Based on Brightstar’s current and proposed expansion plans (and the ESIA reports reviewed for the existing operations), it is expected that the project will not result in adverse material impacts on local indigenous groups, biodiversity and natural resources and cultural heritage. Hence PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous Peoples and PS8: Cultural Heritage are not applicable for this project; however, the company will assess the applicability of these PSs for all the future developments, through the project screening and assessment procedure to be developed as per PS1 requirements.

 This is a category B project according to IFC’s Policy on Environmental and Social Sustainability because the project is expected to generate limited and site-specific E&S impacts that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

Key E&S risks and impacts for the project include: assessment of the project’s E&S impacts, E&S management systems; management of a large workforce, including contractors, according to national laws and PS2; OHS during construction and operation; efficient use of water and energy; management of process wastes (effluent and solid wastes) and emissions; greenhouse gas (GHG) emissions; impacts on nearby communities including those due to transport infrastructure; and land acquisition and livelihood restoration for the project affected families (PAFs). 

 Environmental and Social Assessment and Management System

Policy

In Kenya and Ghana, there are recently created environmental, health and safety policies signed by their respective Managing Directors of Brightstar Ghana and Kenya. The policy highlights a goal of doing no harm to people, protecting the environment, efficient use of material and energy, respecting neighbors, etc. The Senegal operation does not yet have a policy in place. The need to develop an overarching corporate policy to guide the company’s operations in Africa is addressed within ESAP#1, which requires the development of an E&S management system (ESMS) responsive to the PS 1. This overarching policy will be adopted and adapted at each plant and will be widely disseminated to the employees and other stakeholders.

Identification of Risks and Impacts

The company followed applicable national law and regulations with regards to the identification of risks and impacts associated with operations of this kind. An example Impact assessment reviewed by IFC is disclosed along with this ESRS. Such assessments formed inputs to the development of management programs at each plant, which detailed further obligations, such as monitoring and reporting, as detailed below.

Going forward, as part of the ESMS to be developed under ESAP #1, the company will develop a documented screening procedure and standard scope of work for the E&S consultants to assess the applicability of PS6-PS8 for all the future developments, through the project level ESIAs. Based on the outcomes of these assessments, the company may have to conduct additional studies and implement the mitigation measures related to PS6-PS8; if applicable.

Management Programs 

The company has established practices that enable the company to meet its regulatory obligations. These practices are established and implemented by a new project team who reports to senior management in China, but who are assigned to the plant site that is being established. They include project designers, engineers, managers, etc. They are supported on the E&S front by local, registered consultants who undertake the E&S risk and impact assessments, and help the company comply with the host nation laws and regulations, determine the E&S management plans and programs, etc as the project is being set up. As part of the evolution of the company’s operations in Africa, a corporate E&S management function is being established (see ESAP items #1 and #2), enabling support to be provided to all operating entities. E&S management at each plant will report to this new corporate E&S function.

As included in the ESAP #1, the company will develop a PS1-compliant corporate ESMS including required policies, programs and practices. Such an ESMS will ensure compliance with both the relevant local, regional and national environmental and social laws and regulations and the requirements of PS1, and other applicable PS.

Organizational Capacity and Competency

The company has established and maintains an organizational structure at each operating facility that defines roles, responsibilities, and authority to implement the management of environmental, OHS and social matters. Specific personnel have been so designated to fulfill those roles, either in part of full time. These roles and responsibilities are often supplemented by resources within local consulting companies, particularly at the start of operations. Those companies typically lead the assessment of environmental risks and impacts, the design of the environmental and social management plans, and have additional responsibilities regarding regulatory monitoring and reporting.

In Ghana, the commercial department currently oversees aspects related to environmental management, while in Kenya the role is under the plant administration. In both countries OHS managers have been in their respective positions for just under a year. A production safety team has been put into place in Ghana. The general manager of the company is ultimately responsible for the overall work of the company's safety team; the factory manager/ administrative manager is the deputy leader, responsible for the daily management of safety affairs. The person in charge of the workshop is a member of the safety production team and is responsible for implementing safety practices within their department. The safety manager coordinates the safety management work in the factory; two security officers are responsible for supervising, inspecting and reporting on safety matters. Environmental matters related to support operations, be it management of rain water collection, effluent collection/reuse, kiln operations, coal gasification plant, are run by department heads and their staff, supported by consultants as noted above.

