IFC’s review did not identify any risks and impacts to be managed consistent with the other four Performance Standards (PS): PS5: Land Acquisition and Involuntary Resettlement; PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7: Indigenous Peoples; and PS8: Cultural Heritage. MEDLOG leases or acquires land and facilities on a willing buyer willing seller basis. Due to the business activities of the company, all its assets are located either within port areas or within other industrial / commercial areas and in urban or peri-urban locations.  

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

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. MEDLOG’s business activities have potential limited adverse environmental or social risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily avoided by implementation of good international industry practice (GIIP) and addressed through mitigation measures.

Given the corporate focus of this proposed investment and the company’s operations for inland transportation of container and cargo distribution and its relevant assets, E&S issues reviewed included: the availability and development of corporate management systems and implementation at the asset levels, E&S organizational capacity, labor and working conditions (including contractor management, management of temporary workers and casual labor, equal opportunities and gender issues, grievance mechanism and antiharassment/anti-GBV policies), OHS performance, truck fleet management & safety, security risk assessment and management, and stakeholder engagement. The level of integration with the Cargo Division’s sustainability and governance practices and E&S management system was also reviewed.

Environmental and Social Management System and Policy

MSC is an active member of UN Global Compact and supports the UN Sustainable Development Goals (SDGs). Information about MEDLOG’s approach towards sustainability and relevant best practice can be found in MSC Sustainability Reports, which are published as part of MSC’s commitment to submit a “Communication on Progress (COP)” to the UN Global Compact. The Sustainability Reports are available on the MSC’s website: https://www.msc.com/che/sustainability.

MSC is also a member of Clean Cargo Working Group, Global Industry Alliance, Global Maritime Energy Efficiency Partnerships, World Shipping Council, United for Wildlife Transportation Taskforce and a signatory to the Buckingham Palace Declaration against illegal wildlife trade.

MSC had developed and implemented an integrated management system which is designed to be applied by the entire Cargo Division, including MEDLOG. MEDLOG’s management system is certified ISO 9001 and ISO 14001. In addition, MEDLOG adheres to the guidance provided under ISO 26000 on Social Responsibility. MEDWAY developed its own Safety Management System, approved by the National Safety Agencies where MEDWAY operates. Furthermore, MEDWAY operates in compliance with the “Regulation concerning the International Carriage of Dangerous Goods by Rail” (RID) by the Intergovernmental Organisation for International Carriage by Rail.

MEDLOG’s HSSE Manual, issued in June 2020, includes Safety Policy and Environment, Occupational Health and Safety Policy, and Integrated Management System Policy. It requires that all MEDLOG’s Affiliates adopt a management system at the operating sites.

In October 2020, the company issued, as part of its HSSE Framework, a technical standard on Safety Management System, which provides the overarching structure of the management system and make reference to the management standards, technical standards and guidance notes, which are collated within the HSSE Manual.  The Management System is built around eight elements, including leadership and commitment; policy and strategic objectives; organization, resources and competence; risk evaluation and management; planning, standards and procedures (including among others, job hazard analysis, management of change process, emergency preparedness and response, and corrective and preventive actions for non-conformances); inspection and assurance; and management review. 

Contractor requirements, assurance and monitoring of contractor compliance is a key requirement under IFC’s PS. MEDLOG will review its current practice in this respect and design a third-party management framework aligned with relevant PS. Requirements for new projects, mergers and acquisitions. are also referred to in the management system and will be reviewed and updated in line with relevant PS. (

The company is committed to working under a Permit to Work (PTW) system as required by the nature and type of site-specific operations and activities. The relevant PTW procedure is presented in the HSSE Manual. The HSSE Manual includes a number of technical standards, including Scaffolding Management, Working at Height, Material Lifting Operations, Confined Space Entry, Control on Hazardous Energy, Control on Hot Work, Management of Gas Cylinders, Personal Protective Equipment, Ground Disturbance and Excavation, Incident Investigation, Fire Risk Management, Machine Guarding, Risk Evaluation and Management, Process Safety Management, Management of Hazardous Chemicals, Emergency Preparedness and Response. Procedures on container cargo management, dangerous goods shipment and relevant training are also available. While the set of standards and procedures is extensive, the company recognizes that there is the need for a review and update of the management system documentation to ensure that it takes into account the specialized and growing needs of MEDLOG across all its operations.

