The proposed site of the Rupshi mill is located within the secured premises of City Economic Zone (CEZ).  Land parcels for the establishment of the CEZ were procured by the Group from private landowners in 2002-03 on willing buyer-willing seller basis, which did not result in any involuntary physical or economic displacement. The license to operate the CEZ was granted by the Bangladesh Economic Zone Authority (BEZA). Procedural scrutiny prior to issue of license involved issuance of public notice (published in newspapers on 17th October 2017) by BEZA, seeking objections to declaration of private economic zone, if any. The license was accordingly granted through a gazette notification published on 18th January 2018. Accordingly, PS5 (Land Acquisition and Involuntary Resettlement) are not anticipated for this project. The site is in well-developed industrial areas. No presence of indigenous peoples or cultural heritage was identified. As such, PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), PS7 (Indigenous Peoples) or PS8 (Cultural Heritage) are not applicable.                                                

   This is a category B project according to IFC’s 2012 Policy on Environmental and Social Sustainability because a limited number of specific E&S impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Key environmental and social (E & S) issues associated with this project include: (i) the existence and implementation effectiveness of EHS management systems, (ii) assurance of fair, safe and healthy working conditions in compliance with local regulatory requirements and relevant Performance Standards during the construction and operation of the proposed mill; (iii) resource efficiency of the operations (mainly energy); (iv) life and fire safety management, including emergency preparedness and response plan; (v) structural and electrical safety for the proposed facility; (vi) engagement with the local communities; (vii) supply chain risk assessment of raw material sourcing.

  Environmental & Social risks and impacts. As per the applicable local legislation, RFML has secured an Environmental Clearance Certificate (ECC) for the proposed mill from the Department of Environment (DoE). As the project is in CEZ (owned and operated by City Group), the company will apply for final approval from BEZA before starting its commercial operation.

E&S Policy and Management Systems. RFML has an Environmental Health and Safety (EHS) Policy, which is in draft stage. As mentioned above, City Group’s subsidiary, Shampa flour mill (SFM), adjacent to Rupshi, is certified to Food Safety (FS) Management System Certification (FSSC 22000) and HACCP. RFML will also implement these FS management systems once the operation starts. City Group has yet to develop a formal corporate EHS management systems, but its subsidiaries have all adopted specific policies and procedures on fire safety, waste management, basic EHS training, HR management system, including compliance with local labor law. The corporate EHS policy and procedures will be approved by Group City and applied to the proposed facility. As set forth in ESAP#1, RFML will implement an Environmental and Social Management System (ESMS) to provide consistent oversight of environmental, social and health and safety (ESHS) for its operations. Performance-based requirements applying to this ESMS will include Bangladesh’s applicable legal and regulatory requirements and IFC Performance Standards. The ESMS will be communicated to all staff and contractors on Rupshi Intranet and induction session, including staff training. RFML will also define the environmental and social objectives, based on identified E&S risk assessment, and establish specific management programs during the construction and operation phase. Also, as set forth in ESAP#2, RFML will implement key procedures/management programs on the following risks: (a) Life & Fire safety (L&FS) and Emergency Preparedness and Response Plan (EPRP); (b) transport safety management; and (c) supply chain management policy.

E&S Organizational capacity and competency. RFML has yet to establish a formal EHS function to oversee the effective implementation of the ESMS. EHS is currently overseen by the HR function, with the technical assistance of external consultant. For OHS and security issues, there is an in-house security team. In addition, plant managers are responsible for enforcing EHS guidelines and inform HR for any discrepancies. 

City Group is planning to recruit a Group-level Sustainability Coordinator for managing its environmental, health and safety and social (EHSS) management systems. EHS/Sustainability organization chart showing reporting relationship between Group-level EHS function and Rupshi EHS function has been shared during appraisal. The Group will also appoint an EHS coordinator and medical staff for Rupshi flour mill.

As set forth in ESAP#3, RFML will then define its EHS functions, including the recruitment of an EHS coordinator, the definition of responsibilities and authorities for its EHSS management systems, including compliance with the yet-to-be developed City Group’s EHS policies and procedures, Bangladesh legal and regulatory requirements and IFC PSs to ensure consistency with good international industry practice (GIIP) performance. The EHS function will be responsible to deliver trainings, monitoring on EHSS performance, including reporting to City Group’s Board of Directors. It will also report Rupshi’s EHS performance to national authorities (e.g. BEZA, Department of Environment) and any external interested stakeholders.

Training records of Shampa Flour Mill (SFM) provided supportive evidences that periodic EHS/HR trainings are conducted covering relevant E&S topics, including new workers induction, emergency preparedness, first-aid, fire safety, security awareness, chemical handling, waste management, housekeeping, resource efficiency, worker’s grievance mechanism, harassment and abuse etc. Training records were noted to be maintained at the individual entities. Similar approach will be followed in RFML.