Going forward, as defined in ESAP#2, the company will appoint a corporate EHS manager to oversee the EHS matters across all the facilities in coordination with respective facility level EHS teams. This person will be fully supported by resources, monetary and human, to enable them to undertake this role and to drive continual improvement in E&S performance throughout all Brightstar operations in Africa. This position, will report to the most senior of management within Brightstar, who will use such information to guide priorities with respect to E&S management in all Brightstar operations in Africa 

The responsibility of the person appointed will also include developing and implementing the PS1-compliant corporate ESMS (as required in the ESAP#1). Training to ensure that those assuming enhanced E&S roles and responsibilities from third parties at the plant level will be required and will be developed and its implementation overseen as part of a corporate PS1-compliant ESMS. 

Emergency Preparedness and Response

An Emergency Response Procedures (ERP) manual was available for review for the Ghana and Kenya operations. The contents included various emergency situations (fire, medical, structural failure, armed robbery, chemical spillage and flood emergency), actions to be taken in the event of such and who should act. Volunteer firefighters/fire wardens are nominated by the managers within their work areas. They are responsible to act in the event of an emergency; these individuals report to the health and safety team. A list of 25 fire wardens and the departments they work in was submitted as part of the due diligence along with information on training provided to the wardens and their certificates issued by the Ghana National Fire Service, Western Region; such training, provided on a periodic basis, covers topics on understanding types of gases, behavior of gases in the event of a fire, types and presence of liquid fuels and general fire safety. In Kenya, the fire wardens are trained by National Industries Training Authority, who also supervised the first fire drill in June 2019.

In addition to the above, the company in Ghana is part of the Aboadze Power Enclave (the industrial area where the plant is located) HSSE Stakeholders Committee, and as such, is party to the emergency preparedness activities of that group including being a part of the emergency response team, development of the emergency response plan and development of communication protocols to be used in the event of an emergency. Similar ERP manuals will be developed for the facilities to be developed in future as part of the project, as per the ESMS to be developed for each facility.

Monitoring and Review

The company has established procedures to monitor and measure management programs, as well as other key performance indicators (KPIs) to assess compliance with related regulatory requirements.  These typically focus on efficiencies in the production process at the beginning of operations, such as rates of consumption of raw materials as well as other inputs which are continually monitored and measured to drive efficiency and, reduce wastes. Results reviewed indicated compliance with stated requirements regarding air emissions; effluent results are not applicable due to the reuse of waste process water in the production process.

The company will update its documented monitoring procedure to include additional monitoring requirements, such as KPIs related to Lost Time Incidents, near misses, and Grievance Mechanism implementation. As noted above, the development of the corporate ESMS will include this monitoring procedure together with the requirement to report to Brightstar’s senior management. Corporate level reporting will strive to use benchmarking to demonstrate where the company’s performance falls in relation to similar enterprises and to drive overall E&S performance improvements. This is addressed, by reference, in the ESAP, item #1.  

 At the time of the appraisal, the company employed over 2,700 people with 865 people in its Ghana operation (including project-related construction and installation staff). 90 of these are Chinese nationals; the remaining 775 are split between 581 full time and 194 temporary workers. Such workers are a mixture of construction workers and those involved in non-technical operations, including loading/unloading, etc. The company expects the percentage of temporary workers to drop from the current value of 22% to between 10-15%. Thirty-three of the 865 workers are female. Like in Ghana, Kenya operations has a workforce of 850 people, of which 300 are temporary workers, 100 Chinese nationals and approximately 5% women who form the bulk of packaging and sales teams. The Senegal operation currently employs about 1,000 local staff. Chinese employees are primarily in the technical / supervisory roles. Local nationals are being incorporated into the management structure and are being capacitated to undertake such roles and responsibilities. Whereas exact numbers are not yet available, given that each plant will be ostensibly the same, total employment, upon completion of all proposed plants (including new recruitment at Senegal, and new plants in Cameroon, Mozambique, DRC and Zambia.pan-Africa employment is expected to be in the order of 6,300 people.

Human Resources Policies and Procedures

In Ghana and Kenya, the company has put in place a policy and procedures manual (the KeDa Ghana/Kenya Ceramics Company Limited Employee Handbook). The contents include matters of equal opportunity and commitment to diversity, conflicts of interest and confidentiality, recruitment and employment relationship, workplace safety, workplace guidelines and employee benefits (including workers compensation, accommodation and provision of food to workers). The handbook includes company policies and refers to the applicable Ghana and Kenya labor law and regulation.