MEDLOG’s Code of Business Conduct addresses compliance with all applicable laws and regulations and sets forth relevant standards of responsible business conduct in a number of areas, including environmental protection and working conditions. It also includes a commitment to continuously improve the company’s practices and procedures to further minimize its environmental impacts and externalities on lands, populations, biodiversity, and ecosystems. MEDLOG upholds compliance with applicable laws, regulations, standards and other relevant requirements for environmental protection such as site permits, vehicle emission requirements and standards in the countries in which it operates, as well as applicable certifications and permits required in connection with cross-border transport of goods.

The Collateral Management Manual, issued in 2019, is a comprehensive set of procedures that regulate the collateral management business, starting from the enquiries and the feasibility studies, and including roles and responsibilities for all steps and relevant requirements in terms of warehouse inspection and risk assessment, health and safety, training, audits and reporting.

Under ESAP Item #1, MEDLOG will review and update its management system (HSSE Framework, HSSE Manual, and Collateral Management Manual) and develop the needed bridging documents (i) to ensure that it takes into account the specialized and growing needs of MEDLOG across all its operations, and (ii) to ensure full alignment with IFC’s PS and requiring the adoption of the more stringent standards, levels and measures among the host country regulations and the applicable and relevant World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines and GIIP. As part of this action, the company will review good international practice and ongoing practice by MEDLOG’s Affiliates  to develop a corporate E&S policy and related policies and procedure, in line with relevant standards and internal procedures and policies. MEDLOG will also issue specific guidance for implementation of the E&S policy and other relevant policies and procedures. with time-bound roll-out plans for the national entities to fully adopt and implement the corporate standards. The management system will be complemented with the relevant social management standards and procedures, including the development of a Stakeholder Engagement Procedure with an external grievance mechanism, as discussed below under Stakeholder Engagement.

Identification of Risks and Impacts and Management Programs

A risk assessment process is implemented by the Collateral Management team during the due diligence carried out on third-party warehouses and facilities; the assessment covers hazards associated with health, safety, security and environmental management. At the level of some MEDLOG’s Affiliates  (e.g., Brazil and Côte d’Ivoire), there are some procedures relevant to the identification and assessment of E&S aspects and impacts, and identification of risks. The same MEDLOG’s Affiliates have procedures relevant to control measures, including trainings, maintenance planning, engineering controls) and reporting procedures, including the definition of key performance indicators for water and electricity consumption, waste generation, permits to work, and environmental and safety incidents. While the MEDLOG’s Affiliates are broadly aligned with the corporate standards and procedures, the systematic adoption of corporate management system requirements across all MEDLOG’s Affiliates is still to be achieved and will be pursued by the head office as part of the ESAP Item #1.

Under ESAP Item #2, MEDLOG’s Technical Standard on Risk Evaluation and Management, the Management Standard on Project Development and Life Cycle Management and the Management Standard on Acquisition, Divestment and Joint Venture Due Diligence will be developed with the elements required under IFC PS with respect to E&S risk identification, assessment, data collection and due diligence processes for new projects, new operations, mergers and acquisitions.

