Averda will strengthen the procedure by developing a standard set of E&S conditions to be included in vendors contracts covering at minimum key Averda Labor and OHS policies (including terms and conditions of employment, minimum age, forced labor, Labor Grievance Mechanism, etc.,) as well as compliance with national laws. Averda will conduct regular internal audits and annual external audits to ensure compliance with these contractual requirements (ESAP #2).

Resource Efficiency: The main resources used by the company are: i) fuel consumption for city cleaning and waste collection, heavy equipment (landfill sites) and operation of incinerators; ii) electricity to support their various operational sites (waste transfer stations, landfill sites, incinerator sites, mechanic workshops, warehouses, offices and labor provided accommodation). Averda does not have an overarching policy or guideline requiring all their operational sites to track resource use, energy efficiencies and/or consumption. However, at the country level monthly consumption records are consolidated on spreadsheets which record energy consumption. The energy consumption monitoring records usually include electricity use, oil, diesel and petrol consumption, water consumption, used oil recycled/recovered/disposed, hazardous materials, etc., with different levels of detail across the different countries of operation. Averda has placed a program to improve on resource consumption. These includes a target to reduce by end 2023, hazardous waste generated by its own operations by five percent, non-greenhouse gas (GHG) emissions (e.g., landfill dust, etc.) by five percent and achieve zero internally generated waste to landfill from all its operations. Averda will develop and adopt a resource efficiency and GHG reduction policy and procedure at the corporate level with clear objectives, consumption records, performance monitoring and energy efficiency initiatives to be cascaded to all countries of operation (ESAP #3).

Greenhouse Gases (GHG): Averda mainly tracks GHG emissions from landfills, fleet operations, travel and from electricity consumption across most of its operations, with a target to also add emissions from incinerators in the near future. Averda has established GHG reduction targets across the organisation with specific focus on fleet impact, emissions from landfill and its circular sustainable services. Averda will report on GHG emissions and reductions achieved based on internationally recognized carbon accounting methodologies (ESAP #3).

Water usage and wastewater treatment: Water usage and wastewater is generated by city cleaning operations, water use at their different waste facilities and leachate generated at the landfills Averda operates. Averda will develop and implement a corporate water resource use policy and procedure at the Group level with clear objectives, consumption records, performance monitoring, water conservation initiatives, and wastewater (where not connected to municipal networks) and leachate treatment specifications, to be cascaded to all countries of operation (ESAP #3).

Pollution Prevention, Waste and Hazardous Material Management: The level of implementation of pollution prevention and waste management varies from country to country with areas of improvement observed at several of the facilities visited. Areas of improvement identified at some facilities (e.g., Congo), included oil spills, management of waste and leachate run off at the transfer stations; procedures for daily cover of waste; leachate treatment and management at the landfills, as well as implementing effective environmental controls undertaken at these locations. In South Africa, areas of further investigation and improvement were identified with regard to incinerator stack emissions control, monitoring and control of leachate, runoff control to stormwater drainages and an old operational landfill that has been sited on clay, but has two unlined cells.

Averda hazardous material management includes medical waste treatment (e.g., South Africa, Oman and UAE), fallen stock incinerator (UAE), a hazardous waste landfill and a hazardous waste blending facility, to transform high calorific hazardous liquid waste into fuels suitable for industrial use (South Africa).

Averda will undertake a corporate-wide audit to assess pollution prevention, waste and hazardous material management, identifying improvements to design and operational practices based on the ESDD carried out for the proposed investment and in compliance with IFC PSs and aligned with GIIP as described in the applicable and relevant WBG EHS Guidelines (ESAP #3).

The environmental design and performance monitoring of Averda projects are mainly guided by local requirements and by what has been requested within the commercial agreements that the company signs with its clients. Minimum E&S standards do not appear to be applied, which creates inconsistency across the different countries of operation, does not constitute GIIP and opens the company up to environmental liabilities. As an example, the design of WTS’s varies greatly between Tangier and Congo. In Oman, groundwater, leachate quality, and landfill gas are regularly monitored, whereby in Congo and Tangier landfills this is not currently undertaken.

As per ESAP #1, Averda will develop a suite of environmental and social minimum specifications at the corporate level, to ensure standardization for the design, construction, operation and environmental monitoring of all their waste facilities across all countries of operations. Averda will also develop a procedure for undertaking due diligence assessments prior to merger, acquisitions and/or taking ownership of sites or concessions to address key issues identified (e.g., historical pollution such as land and groundwater contamination).

