While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS 5 - Land Acquisition and Involuntary Resettlement
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources

This is a Category B project according to IFC’s 2012 Policy on Environmental and Social Sustainability due to limited and site-specific E&S risks and impacts associated with the expansion of the existing feed mill and the construction of new silos. These can be avoided or mitigated by adhering to recognized Good International Industry Practices (GIIPs). Key E&S risks and issues for this investment are: (i) identification and management of E&S risks and impacts during the expansion of the feed mill and the construction of the new storage facilities; (ii) fair treatment and safe working conditions for employees and contractors, including implementation of HR policies and procedures aligned with PS2 requirements; (iii) emergency preparedness and response; (iv) resource efficiency and GHG emissions; management of dust and noise; (v) community safety, traffic and use of security forces, including implementation of a feed safety management system; (vi) habitat conversion risk in primary production sourcing regions raw materials; and (vii) management of PS 5 risks related to government led acquisition of at the proposed site for the construction of storage capacity.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts

E&S Policy. AKF does not currently have an E&S policy, although a basic OHS Policy that applies to workers and contractors is in place and a Supplier Code was recently adopted. AKF will develop/revise and implement corporate policies (Environmental, OHS, and Supplier Code) to align its E&S performance against IFC PS requirements for its feed mill, silos and raw material sourcing. Specifically, the policies/Code will be aligned with the nine elements of PS1 requirements and will address PS gaps as per ESAP#1 below. These policies will be availed and communicated to all AKF staff, contractors and service providers during worker induction sessions. Annual audits (including regulatory external audits) of implementation effectiveness will be carried out (ESAP#1).

Identification of Risks and Impacts. An ESIA study was prepared for the feed mill in 2007 according to Ethiopian E&S regulatory requirement prior to its commissioning in 2009 and was approved by the Oromia Environmental Protection Office in 2007. There is no regulatory requirement for an additional ESIA study and/or addendum of the 2007 study for the proposed feed mill expansion. Nevertheless, AKF will develop and implement a PS-compliant procedure for identifying and assessing risks and impacts of the proposed expansion (ESAP#2a). For the proposed storage facilities to be constructed, AKF will undertake a PS-compliant ESIA study (ESAP#2b).

E&S Management Systems and Programs. AKF have started the development of an E&S Management System (ESMS), such as EHS training, emergency preparedness and response, monitoring/reporting framework. As part of ESAP #1, AKF will apply (i) the E&S risk procedure developed under ESAP #2, to its proposed expansion program; and (ii) the environmental and social management plan developed under the ESIA for the proposed storage facilities, to inform the development of its environmental, health and security, feed safety and social (EHSS) management system and document the related plans and procedures for current and additional operations under the project. The EHSS will incorporate all AKF operations and will be aligned with Good International Industry Practices (GIIPs), especially for resource efficiency, ambient air emissions (dust), noise, solid/hazardous waste, hazardous material (fuel) storage, feed safety, traffic safety, security, contractor/supplier management and community engagement. AKF will also develop a legal register for tracking compliance with local E&S permits, licenses and approvals.

Organizational Capacity and Competency. AKF has not yet established an E&S organizational structure at Group and operation-level for the development and implementation of the ESMS. AKF employs a Quality Manager and a quality team, responsible for the maintenance of the Feedd Safety Management System (FSMS) at the feed mill and the company is in the process of establishing its Quality Environment Health and Safety (QEHS) organizational structure. AKF has recently engaged an OHS Officer who is receiving OHS training (e.g. NEBOSH or similar). The Company will appoint a qualified E&S Officer whose responsibilities will include: (i) the development and implementation of the ESMS; (ii) oversight of continuous legal and regulatory compliance of all AKF operations; (iii) E&S risk assessment / audit for existing and proposed operations; (iv) development of EHS SOPs and management programs; (v) enforcement of contractors’ E&S provisions; (vi) stakeholder engagement plans and community grievance mechanism. Monitoring and reporting on environmental and OHS Key Performance Indicators (e.g. leading/lagging indicators, energy/water use and efficiency, dust and noise management, waste management) and the Feed Safety Management System will be under the responsibilities of the Production Director and the Quality Manager respectively. The raw material sourcing, including the traceability and risk screening of local grain suppliers will be under the responsibility of the Purchase Manager. The oversight of HR management and worker welfare will remain under the existing HR Manager.