Organizational Capacity and Competency

MSC HSSE, Sustainability and Global Human Resources functions will include MEDLOG in their perimeter and scope of work in 2021 (HR discussed in more detail under PS2 below). The organization at the corporate level is complemented by four area supervisors, a rail supervisor, a lifting equipment supervisor, a Head of collateral management, and a Business Development Manager, all reporting to the executive directors of MEDLOG. HSSE oversight at the regional level is delegated to area supervisors with MEDLOG’s Affiliates either having an HSSE function (e.g., Brazil, Côte d’Ivoire, Nigeria) or relying on HSSE consultants (depending on the size of the operations in each country). Site Safety Committees have been established in some of the countries (e.g. Tanzania) bringing together management and worker representatives for general monitoring of safety performance and processes. Given the size and complexity of the operations carried out by MSC’s Cargo Division, the corporate HSSE management is supported by the availability of a HSSE Dash-Board Technology which allows real-time analysis of on-line data from different operations and assets.

As per plans, MEDLOG’s Collateral Management corporate team will also include a Risk Manager, who will be responsible for the risk assessment and audits globally.

The company will implement the organization and resource framework as described in the MEDLOG’s HSSE Framework, once reviewed and approved, and according to an agreed time-bound implementation program. The corporate functions will be complemented by a MEDLOG senior E&S Manager with direct responsibilities on the implementation of the HSSE and Social policies and compliance with IFC’s PS. The manager will be responsible for the implementation of the ESAP, in coordination with the relevant line directors and managers (ESAP Item #3). 

General HSSE trainings are provided to MEDLOG’s personnel, together with specific training procedures, for example on handling of dangerous cargo, were reviewed by IFC. MEDLOG will develop an HSSE training plan and will ensure that HSSE modules are included in the mandatory training curriculum for all the direct employees and contracted workers across all the MEDLOG’s Affiliates. The training matrix for mandatory HSSE modules will be provided to direct and contracted workers (ESAP Item #4). 

Emergency Preparedness and Response

A Technical Standard on Emergency Preparedness and Response is included in the MEDLOG’s HSSE Manual.  The standard requires that MEDLOG’s businesses, projects and managed operations develop and implement an appropriate Emergency Preparedness and Response Plan (EPRP) for the protection of staff, contractors, visitors, environment and general public from any harms that may be caused by Company’s operations and for any emergency situation. The first version of the overall Emergency Plan for MSC’s operations was issued in 1993 and since then has been updated. It now also applies to part of MEDLOG’s business activities. Scenarios covered by specific plans include fire and explosion, hazardous chemicals, including flammable and toxic gases, special equipment accidents, barge terminal accidents, intermodal transport and on-site accidents, natural disasters and extreme meteorological events, and other incidents such as pandemic, earthquakes, technical problems, storm/ gale,

In support of the emergency response system, the MSC Cargo Division implements a Total Integrated Command System, which is not yet centrally developed for MEDLOG. 

Examples of EPRP developed by the MEDLOG’s Affiliates (e.g., Chile) were reviewed by IFC. Consistency with global standards and adequacy of the emergency procedures in terms of preparedness and response strategies or actions will be reviewed and updated as part of the actions under ESAP Item #1.

As of October 2020, MEDLOG employs 8,200 employees across all global operations and Geneva’s HQ. Business operations also engage a sizeable number of contractors and contracted workers, which the company estimated at around 1,800 individuals in 2020. In some jurisdictions, truck drivers are sourced from own account workers. During IFC’s review, centrally-collected data on the gender breakdown of the workforce globally was not yet in place.

Human Resources Management, Policies and Procedures

MSC has a global HR function that l monitors the application human resources global policies. These will be reviewed and improved to ensure their alignment with the revised version of MSC’s Code of Business Conduct issued in 2020. The Code applies to all MSC employees and it covers issues such as non-discrimination, child labor, working conditions, harassment and abusive conduct, worker associations and occupational health and safety matters. In 2020, MEDLOG started the review process of its own Code of Business Conduct, which is being implemented within MEDLOG’s Affiliates in 2021, and is largely based on MSC’s Code of Business Conduct, but with more comprehensive text on sexual harassment, child labor and freedom of association to cover the company’s sector specific risks and standards. The policies are broadly consistent with the requirements of PS2. Grievance mechanisms and the procedures required to cover the way in which labor conditions are governed for workers engaged by third parties will be developed in line with relevant national legislation and international frameworks of reference, including relevant IFC PS requirements. In addition, the company will also develop a framework retrenchment policy, consistent with PS2 requirements (ESAP Item #5). 