 Community Health and Safety

In general, Averda operations contribute to the reduction of community health and safety risks by collecting and removing waste and proposing innovative solutions for their treatment and final disposal.

Most Averda landfill sites are located away from sensitive receptors, whilst waste transfer stations are mostly located close to urban areas. Of the waste transfer station visited, the facilities located in Congo needs improvements to mitigate potential negative health and safety impacts, by improving waste storage process ensuring waste is immediately transferred, and by installing leachate collection. Under ESAP #1, the company will implement corporate procedures which will be rolled out at the country level to ensure consistent operations at the waste transfer facilities, including the facilities in Congo. Given the nature of Averda’s activities the most significant risk to community’s health and safety relates to road traffic risks, collisions, and accidents. The company is running a robust road traffic management program that has been designed at the corporate level and is being applied across all operations (see OHS section under PS2). As per ESAP #3, Averda will undertake a corporate-wide audit to assess pollution prevention, waste and hazardous material management, identifying improvements to design and operational practices based on the ESDD carried out for the proposed investment and in compliance with IFC PSs and aligned with GIIP as described in the applicable and relevant WBG EHS Guidelines.

The selected circular economy projects will be designed, constructed and operated as per IFC PSs, GIIP and applicable WBG EHS Guidelines; therefore, it is expected that their normal operations will have limited impacts to the local communities. Community risks and impacts will be assessed as part of the project ESIAs, where these are required, or through focused E&S assessments (ESAP #1).

Security Personnel: Most sites operated by Averda are secured by a fence and have an Access Control procedure and Physical Security plan in place. Security guards are not armed. In South Africa, some sites have access to armed response units. Some of the landfill sites in South Africa have experienced encroachment (of buffer zone) and incursions by informal waste pickers, despite repeated efforts to physically maintain the boundary fencing and educate and/or liaise with communities about the risks to health and safety. Averda will document a Group Security policy (applicable to all Averda facilities) which will include the requirement to carry out security risk assessments and will specify security guard conduct, code of ethics, guidelines on use of force, as well as processes on background checks of private security providers. The policy will be contractually binding for the private security provider and communicated to the security guards as part of the induction, as well as refresher training. In addition, the community grievance mechanism (discussed under stakeholder engagement) will also allow for complaints related to security forces (ESAP #4).

 Averda facilities are mostly located within industrial areas and where this is not the case (e.g. landfills and incinerators), these are mostly located in areas of modified habitat.

In Morocco, the Tangier non-hazardous landfill was the only location where potential impacts of the project on biodiversity were identified. The proposed PRF for Tangier is currently proposed to be collocated within the Tangier landfill development footprint. The landfill site is located in the Mediterranean woodlands and forests ecoregion. The current operational site is located immediately adjacent to (and once fully developed will partly overlap a small part of) the Oued Tahadart Important Bird Area (IBA) / Key Biodiversity Area (KBA). This area is a mix of natural habitats with agricultural land uses, settlements, and roads. The values for which the KBA was designated are unlikely to be present in the project area because they are recorded in a different section of the KBA or require habitats which do not occur in the project area. The IBA/KBA overlaps a legally protected area (Sites d’Intêret Biologique et Ecologique – SIBE, IUCN Cat. Not Reported) and Ramsar site, both named Oued Tahadart. The landfill site does not overlap the boundaries of the protected area or Ramsar site. National legislation does not allow landfills near protected areas, sites of biological and ecological interest, wetlands and forests, and irrigated areas but does not specify a minimum distance from these areas.

The project area is treated as modified with some degraded natural habitat possible due to presence of existing waste management infrastructure, agricultural land, and heavily degraded but undeveloped lands. Although modified, some biodiversity values (e.g., plant, invertebrates) have global ranges that overlap the project site or could occur in downstream wetlands but which the ESIA baseline did not address.

Averda will conduct a biodiversity assessment by a suitably qualified biodiversity consultant, familiar with IFC PS6 requirements, to i) update the biodiversity baseline of the project area, focusing on possible plants and invertebrate values; ii) confirm extent and condition of natural habitat; iii) clarify downstream risks to legally protected and internationally recognized sites adjacent to the project; and iv) assess risks of species that could be attracted by the landfill (e.g., Egyptian Vulture). Based on the assessment, Averda will update the ESMP to mitigate risks in compliance with PS6. This will include consultation with relevant organizations managing the legally protected and internationally recognized areas (ESAP #6).