The handbooks make explicit reference to prevention of sexual harassment. The handbook describes in detail what could constitute sexual harassment and the procedure to follow if an individual believes that they have been subject to sexual harassment or that sexual harassment has been seen to have occurred elsewhere in the workforce. They also outline the procedures with regards to handling of other complaints and/or suggestions. Specifics on hours of work, time recording, overtime, contract terms, disciplinary procedures, termination practices, leave, salaries and bonuses, deductions, paychecks are provided. The handbook contains two pages to be completed by the employee, that acknowledges receipt of the handbook and the harassment policy. The signed pages are kept in the employee’s personnel file. Awareness of the company’s policies and procedures will be extended to those engaged on a temporary basis at the company’s premises, to include those involved in construction, to ensure all who work for or on behalf of the company comply with the policy on sexual harassment. This is addressed in the ESAP in item #3.

The company has a training and development policy at group level, the stated aim of which is to set out measures to support objectives in relation to staff training and development, and the responsibilities that staff at all levels have to ensure development of a strong culture of learning and continuous development.

Broadly, the company’s HR policies and procedures are consistent with the applicable local labor laws and the requirements of IFC PS2 in the countries where it currently operates.

The company will use its existing HR manual template as part of the corporate ESMS that will subsequently from the basis of a corporate HR manual, allowing for and promoting compliance with, the stricter requirements of either national labor law and regulation or PS2 in all countries where it will operate.

Freedom of Association and Grievance Mechanism (GM)

There are no workers’ union at the plants in Ghana and Kenya at present. Both Ghanaian and Kenyan labor laws do not preclude unions.

The Employee handbook includes a section on GM, which mirrors the national laws procedures. In Kenya, the company has formed an employees’ committee, which among other terms of reference, hears workers disciplinary issues. In Ghana, a total of twenty complaints have been received during the 6 months prior to the appraisal and were addressed using the GM. Issues raised included clarification re wage payments, working hours, etc.

Considering the large number of workers and lack of a union, Brightstar will develop and publicize explicit language regarding freedom of association, as would be allowed under national law. This is addressed in ESAP item #4.

Also, Brightstar will implement a formal system for employees to raise grievances anonymously, for example, through a dedicated email address or suggestion boxes to file confidential grievances, without the risk of reprisals, and according to other requirements of IFC’s Performance Standard 2, including aspects such as sexual harassment. The grievance handling procedure will also articulate how the grievances will be handled and resolved; and outcomes communicated to all employees. This procedure will be applicable to all existing and new employees, third-party staff, and shall form part of the HR policy and other relevant documents and shall be communicated extensively to all the beneficiaries (ESAP#5).

Protecting the Work Force

Neither child labor or forced labor is utilized by the company. Whereas minimum age for admission of children into employment is 15 in Ghana, the company does not employ anyone under the age of 18 as per its own HR policy.

With regards to possible child labor in the supply of raw materials, the 2018 List of Goods Produced by Child Labor or Forced Labor (Bureau of International Labor Affairs, U.S. Department of Labor) does not show those materials required in the manufacture of ceramic tiles in Ghana as being associated with either child or forced labor. Further, the company references a policy prohibiting either child or forced labor and it was stated that the purchasing department (who is responsible for procuring raw materials) conducts random checks while visiting suppliers.  Whereas sand is listed in Kenya in the above publication as being associated in general with child and forced labor, IFC was informed that suppliers to the company’s operations are subject to NEMA approval and bi-annual environmental and social audits; likewise, as in Ghana, the purchasing department manages the supply of raw materials so oversight is undertaken to ensure the company does not procure from entities engaged in child or forced labor.

See comment below (under Supply Chains section) and associated ESAP item re integrating E&S norms and regulations into procurement agreements on a corporate wide basis. In addition, a summary of review of raw material suppliers by country will be reported to IFC in the annual monitoring report.

Third Party Workers

Major construction was underway at both Ghana and Senegal locations (e.g. concrete work, erecting steel structures, etc.), being undertaken by the engineering, procurement and construction (EPC) contractors and the sub-contractors employed by them. During a walkthrough of the sites, several poor practices regarding OHS were observed; for example, working at heights without proper fall prevention measures, a lack of personal protective equipment (PPE) such as gloves or steel-toed boots when laying rebar and pouring concrete. The company will develop and then implement a contractor OHS management plan that will increase the rigor, and enforcement, of its OHS oversight with regards to such workers. This plan will be disseminated to all operations within Africa and shall be an important condition in the future contracts issued. This is addressed in the ESAP item #6.