The MSC Global Human Resources structure includes a Global HR director, two  Global HR managers and also global managers who are responsible for HR Transformation, Learning & Development and Training for the MSC’s Cargo Division. MSC has established a team of 10 regional and cluster HR managers, each responsible for several countries. The Global Human Resources function will strengthen its support to MEDLOG’s Affiliates in order to monitor compliance with applicable national labor legislations, local and global HR policies and approaches. It will also ensure appropriate review of HR action plans and related processes.

With reference to the above, and due to MEDLOG’s business expansion over the past five years, which has involved a doubling in the number of MEDLOG’s Affiliates , the MSC Global Human Resources function is currently recruiting a MEDLOG Human Resources manager to carry out a dedicated supervision of all MEDLOG’s Affiliates.

An HR global IT platform for the MSC’s Cargo Division and MEDLOG is under development to facilitate information on HR demographics and promote consistency across the organization when applying global HR policies. The information on the platform will be at the disposal of MEDLOG’s management and employees with information available on performance criteria, demographics and trainings.

At the national level, HR functions are responsible for the implementation of national legal requirements and relevant global policies in-each country, in line with the Employee Handbooks, which contains all company’s global policies and reflects relevant provisions of national legislation. The handbooks are shared with employees and serve as a guidance document and a checklist for local management and regional managers to review jointly. For some MSC’s Agencies, where the managing director is responsible for HR, MSC HR function has developed a toolkit to provide guidance on issues related to employee recruitment, performance and HR basic management.

Due to variations in national law, not all MEDLOG’s Affiliates have exactly the same policies and procedures in place. Degree of variations in implementing global policies will also depend on the size of the business and on the phase of evolution of the company. MSC and MEDLOG senior management is aware of this disparity and intends to address it by leveraging existing due diligence processes, including the Human Rights Due Diligence processes. The global HR IT platform will be used to provide training on specific policies and improved processes.

The internal auditors within the MSC Corporate Audit Department conduct internal audit engagements, including over payroll and HR areas such as remuneration and employee benefits, training and development, performance or termination. The global MSC Social Audits launched in 2019, include areas related to Human Rights, Modern Slavery and social issues, in line with standards and principles set forth in MSC Code of Business Conduct.

Working Conditions and Terms of Employment

As indicated above, MEDLOG will ensure that each if its Affiliates will produce an Employee Handbook, in alignment with applicable national law and the Company’s Code of Business Conduct. The handbooks will describe and address issues related to working conditions and the terms of employment. Handbooks received from a number of MEDLOG’s Affiliates were reviewed by IFC, including Brazil, Côte d’Ivoire, Malaysia, Uruguay. For example, in Brazil, the terms and conditions of employment reflecting national law and Company’s policies are outlined in the Employee Handbook and referred to in the contract document provided to workers. The policies are consistent with the requirements of Brazilian labor laws and PS2. 

In relation to the process and approach related to recruitment, there are broad provisions included in a global policy document. Implementation is the responsibility of each MEDLOG’s Affiliate and, as a consequence, will necessarily vary depending on the national regulatory and practical environment.

The company will ensure that Employee Handbooks, in local language where required, are available in all MEDLOG’s Affiliates and that they all have minimum standards set out in PS2, relevant company’s policies, relevant standards and principles as set forth in MEDLOG’s Code of Business Conduct and applicable national laws. Relevant procedures and processes will be developed in local languages. MEDLOG will also ensure common principles for structuring contracts for direct employees across its Affiliates with the defined PS2 minimum standards. The company will therefore conduct an analysis of existing Employee Handbooks and work contracts, and agree on a common structure and consistency in referencing PS2 subjects, relevant policies, minimum requirements and standards.(ESAP Item #6).