EHS Training. Training program and curriculum on first aid, fire prevention and occupational health and safety is provided annually through licensed government service providers. Following the various EHS risk identification processes (including work-station risk assessments) to be developed as part of the project ESAP, AKF will develop and implement an EHS training plan (ESAP#4). Training service providers will be engaged to deliver training on specific topics (e.g., emergency preparedness, first aid, supply chain risk screening).

Emergency Preparedness and Response. AKF has a basic firefighting system, fire evacuation, and accident and emergency procedures, but do not have a formal Emergency Preparedness and Response Plan (EPRP). The feed mill is equipped with 27 fire extinguishers, which are inspected every six months, and a number of fire hose reels. In 2022, AKF engaged the services of a consulting firm to design water storage and distribution systems and fire protection systems to local and international codes of practice. This corrective plan, yet to be implemented, comprises fire hose cabinets, fire hydrants, a fire water tank, water distribution systems, and fire extinguishers, including in key locations such as storage areas, the production floor, and the generators.

Dust associated with grain handling and processing presents an explosion and fire risk. AKF has installed dust collection systems in various sections of the feed mill from silo intake to storage of the finished product and has temperature sensors and cooling fans within each silo. AKF has not yet commissioned an ATEX review of installed equipment and protective systems by an external specialist. To incorporate management of explosion risk, AKF will commission an ATEX review and implement the necessary engineering controls and operational procedures to prevent dust explosion. As a minimum, these should cover housekeeping procedures to avoid dust accumulation, hot work permit system, safe electrical equipment in areas at risk, use of spark proof materials, explosion vents in silos, and a program for maintenance of grounding & bonding for the prevention of accumulation of static charges (ESAP #5).


AKF will also complete a hazard risk assessment of the types of emergencies it may be exposed to and develop/implement site specific EPRPs. The EPRPs are expected to cover power outages, fire, explosion, flooding, workplace accidents, security threats and suspected sabotage. AKF will subsequently install and maintain appropriate emergency response systems (alarms/detectors, appropriate firefighting equipment, etc.) and integrate expert training by an external service provider and appropriate drills into its updated Training Plan (ESAP#5).

EHS Monitoring and Review. The Bishoftu Environmental Protection Authority conducts annual inspections (with no prior warning) of the AKF feed mill and provides verbal feedback. AKF also undertakes annual environmental audits and reports on its E&S performance (e.g., employee diversity, GHG emissions) on an annual basis to De Heus senior management, via a dedicated monitoring dashboard developed by De Heus. As part of ESAP #1, AKF will expand the EHS/HR monitoring and reporting to include KPIs per applicable PS and WBG EHS requirements to AKF operations. This will include, but not be limited to, implementation effectiveness of the ESMP, corrective actions resulting from E&S audits, EHS SOPs and management programs, emergency preparedness drills, OHS leading and lagging indicators (including accident statistics), resource efficiency (energy/water use and efficiency), ambient air quality (dust) and noise, and grievances from workers and external stakeholders. AKF will comply with all reporting requirements mandated by the regional environmental agency (ESAP#1).

Supply Chain. Over one-third of AKF’s raw materials, including the majority of soy, wheat and barley, are food processing by-products (e.g., oil cakes, brewer’s yeast, rice bran, undersized barley) sourced from factories. The majority of the raw materials (e.g., maize, sunflower) are sourced from local traders who in turn, source from thousands of small farmers across Ethiopia. Vitamins and other micro-ingredients are imported from abroad or purchased from local importers.

. At the time of appraisal, the company had no visibility over its upstream supply chain beyond the traders, agents and factories and IFC could only undertake a regional contextual assessment of PS 2 and PS 6 risks.