Emergency Preparedness and Response. The life and fire safety drawings for RFML has been approved by the local regulatory body, namely the Fire Services and Civil Defense. As RFML is in construction stage, emergency response is presently provided by its adjacent Shampa flour mill. As set forth in ESAP#4, RFML will develop and implement an Emergency Preparedness and Response Plan (EPRP), according to best industry (flour mill) standard. The EPRP will consider all potential emergencies, e.g. combustible dust explosion, fire, oil leakages, and describe detailed roles and responsibilities for relevant personnel (as well as their back-up), training needs and their frequencies and conduct emergency drills at defined intervals.

All working areas will be equipped with portable fire extinguishers which will be placed in easily accessible areas and marked for easy identification. All types of fire extinguishers will be labeled with user instruction and effective use period, as per recommendations of the local fire service and civil defense authority. Fire alarms with emergency lights would also be placed at appropriate locations. To prevent dust explosions, RFML has provided mitigation/maintenance measures, including aspiration system for dust. All machines are connected together in the air circulation system which sucks any dust into air jet filter. These air jet filters separate the dust from the air and send to screening bin.

Fire emergency exit plans will be displayed on every production floor. The entry and exit routes of the mill will be well marked and fitted with emergency lights. There will be provision for emergency staircase for emergency evacuation, besides the regular staircase. Any emergency medical requirement will be provided by City Group’s own hospital which is thirty minutes driveway from the plant.

SFM has already adopted a site-specific emergency preparedness plan, considering scenarios, such as fire, medical emergencies, bomb threats and natural disasters, like flood and earthquake. However, this plan does not cover all potential emergencies like combustible dust explosion, oil leakages and the responsibilities of individuals in case of an emergency.

EHS Monitoring and Review. City Group compiles legal EHS and HR compliance, through a legal register of its subsidiaries, including RFML. In order to extend this EHS/HR monitoring program to cover all E&S aspects internally against performance-based requirements, such as IFC Performance Standards, applicable WBG EHS Guidelines and GIIPs, as already indicated in ESAP#1, RFML will develop a Standard Operating Procedure (SOP) for quarterly/annual EHS/HR monitoring and reporting of key leading and lagging performance indicators (KPI) which will be submitted to City Group’s management team, including sustainability and EHS coordinator for review and corrective actions, as needed.

Supply Chain Risk Assessment and Management. City Group procures raw material (especially wheat) from international suppliers on a spot purchase basis in USA, Canada, Australia, Russia and Ukraine. As all the wheat production in these origins are based on consolidated agricultural lands and mechanically harvested, there are no significant supply chain risks.                                                  

   City Group employs about 15,000 employees across its 40 subsidiaries. SFM has a workforce of 146 employees (40 permanent and 106 temporary) out of which 72 are female. RFML will follow existing Group-level recruitment policy for hiring new employees. RFML is planning to add 200 additional permanent and temporary workers during operational phase.

Human Resource (HR) Policies and Procedures. City Group has adopted HR policies and procedures applicable to its staff, covering recruitment and selection, compensation and benefits, performance evaluation, transfer, training and development, disciplinary action, grievance redressal, restriction of forced labor and anti-discriminatory and equal opportunity policy. The policies are aligned with the objectives of IFC PS2 on labor and working conditions.

The Group has adopted a HR Policy Manual and “Employee Code of Conduct” through which the Group commits to prohibition of child labor, forced labor, bullying, sexual harassment, racial and religious vilification, occupational health and safety (OHS), grievance handling and redressal. As set forth in ESAP#5, RFML will develop and implement an HR management system and will also document specific policy on freedom of association and provide training to supervisors and managers and communicate the policy to the employees.

Working conditions and terms of employment. A contract is signed with every worker at the time of employment. The contract describes the working conditions and terms of employment. The worker is also provided with a copy of the contract. In addition, regular trainings are conducted explaining the provisions of Bangladesh Labor Act, working conditions and benefits provided during probation period, wage calculation, festival bonus, leaves etc. and basic instructions on OHS. Induction training is provided to new workers explaining the HR policies and procedures. The same HR policies and procedures and those discussed above (ESAP#5), are consistent with IFC PS2 requirements, will be implemented at RFML.

All employees at City Group receive a salary above the minimum national wage. The temporary workers are paid according to the contractual agreements (e.g. piece rate, hourly wages etc.) which are as per the industry standards. The attendance is recorded through biometric system. In City Group’s subsidiaries, working hours are 8 hours per day (6 days a week), and 3 shifts per day. Based on attendance records reviewed during appraisal, overtime hours at subsidiaries-level are within the legal limits and overtime is paid as per the legal requirements.