Workers’ Organization

Freedom of association, including workers’ rights to form and join trade unions, and related matters, are referred to in the company’s Code of Business Conduct and shall be in compliance with applicable laws and regulations of the countries in which the Company operates, and in line with PS2 requirements. Its implementation will be considered for inclusion be in the internal audit program, in line with current due diligence practices developed for MSC. Given MEDLOG’s presence in over 70 countries, relations with trade unions are an important matter that needs careful monitoring, as recognized by the company.

MEDLOG recognizes the importance of establishing an oversight and support mechanisms for its Affiliates to manage trade union and collective bargaining issues. Under ESAP Item #7, following the appointment of the MEDLOG HR manager, the company will conduct a global and country risk analysis and develop specific guidance, in collaboration with the Human Rights function within the Sustainability Department. It will also provide tools and training for HR managers and staff on union engagement, collective bargaining and engagement with worker representatives, based on international good practice and relevant international standards. Workers organizations management, performance and issues will be included in relevant processes and procedures, in collaboration with relevant departments.

Non-discrimination and Equal Opportunity

There are provisions related to non-discrimination referenced in the company’s Code of Business Conduct which explicitly states that the company does not tolerate any discrimination based on sex, race, religion, language, gender, national origin, age, disability, political or ideological beliefs, marital status, and sexual orientation or family responsibilities. There is also a specific reference to the prohibition of sexual harassment, although there is no explicit protection provision in reference to gender-based violence and harassment. 

Non-discrimination is not yet routinely examined as part of the internal audit process, although it is informally covered during the regular exchanges between local and regional HR managers in MSC and is assessed by the audit team if there is a complaint raised. Its implementation is a responsibility of the national entities and, therefore, its performance may vary depending on the socio-cultural context and the legal framework. For example, MEDLOG Brazil has established a non-discrimination working group to deal with the issue.

As part of the actions to ensure consistency across national agencies and to comply with PS2, under ESAP Item #8, the company will implement a program to strengthen its capacity to deal proactively and consistently with issues relevant to discrimination and equal opportunity. MEDLOG will conduct a global and national level risk assessment, including gender-based violence and harassment, and will follow up with appropriate action and training. It will develop a training program on non-discrimination and equal opportunities for its Affiliates’ Human Resources functions, Managing Directors and other relevant supervisory functions with an emphasis on gender-based violence, all forms of harassment, including sexual harassment, and vulnerable groups. As part of the program, the company will review existing locally developed good practice , e.g. Brazil non-discrimination working group, and will develop good practice training and processes accordingly. The company will also include identification, prevention and handling of potential discrimination issues in its risk management frameworks.

Grievance Mechanism

Employees can raise complaints via a web-based portal called the ‘Speak-up Line’. In Brazil and Chile, both MEDLOG’s Affiliates have developed a grievance mechanism in line with respective national legal frameworks. Labor-related lawsuits, including the ones related to contractors’ workers, are also analyzed at the national level.

Under ESAP Item #9, MEDLOG will improve its existing complaint procedures in line with relevant international standards and develop internal workers’ grievance mechanisms in line relevant IFC PS. As part of this action, the company will review good international practice and ongoing practice at the national level on management of complaints (e.g. Brazil and Chile). The grievance mechanisms will be accessible also to temporary agency workers. MEDLOG will also develop contractual requirements and/or due diligence requirements for contracted workers as defined by IFC PS2, to establish their own grievance mechanisms and report to MEDLOG on the operation of such mechanisms and patterns of grievance. 