Workers Accommodation

The site visit to the Senegal plant included worker accommodation as provided to non-Chinese construction workers (generally male laborers). Whereas IFC did not enter the accommodation (they were occupied at the time of the visit) they appeared to be sub-standard (i.e. lacking proper ventilation). IFC was informed that they were temporary housing; regardless, the company will review the standard of housing to be provided to workers to ensure they meet the minimum standards found in the IFC/EBRD Guidance Note on Workers’ accommodation: processes and standards. The company will develop standard contract clauses defining minimum requirements for labor accommodation for EPC contractors for construction workers. This is addressed in the ESAP in item #7. 

Supply Chains

The main inputs required in the manufacture of ceramic tiles are limestone, sand, clay, feldspar, water and additives (such as carbonates, silicates and flocculants). Some tiles are decorated using inks (inkjet spraying). Typically, 90% of raw materials are sourced from the country where the plant is located. For example, in Ghana, various quarries (13 in all), that were in existence before the plant was established, and located up to 300km from the plant, supply the raw materials.

The company often signs an exclusive purchasing arrangement with the quarry; a commercial practice to ensure a reliable supply of needed inputs. IFC reviewed a sample mining agreement. Whereas the agreement includes warranties and representations that the miner is legally and beneficially entitled to mine, there is no explicit mention of matters related to applicable environmental and safety laws and regulations pertaining to the operation of the quarries. Whereas current suppliers in Kenya are subject to permitting and auditing, the company will include in future raw material supply agreements in all countries where the company operates reference to compliance with applicable environmental and OH&S laws and regulations and a protocol for auditing the suppliers through site visits as needed. This is addressed in ESAP item #8.

Occupational Health and Safety

The company has conducted risk assessment for its operations as well as has developed a documented training plan for OHS. The plan lists the department to receive the training, the date, the topic, location and name of the person to provide the training. Accordingly, supervisors receive hazard awareness training. Workers receive training on hazards identification and control measures, general safety rules and housekeeping, accident prevention, MSDS and specific risk training (such as related to electrical safety, hot work, working in high temperature areas, loading and unloading) and that targeting instances of unsafe behaviors or conditions previously observed. In addition, training on malaria prevention and road safety is provided. Similar risk assessments and training plans will be developed for all the future facilities. This will be undertaken as part of the requirement to develop and implement a PS1-compliant ESMS in the ESAP. (ESAP # 1)

Despite the above measures, several instances of excessive noise without workers using hearing protection, poor construction safety oversight (unsafe practices observed as noted above) were seen during the site visits in Ghana, Senegal and Kenya, where enforcement of use of PPE could be better.  As recommended in the environmental audit report of October 2019 (that undertaken for the Kenya plant), Brightstar will enforce the use of PPE in all its plants.

  Resource Efficiency

The client has implemented various technically and financially feasible and cost-effective measures for improving efficiency in its consumption of energy, water, as well as other resources and material inputs for core business activities. Such practices involve rainwater collection and collection of waste process water and reuse in the production process after treatment. Similarly, sediments recovered from the process effluent is returned to the process after settlement and collection thereby reducing raw material inputs. Waste heat from the kilns, once discarded, is now captured and used in the drying kilns. Details are presented below.

Water and Wastewater

In Ghana and Kenya, raw water is sourced from borewells subject to review in impact assessments and receiving due regulatory permits.  For the existing operations, water abstraction from the aquifer constitutes a very small portion of the total availability, and hence, does not present any risk or adverse impact on the sustainability of water sources (for other users) due to the project. Water used in accommodations for human consumption is further treated to meet both local and WHO limits.

The total annual water consumption for the first phase in Ghana is 128,000 m3; that after completion of the second phase is projected to reach 237,000 tons m3. In Kenya, the operations used 294,000 m3 in 2018. In Senegal, the plant required a borehole to be drilled. The maximum flow rate of the borehole was permitted at 30m3/h. Total water use (that required for production and for workers, etc.) since the plant opened has averaged at about 600 m3/day. Once the amount of water that is recycled (plus that collected during rainfall events) is deducted from this amount, the net consumption is expected to be approximately 500 m3/day (i.e. approximately 70% of the total permitted yield of the borehole). As per the Water Code (Law No. 81-13 of 4 March 1981 and its implementing regulations), the company applied for authorization for the borehole. Upon investigation by the Ministers in charge of Hydraulics and Sanitation, and as noted above, the borehole was subsequently permitted. Information presented by the company to IFC reported that the company’s permitted maximum groundwater withdrawal from the aquifer through its one borehole represents 0.5% of the total yield of that aquifer.