Dormitory for the male staff (~approx. 61 people) and staff quarter for 78 families is available near the project site. The company shall ensure that the facilities provided in the dormitory meet GIIP specifically complying to IFC/EBRD Working Accommodations Guidelines and life and fire safety systems (including fire extinguishers, adequate emergency exits) are in line with the Bangladesh National Building Code. Going forward, as set forth in ESAP#6, in the event of RFML hiring more than 40 female employees, RFM will provide a childcare facility in line with the requirements of Bangladesh Labor Act.

Non-discrimination, Equal Opportunity & Freedom of Association. City Group has a documented non-discrimination policy stating its commitment to non-discrimination based on gender, caste, religion, social status, and disability. City Group has zero tolerance policy for any form of sexual harassment in the workplace. The policy requires that all incidents and allegations of sexual harassment are treated seriously, and prompt investigations are conducted. Similar policies will be implemented in RFML. Based on appraisal findings, there has been no major labor related disputes or legal cases in the recent past. While there are no labor unions in City Group and/or subsidiaries, worker’s participation committees (WPC) have been formed at each subsidiary, which has elected worker representatives. These committee meets on a regular basis to discuss issues related to workplace conditions and improvement of facilities. Collective Bargaining Agreements (CBAs) are also discussed in these committees. A similar WPC will be formed at RFML. As stated above, a specific policy on freedom of association will be documented, implemented and communicated.

Protecting the Work Force. In line with its Code of Conduct, City Group has documented policies for prohibition of child labor and forced labor in its workforce. To avoid any use of child labor, verification procedures, such as age proof documentation (e.g. copy of National Identity Card) is collected at the time of recruitment of the worker. In absence of age proof documentation, age of the worker is verified through medical examination.

Grievance mechanism. City Group has a documented worker grievance procedure. Under the procedure, any workers can raise their grievances in writing to immediate supervisor/Head of the Department; and in case not resolved, grievances can be escalated to the management. As part of the ESAP#7, City Group will update its grievance handling procedure by making provisions of anonymous complaints and inform the employees about the availability of the procedure during workers (permanent/temporary) and contractor induction session.

 Impact of COVID-19 Pandemic on Workforce. Since City Group’s subsidiaries are considered essential food commodity manufacturer, COVID-19 has not disrupted City Group’s business operations. As such, all subsidiaries are running normally. City Group has not implemented any changes in terms of reduction of personnel, salary and benefit cuts, or changes to vendor contracts. Support is provided to employees through regular briefings and contingency measures for preventing COVID-19 risk in accordance with the Ministry of Health’s instructions and in allowing employees to work from home or remotely. Employees entering the factory premises are screened with infrared thermometers and provided with necessary personal protective equipment (PPE), such as face masks, gloves and sanitizers at their respective workplace. Employees who live in workers’ accommodation is also provided with PPEs and sanitizers.

Currently, there are about 20 expatriate employees in RFML Property and none of their work are suspended. Same protection and prevention measures are applied than local employees.

Workers Engaged by Third Parties. City Group has hired construction contractors for the construction of RFML. City Group has its own engineers and project managers who supervise the contractors’ work. Construction workers of RFML are provided with PPE like helmet, gloves, mask, gumboot, safety goggles, safety vest etc. to prevent any accident in the plant. Also, relevant govt. regulations like Bangladesh Labor Act is being followed. As set forth in ESAP# 8, RFML will develop a comprehensive EHS/labor guideline applying to its EPC contractors and will establish a monitoring/ verification mechanism to ensure its enforcement. In addition, City Group’s engineers will conduct EHS trainings to the workers at construction site. City Group will develop and implement the construction safety policy by specifying: (a) key aspects of safety organization on-site, new worker training, general safety, electrical and fire safety, dangerous works (e.g. working at heights, welding, excavation, covered under safety during construction), vehicle movement, storage of materials, accident/incident investigation and record keeping etc. (b) clear roles and responsibilities of company personnel for implementation on-site including communication to the contractors; (b) consequences of non-compliance for the contractors and their method of implementation; (c) clear accident/investigation procedures; and (d) documented internal safety inspections and audits.