Occupational Health and Safety (OHS)

MEDLOG’s HSSE Manual and the HSSE Framework covering Technical Safety Standards provide for a hazard identification and risk evaluation framework, including processes for risk management and control for both routine and non-routine activities as per ISO 9001:2015 standard. In addition, MEDLOG’s Affiliates at national level are required to have a hazard identification and risk mitigation plan including the use of job safety analysis to ensure the safe completion of tasks. These corporate requirements have been implemented in some of MEDLOG’s Affiliates (e.g. Tanzania and Brazil) including the Collateral Management function. As part of ESAP Item #2, the company will ensure consistent implementation of a structured hazard identification and risk assessment process, in line with relevant ISO standards and guarantee availability of project/company specific risk registers across all countries of operation in compliance with the requirements of the company’s standards.

Some MEDLOG’s Affiliates have established a training plan and program for direct employees targeting warehouse operators, lifting equipment operators and truck/locomotive drivers (e.g. MEDWAY Italy). A specific training plan covering mandatory and task specific HSSE modules will be developed and implemented by the company as per ESAP Item #4 indicated above under “Organizational Capacity and Competency”.

MEDLOG’s Affiliates (e.g. Tanzania, Nigeria, Italy, Brazil) have a system for collating and reporting information on work-related accidents and incidents including conducting investigations and analyses of their root causes. At the corporate level, there will be a systematic aggregation and analysis of OHS performance data (both lagging and leading indicators) from MEDLOG’s Affiliates, according to relevant ISO standards and existing HSSE risk assessment dashboards. The company will establish and implement an appropriate OHS performance measuring system including periodic reporting on both lagging and leading indicators relevant to its logistics and transportation operations, as defined in MEDLOG’s HSSE management system, according to relevant standards within the industry, and as per requirement defined under ESAP Item #1.

On incident investigation process, IFC’s review of sample investigation reports identified areas of improvement, including the identification of contributory factors and root causes material to the apparent failures and circumstances leading to the incident. MEDLOG will, therefore, continue to strengthen incident investigation capabilities of its workforce by ensuring that members of the investigation teams are consistently trained on root cause analysis under ESAP Item #4. In addition, MEDLOG will revise and update its incident investigation procedure to provide for preparation of a timeline and identification of critical factors in line with GIIP under ESAP Item #1.

MEDLOG’s will develop a Technical Standard which specifies a requirement for undertaking industrial hygiene and employee health monitoring related to the handling and transportation of hazardous substances, as per international legislations and standards. Each of MEDLOG’s Affiliates will develop and implement procedures and plans for industrial hygiene monitoring and health surveillance of workers exposed to hazardous substances in line with national requirements and relevant international standards, where defined, performance levels stipulated in the WBG EHS General Guidelines (ESAP Item #10).

An OHS audit for warehouses under MEDLOG’s Collateral Management program is conducted prior to any contractual agreement and periodically thereafter to ensure continued compliance with company requirements. There are ten warehouses at present in the Collateral business. The audit protocol includes a review of legal status of ownership, OHS policies, life and fire safety, safety signage, material storage and handling practices, loading docks and walkways, heavy goods trucks and powered industrial vehicles (forklifts), security and physical condition of warehouses, among other requirements.

MEDLOG will further implement emergency preparedness and response plans to protect workers from the risks related to COVID-19 contagion and these plans, which include regional and local COVID-19 response plans and mitigation measures, are applicable to MEDLOG operational sites. Specifically, as of 2020 MEDLOG has ensured that workers such as essential office staff, drivers, maintenance teams and warehouse personnel whose roles cannot be performed at home, are given adequate support and resources to continue to work safely and to avoid spread of COVID-19 disease, which include sanitization and hygiene measures, work and travel risk assessment, face masks, physical distancing measures and other barrier measures to minimize person-to-person interactions. MEDLOG’s Affiliates have undertaken regular infection and exposure mapping, including sharing of safety alerts, messaging materials and awareness sessions for its workforce on the safety controls and public health measures that have been put in place by MEDLOG the organization and by the relevant government institutions respectively, across all countries of operation.