AKF will develop a supply sourcing strategy to increase the proportion of raw material sourced from areas determined to be low risk for habitat conversion. Potential avenues to increasing the raw material supply include purchase of additional volumes from traders and agents who source from lower risk areas, and exclusion of suppliers situated in areas considered to be high risk for habitat conversion. In the long term, AKF will also seek to strengthen their sourcing strategy, which includes exploring working directly with traceable commercial farms.

AKF is in the process of adopting the De Heus Socially Responsible Sourcing policies and principles as Supplier Code (https://www.deheus.com/about-us/our-business-principles/supplier-code-of-conduct). The newly developed AKF Supplier Code provides for AKF’s right to verify compliance of the E&S provisions of this Code. However, the risk screening and internal verification procedures to farm level and the traceability systems to raw materials producers are yet to be developed or rolled out.

AKF will update its Sustainable Procurement Policy and Supplier Code to align its supply chain performance requirements with PS6 requirements, including a commitment to no conversion of natural habitat in the supply chain. AKF will include PS2 and PS6 related clauses in supplier contracts and provide training programs and workshops to help staff and suppliers understand and implement PS2 and PS6 requirements effectively. AKF will commit to meeting PS2 and PS6 requirements for its directly contracted suppliers (warehouses, transporters and directly engaged commercial farms). AKF will commit to a strategy aimed at obtaining the majority of their primary production supply from areas at low risk of habitat conversion by 2029. (ESAP#2c).

Additional requirements to meet under PS2 and PS6 requirements are discussed in the specific sections below.

PS 2 – Labor and Working Conditions

AKF has a workforce of around 320 staff (14% women) at its feed mill and storage facilities. About 48% (280) of this workforce are outsourced workers engaged through the regional government local community employment program that sources unskilled staff from local enterprises for loading/unloading tasks. AKF also engages contractors to provide ad-hoc maintenance services and other minor works. The company will hire an additional 30 staff at the feed mill and storage facilities as well as additional field staff for its grain sourcing operations.

Human Resource Policy and Procedures. AKF has HR Policies and Procedures documented in an HR and Company Regulations Manual, a Recruitment and Selection Policy and a Benefits Package Rules and Regulations. The company will implement the De Heus Speak Up Policy and the De Heus instruction guide for monitoring of HR related indicators. These policies and procedures are broadly aligned with the Ethiopian Labor Code and PS2 requirements, except for the gaps identified below.

Working Conditions and Terms of Employment. AKF provides open-ended and term contracts for staff in accordance with the Ethiopian Labor Code. The company policies define the working hours which include a three-shift system for some of the production staff. The shift system is organized into working groups to facilitate compliance with local requirements for overtime, rest days and annual leave. The HR manual and the Benefits Package Rules and Regulations outline AKF terms to include pay, overtime pay and deductions as per local labor law requirements (social security and taxes); medical cost-reimbursement and PPE issuance policies; salary review, production, performance and bonus criteria for applicable job categories; attendance allowance, per diem, transport, cellphone communication and meal subsidies. Staff are informed of these terms and conditions at workers’ induction session.

Non-discrimination and Equal Opportunity. AKF policies and procedures provide guidelines and mechanisms to facilitate observance of the company non-discrimination and equal opportunity commitments throughout worker engagement from job advertising and recruitment up-to termination.

Workers Organization. AKF’ HR policies allow for freedom of association and formation of workers associations. At the time of appraisal, none of the AKF workers were unionized. Nonetheless, should the need arise in future, the HR Manual already outlines the procedure for collective bargaining, including the process for registration of a Collective Bargaining Agreement (CBA) as per local labor law requirements. The outsourced workers are also organized into an association under the government program for small and micro-enterprises.

Protecting the Workforce. AKF’s HR polices align with Ethiopian laws which prohibit child labor and forced labor. The minimum age of employment at the AKF feed mill and storage facilities is 18 years, and all job applicants are required to present proof of age in the form of an identification card. Child labor, forced labor and OHS risks in the supply chain are covered below.