Occupational Health and Safety (OHS). City Group has developed documented procedures for all its operations on electrical safety, chemical safety, dust safety in accordance with ISO 45001 which is still in the draft stage. Additionally, basic Do’s and Don’ts, Material Safety Data Sheets (MSDSs) and safety instructions, self-audit checklists, preventive maintenance checklists, accident/incident reporting formats have been prepared for all the operations, including the construction phase, which is in the draft stage. It was noted that no OHS risk assessment has been completed for operations. As set forth in ESAP#9, RFML will conduct an environmental and occupational, health and safety (EHS) risk assessment for the construction and operational phase of the flour mill. Based on this workplace risk assessment, RFML will prepare comprehensive OHS management plan with preventive and mitigation measures for the operations. As discussed in PS1 section and as set forth in ESAP#1, an EHS management program, consistent with ISO 14001 and ISO 45001 management systems, will be developed and implemented, as part of the ESMS. The program will be supported by regular training and communication covering all employees and contract workers.  City Group records the number of accidents and injuries. No fatalities, fire incidents or lost time injuries have been reported during the construction of RFML and in the other Group’s subsidiaries over the last three years.                                                 

   Resource Efficiency. The City Group’ Economic Zone (CEZ) will provide electricity, gas and water. To optimize energy efficient at RFML, the mill will install a natural air ventilation system designed by the Swiss supplier Buhler. The system will consist of central louver system at the top of the mill and several openings on each floor. The mill will also be using Premium Efficiency ranged IE3 motors. Majority of the power consumption in the mill would be by motors used for conveying, milling, cleaning, delivery, intake section of the mill. The mill will also be equipped with Yield Management System (YMS) which will help the management/miller to optimize the mill operation. As flour mill is a dry process, the water requirement in the production process is minimal. However, based on wheat quality, 2-3% water will be added which will be part of the product, as per local and international regulations.

Emissions and Wastewater. As per the ESAP#10, the group will identify air pollution control systems needed for the utilities for the proposed facilities and ensure their implementation within the required timelines. Also, as part of ESMS implementation (ref. PS1 section above), regular air quality and stack emissions monitoring will be conducted at the project’s facilities to ensure their compliance with applicable national and local standards and WBG EHS guidelines. Summary of these reports will be shared as part of the annual monitoring reports submitted to IFC. Similarly, RFML will also regularly monitor the stack emissions, heat and ambient air quality. The main water usage for RFML will be for domestic purposes which will be discharged into the central wastewater treatment plant of the CEZ. The main source of water at the facility will be on-site borewell. No process effluent will be generated.

Waste Management. The solid wastes generated by RFML’s daily operations will include papers, poly bags, water bottles, electrical and mechanical wastes, oil containers and chemical containers/bags. City Group has established standard procedure for disposal of waste. RFML will have a maintenance team who will regularly clean and collect solid wastes generated in the projects. Sufficient numbers of dustbins and sign board will be installed. Electrical and mechanical waste will be collected and stored in locked storeroom and will be disposed through approved waste disposal agencies. 

Management of hazardous chemicals and wastes. RFML will use hazardous material in the form of chemicals, lubricants, fuels, etc. SOPs are available to handle any unwanted incident with hazardous material. Any hazardous materials to be transported to or from the Project Site will include suitable protection (in the form of manufacturer / supplier recommended packaging or as stated in the relevant MSDS) to mitigate against any accidental release. Spill kits will be available to contain any accidental release of hazardous materials (including within vehicles when transporting hazardous materials). All materials recovered during clean-up operations will be stored in labeled and secured containers for further disposal to authorized agencies.

Greenhouse Gas (GHG) Emissions. The GHG emissions at the proposed facility will be from consumption of electricity from the captive power plant within CEZ. The estimated GHG emissions from the facility operations are estimated to be approximately 49, 589 tCO2 /annum (mainly direct emissions).

Pest control. Procedures under ISO 22000 address pest management and control in SFM. Licensed service providers are recruited to conduct rodent control. This activity includes inspection and maintenance. To control pest infestation, including final packing area, RFML will also use different kinds of pesticide. The chemicals and the target pests were provided during appraisal.                                             

    The proposed flour mill is located within the secured premises of City Group’s Economic Zone (CEZ). CEZ is situated in north corner of Rupshi Mouza (land revenue unit equivalent to village) where it is bounded on the east by Naogaon Mouza, on the west by Gandhabpur and Char Gandhabpur Mouza, on the west by Shitalakhsya river and to the south by Rupshi Mouza. Adverse impacts to surrounding communities are relatively remote, aside from induced increase in traffic.  As discussed in PS2 section and as set forth in ESAP#7, the grievance handling procedure will also include mechanisms for handling community grievances. City Group’s drivers go through background, basic health and license check-up before employment.

All security personnel are City Group’ employees. The security officers are not armed and are trained for defensive measures.                                       

   As part of its corporate social responsibility (CSR) initiative, the group undertakes several activities related to community development, education, infrastructure development providing medical support, supporting the sports association.                                                 

Contact Person: Tanvir Hydar Pavel {Director (Finance & Commercial)}

Company Name: Rupshi flour Mills Limited.

Address: “City House”, Plot # NW (J) 06, Road # 51,

Gulshan - 2, Dhaka -1212, Bangladesh

Tel: +880 2 9852356–60

Mobile: +880 1713 001227

Email: pavel@citygroupbd.com

Web: www.citygroup.com.bd