Workers Engaged by Third Parties

A number of third-party contractors engaged by the company provide services that are core to MEDLOG’s business, such as warehouse operations or truck transportation, and that complement MEDLOG’s workforce. The company also uses temporary agency workers to respond to peaks in business activity. For example, in 2020 in Côte d’Ivoire MEDLOG has 400 direct employees and, on average, 270 temporary workforce.

Contracts with third parties should include standard clauses that require compliance with the applicable legislation in terms of labor management and OHS protection and management but do not specifically refer to all PS2 requirements. In some countries, third-party contracts also include a reference to the company’s Code of Business Conduct. Periodic safety, security and hygiene audits might be conducted by some legal entities, although a systematic review across all operations is not yet implemented. Monitoring activities on HR management and payroll for workers employed by contractors are out of scope in the internal audit process.

MEDLOG will launch a time-bound program to progressively enhance monitoring and enforcement of compliance of third-parties with national labor legislation and PS2 requirements (ESAP Item #11). The program will include the following actions: (i) include in global policies’ scope and establish system to mandate, leverage and monitor third-party compliance with national law, PS2 and relevant policies and requirements developed as industry standards ; (ii) conduct a risk analysis on salient labor issues for each country and develop guidance for MEDLOG’s Affiliates to better address those issues; (iii) introduce a comprehensive and auditable process of selection and management of contractor and third-party including labor standards, based on defined minimum standards set out in PS2; and (iv) identify in which countries labor agents or intermediaries are being used by MEDLOG’s Affiliates and start to develop an auditable process to ensure working conditions of those workers meet minimum standards set out in PS2 and comply with national law, and requirements developed as industry standards.

Supply Chain Workers

MEDLOG is committed to ensuring that working conditions in the supply chain are safe, that workers are treated with respect and dignity, and that manufacturing processes are environmentally responsible. The need to understand and respond to emerging risks is even more relevant if the company invests in auxiliary business areas such as processing and packaging (for example cocoa packaging in Côte d’Ivoire and in the near future a food packaging facility in Peru) where labor issues associated to these activities can be very different from those associated to transport and logistics and where labor agencies are being used to provide temporary labor. There may be also potential PS2 supply chain issues, including child labor risks, to consider in these circumstances. MEDLOG will ensure to develop relevant processes in line with sector-specific current and emerging risks, in line with relevant international standards of responsible business conduct and relevant PS2 requirements.

Under ESAP Item #12, MEDLOG will include identification, prevention and management of supply chain risks in its global policies and related operational procedures, in compliance with PS2 requirements and relevant international standards.

As per the Code of Business Conduct, priority environmental topics at MEDLOG include, but are not limited to, greenhouse gas emissions reduction, abatement of polluting gaseous emissions, energy and operational efficiency, responsible use of natural resources, sustainable waste management, sustainable water use and effluent discharge, noise reduction, and respect of local biodiversity.

Resource Efficiency and Greenhouse Gas (GHG) Emissions

In line with the efforts and several initiatives carried out by the MSC’s Cargo Division on reducing GHG emissions throughout the entire container logistics flow involving the shipping line, port terminals and inland transportation and logistics, MEDLOG supports the shift from trucks to alternative modes of transport by investing in more efficient and sustainable intermodal solutions, wherever possible. The strategy includes the deployment of an inland depot network in locations that allow to maximize the use of barges on inland waterways, where viable, and reduce the distance covered by trucks. Transporting containers using barges as the main transport mode allows for a measurable reduction in absolute greenhouse gas (GHG) emissions. For example, in late 2019 MEDLOG opened a barge terminal and depot facility in the western part of Lagos’ Port, Nigeria, enabling the replacement of up to 50 trucks per day, by using barges with 50 TEU capacity.

The annual GHG emissions from the company’s facilities and operations, including both direct (on-site fossil fuel combustion and fleet fuel consumption) and indirect (electricity consumption) emissions will be quantified. Quantification of GHG emissions will be conducted by MEDLOG annually in accordance with internationally recognized methodologies and good practice and published in the Sustainability Report.