Worker’s Grievance Redress Mechanism (GRM). AKF has a documented workers’ GRM procedure that allows for expeditious address of workers’ grievances with explicit commitment to non-retaliation for logging a complaint or participation in the procedure. The GRM allows for informal and formal hearing processes, representation of involved parties, escalation mechanisms and mechanisms for collective grievances. AKF has no specific platform or mechanism for receiving and handling anonymous complaints, but they intend to establish one based on the De Heus speak up policy provisions. In addition, the project level workers’ GRM does not have additional or specific measures in place for dealing with grievances related to gender-based violence (GBV), sexual harassment and/or general harassment in the workplace. The company will review and update its GRM policies and procedures to ensure alignment with IFC requirements and guidelines on anonymous reporting as well as prevention and management of general harassment, sexual harassment and GBV risk/related complaints in the workplace (ESAP#6). The updated workers’ GRM will be communicated to workers through sensitization and training activities.

Occupational Health and Safety. Key OHS risks of the feed mill and grain storage operations are related to lifting of heavy loads and related physical activity/movements, working in confined spaces, working at height (e.g. silos), hot works (especially in the proximity of grain dust), fire and explosion, noise emissions, air quality (including continuous exposure to grain dust), electrical installations, and road transport/logistics. AKF health and safety (H&S) policy includes commitments to the health, safety and welfare of all employees, clients, visitors or contractors working on premises under the company’s control and of all others affected by its activities. As a result of these commitments, the company established an H&S Committee and appointed fire marshals and first aiders that are appropriately trained to undertake their tasks. AKF also undertakes H&S training as part of its staff induction, as well as annual training on H&S related topics for production staff including first aid, fire safety, and risk assessment. Performance reviews for area managers also include KPIs in housekeeping, proper use of equipment/working materials, communication with staff and overall safety. In the event of incidents and accidents, AKF provides reimbursements for medical costs and provides free evacuation services to the nearest health facility in the event of a medical emergency. The company also undertakes fitness to work examinations at induction. In addition to the EPRP discussed under PS1, AKF will develop an OHS Program as informed by appropriate OHS risk assessments encompassing both its current and proposed operations, in accordance with IFC PSs requirements and WBG EHS Guidelines. The program will have provisions for operation/site specific risk registers and management plans commensurate to the level of OHS risk to workers, including management/monitoring of outsourced workers and contractors’ staff on company premises. AKF will upgrade its accident and emergency procedure to incorporate incident reporting and investigation procedures and reporting systems. The OHS program will be supported by an upgraded worker training program, worker exposure monitoring (see PS3 section below), an annual health check-up for staff exposed to occupational diseases in the workplace (e.g., noise and dust), and an appropriate OHS corrective action & performance improvement program (ESAP#7).

Third Party Workers. AKF outsources its unskilled staff through a renewable 6-month agreement with the local youth enterprise registered under the regional government local employment program. Engagement of this youth enterprise is a regional government requirement for industrial and manufacturing companies in the Oromia region. The youth enterprise typically sends a variable number of workers to the company to load and offload materials. The group rate is typically set by the regional government to ensure a similar pay rate as other enterprises working with other companies in the region. Once on the premises, there is no discrimination between outsourced and company staff with regard to accident and incident responses, OHS training and welfare services (meals, sanitation, drinking water). The outsourced workers also have access to the AKF worker GRM. AKF will develop a procedure to monitor the youth enterprise compliance with local labour laws and PS 2. The company will also develop an outsourced labor policy and develop labor compliance clauses aligned with PS 2 requirements (ESAP#8).

AKF will engage a contractor for equipment installation and civil works for the project. As part of ESAP #8, AKF will develop a project specific contractor management plan to facilitate monitoring and audit of the contractor(s) E&S performance, as well as close out of corrective actions in accordance with PS2 requirements.

The contractor(s) for expansion works is yet to be selected. As part of ESAP #8, AKF will ensure that the necessary contractual clauses are included in contracts, stipulating the environmental, labor and OHS measures and controls that will be enforced during construction activities.