Rainwater is collected from the roof of the factory, impounded in on-site reservoirs, and used to supplement raw water to be used in the production process (in addition to that returned from effluent settling ponds). At present, rainwater provides about 60% of production needs in Ghana and 30% in Kenya.

Effluent generated by the production process is collected, stored in a series of settling ponds (where it is decanted, flocculated, etc.), and the supernatant water after treatment is subsequently re-used in production. As such there is no process effluent discharge to the environment. The settled solids are pressed using filter press and the pressed mud cake is re-used in the production of tiles. Effluent from housing and other sanitary wastes are sent to septic tanks to be periodically cleaned by licensed vendors.

For future developments, as part of the development of any ESIA, Brightstar will ensure that adequate water is available from the designated source (groundwater aquifer/surface watershed) for the use by company in sufficient amounts, and that those amounts will not adversely impact other competing users including communities dependent upon that source in keeping with the requirements of PS 3, paragraph 9. This is addressed in ESAP Item #9. Similarly, the company will develop a standard procedure including technical designs for process wastewater treatment and recycling, for all future developments to ensure the current practices of reuse are put in place at such operations. (ESAP # 10)

Energy Consumption and Air Emissions

Kilns operate at 1,200º C and in Ghana are fed with natural gas from the national gas grid. Consumption of the first line “K1” is 0.92m³/m² of gas per m² of tile, while the second line “”K2” consumes 1.4 m³/m². Various practices have been put into place to reduce consumption; for example, gas consumption of kilns went l down by 20% due to waste heat from the kilns being supplied to the drying kilns. Likewise, waste heat from generators is used in the spray drying tower. Monitoring data shows compliance with WBG limits with regards to point source emissions. Energy usage for Ghana is about 2GWh/Month for production of 1.75M m²/month of times, so approximately 1.15 kWh/m²

There is no gas available for the Senegal operation. The company runs its own coal gasification plant to provide gas to fire the kilns. Current consumption is about 200T of coal per day, sourced from South Africa, with the expectation that 80,000T per year will be consumed once the 2nd line is up and running (i.e. an average of 220T/day for a whole year of operations). Waste ashes are currently recycled for road coating and brick materials. Power is provided by 14MW diesel generators fueled by heavy fuel oil (HFO). Monitoring of emissions from such sources has yet to commence given the startup of the plant was only a couple of weeks prior to appraisal; this is required by regulation and will be undertaken according to the required regulatory schedule. The company will report on required emissions monitoring in the AMR and will include results compared with WBG EHS guidelines and local norms and regulations.

Energy sources for the Kenya operations include 230T/day of coal sourced from Tanzania, an average of 2,750 KWH per month of electricity from the national grid and ten 450 KVA standby diesel generators. Emissions monitoring results reviewed by IFC showed compliance with NEMA limits.

Benchmarking by the company shows good performance regarding energy consumption in Ghana, Kenya and Senegal plants for many processes against industry benchmarks (including those contained in the Ceramic Tile and Sanitary Ware Manufacturing EHS Guidelines), such as for spray drying and other drying, once fired tiles, twice fired tiles, etc.

Energy consumption and air emissions management for the future facilities, will be assessed through the ESIA and necessary mitigation measures will be implemented.

Solid wastes

Non-hazardous wastes from the production process are re-used or used as inputs to other non-production-related processes. For example, waste powder, waste billet and waste glaze produced during production are recycled, some bricks are sold, and some are used for paving roads. In Ghana, recycled wastes used in the production process amount to some 15 tons per day; such recycling reduces raw material inputs and equates to annual savings equivalent to approximately $73K/year USD.

Empty paint cans, office waste, food waste, packing material, clay and maintenance waste such as PVC pipes, scraps and wires are typically generated on-site. In Ghana, such waste is collected by an approved waste collector for the area and disposed of at the Sofokrom Municipal landfill.  Scraps and other metal are sold to licensed vendors for use at the foundries located in Takoradi and Tema. Similar arrangements, but dependent upon local resources related to waste management, will be implemented for plants to be developed in other countries in the future.

Greenhouse Gas Emissions

The total gross GHG emissions of all six facilities to be supported in part by IFC’s investment (in operation and planned) are estimated at about 742,800 tons of CO2e, resulting from combustion of fuel for the process, consumption of electricity generated in the various countries hosting a plant, and auxiliary equipment, including trucks for transportation.