Pollution Prevention

Company’s existing operations do not pose a threat of significant environmental pollution. However, although the inherent risks of pollution associated with MEDLOG’s operations are limited both in likelihood and magnitude, these can be further prevented and mitigated by appropriate measures in accordance with GIIP. 

MEDLOG’s depots, warehouses and fleet are not only bound to meet environmental compliance requirements, but also comply with company’s standards relevant to noise, air pollution, water / wastewater effluent, and fuel management.

Electricity is mainly sourced from the public grid at company’s facilities, while on-site back-up, diesel generator (DG) sets are provided and used only in case of emergency or power failure. The company ensures such sets are equipped with integral acoustic enclosure at all times. No significant impact on ambient air quality is expected on account of the company’s operations at facility level.

The effluents produced are discharged to municipal or industrial water treatment plants, septic tanks and/or soak pits provided on-site or discharged to the local sewerage system. Septic tank sullage is periodically transported and disposed of by authorized third parties.

Waste generated by MEDLOG’s operations is also limited, and include general waste, recyclables (packaging, paper, plastic) and smaller amounts of hazardous waste (used oil, used batteries from truck maintenance and from DG sets). The company will establish procedures for waste management across all operations, according to ISO 14001. Waste is gathered, sorted and disposed of through certified third parties in accordance with the local regulations. Examples of waste management plans issued by some MEDLOG’s Affiliates were reviewed by IFC and are consistent with PS3 requirements. Hazardous chemical management and management of dangerous goods shipments are processed in line with the relevant applicable requirements and will be monitored as part of company’s E&S management system to be developed. 

For reefers, MSC Cargo division is committed to ensuring and reporting compliance with the Montreal Protocol and the relevant Kigali Amendment on ozone-depleting substances.

As indicated above, in case of new projects, the company will develop and implement a project-specific EHS plan (ESAP Item #2), based on an E&S assessment in line with company’s standards, national requirements, and consistent with relevant IFC PS, and will monitor construction-related emissions.

Community Health and Safety

At the corporate level, MEDLOG will review and improve specific technical standards relevant to Transportation and Logistics Management, and Road and Driving Safety as well as develop specific policies on these elements. The company owns a significant fleet of trucks, rolling stock and barges and, given the relevance for its business activities, it has a technical team in charge of the development and adoption of the required technical specifications and to support the MEDLOG’s Affiliates in maintaining their fleets. 

IFC’s review found that adequate transportation safety management systems have been established in some MEDLOG’s Affiliates (e.g. Italy and Australia) that include effective approaches to journey management, fleet management and driver management. For consistency across all MEDLOG’s Affiliates, the company will implement and maintain a systematic and structured corporate program on road transportation safety to ensure compliance with local laws, GIIP and WBG General EHS Guidelines on Traffic Safety (ESAP Item #13). 

As part of the Collateral Management process, MEDLOG has established and implemented a pre-acquisition and periodic warehouse safety inspection and maintenance system to ensure both company-owned and third-party leased warehousing facilities are in compliance with fire safety regulations (e.g. Australia, Nigeria, Brazil and Chile).

Security Risk Management

MEDLOG engages private security providers to protect its personnel and assets, in line with applicable laws. In addition, MEDLOG have implemented a robust security seal management process for securing cargo containers which complies with GIIP and is augmented with the OpenTech system to track and manage receipt, handling and transportation of clients’ cargo. Under ESAP Item #14, as part of its corporate management system, MEDLOG will develop and implement a structured security risk assessment and management procedure and plan that delineates clear responsibilities and accountabilities and ensure training of security personnel contracted to safeguard personnel and property, in line with PS4 requirements. In addition, as part of ESAP Items #9 and #15, the company will provide a community and staff grievance mechanism, commensurate with the level of risk identified during the security risk assessment, to also handle complaints on the acts of security personnel deployed at MEDLOG owned or leased premises.