Supply Chain. Ethiopia has a contextual child labour (CL) risk in agriculture in general, with a comparatively higher risk profile in rural Ethiopia. OHS risks are also expected at farm level while poor OHS performance is expected in factories and possibly aggregator warehouses, especially for enterprises that rely on workers contracted from local youth enterprises. ESAP #2c (above) describes measures that AKF will take to align supply chain management with the PS 2 requirements for supply chain workers. As part of ESAP #2c, AKF will undertake supplementary child labour risk assessments at regional level and establish systems for reporting breaches of AKF’s Supplier Code of Conduct including child labor, forced labor, and life-threatening OHS risks among its Tier I suppliers (warehouses, factories, commercial farms). AKF will undertake training of its current aggregators and suppliers on PS 2 requirements for identifying, responding to, and remediating child labor risks/cases in the supply chain, including large-scale suppliers.


PS 3 – Resource Efficiency and Pollution Prevention

Resource Efficiency (Energy / Water). The site is connected to the national electricity grid, with two diesel-powered back-up generators (0.85 MW and 0.28 MW), which are only used during power outages. There is one boiler (1.1 MW) used for generating hot steam and used as part of the production process, which is also diesel-powered. Energy consumption is not expected to significantly increase with project expansion.

Water. Water is sourced from a deep borehole at the plant site and consumption is recorded. As the feed mill is a dry process, water consumption is low at 28,800 m3/year. Water supply for the new site is not currently defined, but water use is expected to be very low (domestic needs only). Water is primarily used for steam production, cleaning of machinery and the plant in general, and domestic purposes (toilets). Stormwater is managed via a recently upgraded site stormwater system and is discharged to municipal drains. Drainage around grain silos was designed to cope with floods. The site is located at a higher elevation than most of Bishoftu town.

Air Emissions and Noise. The main source of air and noise emissions from AKF feed mill and grain storage operations are from raw material/product transportation, dust generation and noise associated with grain handling/processing activities, and emissions from use of the boiler and back-up generators (the latter only during power outages, used approximately 500 hours per year). AKF has installed dust collection systems throughout the feed mill from silo intake to storage of the finished product. AKF does not currently carry out air quality monitoring; AKF will conduct ambient and occupational air quality monitoring to verify the efficacy of dust collection systems and, in case of exceedances, propose any additional mitigation measures (e.g. in the truck loading/unloading areas) (ESAP#9). Noise monitoring conducted as part of an E&S audit in February 2022 indicated noise levels of 85-86 dBA within the facility, which are below national standards (90 dBA), but at or just above WB EHS Guideline levels (85 dBA) for occupational exposure at the feed mill and packing areas (all other areas monitored were below WBG Guideline values), while ambient noise monitoring in nearby residential areas has not been carried out. AKF will conduct ambient and occupational noise monitoring and implement mitigation measures based on monitoring results (ESAP#10).

Greenhouse Gases (GHG) emissions. AKF quantify their GHG emissions. Annual Scope 1 emissions are estimated at 582 tons of CO2-equivalent, while Scope 2 emissions are zero (hydropower grid electricity), thus falling well below the 25,000 tons of CO2-eq GHG accounting threshold. Scope 3 emissions are estimated at 157,643 tons CO2-eq. De Heus has company-wide plans to reduce GHG emissions, although a specific target has not yet been set for AKF.

Waste Management. AKF operations generate lastic bags, metal scraps and organic waste from the canteen. Waste is segregated and plastic and metal are recycled, while organic wastes go to landfill. Limited quantities of used lubricants (grease, oil, and solvents), office waste (paper and ink cartridges), disposable PPE (e.g. masks, gloves) are also generated. AKF will formalize their waste management processes into a waste management plan, which will reflect the company’s commitment to reduce the impact of its feed mill operation through proper disposal of its waste streams. The waste management plan will include waste sorting and storage, record-keeping, disposal of waste via government-accredited service providers, periodic review of service providers, and evaluating alternatives to disposal such as composting of organic wastes (ESAP#11).

Wastewater treatment. Feed mill is a dry production process and thus does not generate wastewater. Domestic wastewater is collected in septic tanks on-site and regularly emptied by the municipality.