The company will continue to seek technically and financially feasible options to reduce project-related GHG emissions. Given the amount of CO2e estimated to be produced by the project, the company will quantify direct and indirect emissions from its facilities, owned or controlled, using internationally recognized methodologies and good practice, and report them to IFC on an annual basis in the AMR. 

 As part of the ESIA for its existing facilities, the company has evaluated the risks and impacts to the health and safety of members of the public that may be impacted by company operations. The main risks to the nearest communities (whose location varies between 1 and 3 km from the fence in existing project locations) are those associated with traffic (bringing in raw materials and transporting finished goods), fugitive dust and excessive noise. Note that trucks only drop off and pick up materials and goods; there is no overnight parking at the plants. To deal with impacts from moving traffic, traffic management and traffic-calming measures (road humps, barriers, etc.) have been implemented when trucks travel through built up areas found near to plants (e.g. in Ghana).

Likewise, involvement of other industries in the neighborhood in emergency preparedness has also been described above and the company is active in such dependent upon the location of the factory.

There is also minor risk of increased exposure of communities to communicable disease (from workers) as there is typically only a relatively small influx of labor associated with the projects (largely limited to Chinese nationals who often are accompanied by their families while on site and some local nationals who live too far from the plant to commute). For example, approximately 30 or so local nationals reside on premises in both Ghana and Senegal. There are no local nationals residing on the plant in Kenya.

Regarding the prevention of possible gender-based violence in interactions with local communities, especially during construction, the company will develop and implement a code of conduct that will be applicable to all employees and to workers engaged by contractors and subcontractors. It will include references to non-discrimination, sexual harassment and gender-based violence (GBV), and rules for interaction with the local population. This is addressed in ESAP item #11

Security Personnel

The company has unarmed security guards in place in Ghana, Kenya and Senegal plants for access control and emergency response. Employees are tasked to limit access to the sites and patrol the perimeter fence/walls and other buildings and facilities. In Ghana and Kenya, armed local police are also being utilized. The company will review its security arrangements at the existing plants, undertaking a risk assessment of such arrangements in accordance to the requirements of paragraph 12, 13 and 14 of PS4. This is addressed in ESSAP item #12. In addition, the company will develop and implement a framework considering the same requirements as above, for future operations, i.e. those to be in Cameroon, DRC, Zambia and Mozambique. This is addressed in the ESAP, item #13.

 With regards to Ghana, the Preliminary Environmental Assessment (PEA) identifies relevant stakeholders to assist in the identification of potential impacts and measures to mitigate such impacts. In addition, the company engages with communities in the larger project area. Some of these interactions stem from recruitment drives to hire people to work in the plant; others are more about information sharing and project awareness.

The ESIA prepared for the Senegal project describes the consultation process required as per national law. Meetings were advertised beforehand and were used to describe project specifics, risks, impacts, etc. National, regional and local stakeholders attended the meetings including those whose land was used for the project.

The Kenya Environmental Management and Co-ordination Act Cap 385 requires stakeholder identification and participation during the ESIA process and annual environmental audits. The company has engaged a community liaison officer and formed a community committee for regular engagement with the community and other stakeholders.  Most of community grievances are facilitated through corporate social responsibility program.  So far, the company has initiated Maisha bora scholarships for needy students, provided piped water for 70 households and constructed and repaired approximately 14 km of roads and its workforce is 30% from the local community.

Whereas the company has engaged with stakeholders and local communities as part of the risk and impact assessment process in Ghana, Senegal and Kenya, they will develop a formal approach to engagement and manage its implementation for future projects as part of the development of a PS1 compliant ESMS. It will encompass local norms and regulations as well as be responsive to the requirements of PS 1. This is addressed in ESAP item #16                                                   

Twyford (Senegal) Ceramics Co., LTD

Armin Zheng, Managing Director,

Phone: +221 771304010

Mail: armin@sunda.com

Address: Mermoz meteo, lot 10, Dakar, Senegal

www.twyfordtile.com/senegal.html

KeDa (Kenya) Ceramics Co., Ltd.

Yong Zhao, Assistant to Managing Director

Phone: +254-796-672962

adminkenya01@twyfordtile.com

Along Namanga Road, Opposite to Umma University, Kajiado County, Nairobi, Kenya

http://www.twyfordtile.com/kenya.html

KeDa Ghana Ceramics Company Limited

li wei, Managing Director

Phone: +233 546205786

lorry@sunda.com

behind ghana gas station, lower inchaban, shama district,western region, ghana

http://www.twyfordtile.com/ghana.html