Hazardous Materials. Hazardous materials include diesel fuel for the on-site generators, and minimal quantities of lubricants associated with machinery and chemicals in the quality laboratory. Diesel fuel is stored in a 4000 L aboveground storage tank (AST) which is located on a covered concrete slab. AKF plan to install additional fuel storage in the future to increase storage capacity. Appropriate pollution prevention measures will be required for existing and any future tanks i.e. secondary containment for AST; risk assessment, secondarily contained (double-walled) tanks and piping and continuous leak detection system (interstitial monitoring), monitoring well, leak response procedure etc. for any underground storage. (ESAP#12).

Pesticide Use and Management. AKF have a basic procedure relating to rodent control, indicating that the feed mill must be kept clean and that poisoned bate is only to be used in areas free of raw materials/finished products. AKF will enhance this procedure by developing an Integrated Pest Management (IPM) plan, which will describe pest control and prevention procedures to fight rodents and insects at the feed mill and storage facilities. This will entail implementing an integrated management approach for maintaining a clean environment inside the facility (by preventing the accumulation of organic matter and removing all waste immediately), preventing entry (screened windows and keeping doors/windows closed), monitoring and repairing all potential cracks in walls, and keeping the exterior of the plant clear of vegetation. Pest control devices will include the use mechanical traps inside the feed mill. AKF will ensure the existing rodent control service provider adheres to this procedure and undertakes regular monitoring of traps to identify early on the potential need for more aggressive pest treatment (ESAP#13).

PS 4 – Community Health, Safety and Security

Community Health and Safety. The feed mill and road transport are the main components that may raise community health and safety risks. The feed mill is located in an area zoned for industrial activities and current land uses in the immediate vicinity of the AKF premises are predominantly industrial. Previous E&S audits did not record any complaints from the community on noise and air emissions (dust, particulate matter or odor). Nonetheless, as indicated in PS3 section above, AKF will establish KPIs to inform the performance of its noise and air quality management plans.

Road Safety. AKF’s vehicle fleet consists mainly of pick-ups and trailers for delivery of product and buses for transportation of staff. The company has procedures in place for vehicle maintenance and due diligence on drivers’ qualifications, permits to drive and basic good conduct background checks. As discussed under PS1 section above, AKF will review and improve its emergency response procedures to incorporate management of road safety risks, including accidents involving the local community.

Life and Fire Safety. As indicated under PS1 section, AKF will improve its fire safety management practices, including the emergency preparedness and response planning to cover fire and explosion risks from its feed mill and grain storage operations. For the new warehousing and storage facilities, AKF will develop a site-specific fire safety program and integrate the fire emergency response procedures into the site specific emergency response plans.

Security Personnel. Security personnel on AKF premises are direct employees. The company will undertake an assessment of the risks and impacts on communities due to the project’s use of security personnel. Based on the assessment findings, AKF will develop a Security Management Plan that will incorporate: (i) a security staff Code of Conduct, (ii) guidelines on appropriate use of force and use of firearms, (iii) training on AKF’ human rights commitments, and (iv) community grievance channel to address any community complaints related to AKF security personnel (ESAP#14).

PS5- Land Acquisition and Involuntary Resettlement

AKF is yet to identify the land that will be leased for the warehousing facilities. The land leasing process will be undertaken by the Regional Land Office in accordance with Ethiopia’s land acquisition and allocation laws and procedures. AKF will incorporate a PS 5 aligned assessment of land acquisition risks (if any) into the site ESIA. The ESIA findings will determine any additional support needed by AKF to meet PS 5 requirements. (ESAP#15).


PS6- Biodiversity Conservation and Sustainable Management of Living Natural Resources

AKF’s primary raw materials in terms of volume are corn (approx. 40,000 tonnes annually), soy by-products (residual sources of soy cake, defatted soya; raw soya beans) (approx. 14,000 tonnes), wheat bran (approx. 9000 tonnes) and residual undersized barley (approx. 5,000 tonnes). The majority of corn, soybean, wheat and barley grown in Ethiopia is produced in western, central and southern Ethiopia (primarily Oromia and Amhara regions) which is a region of concern for natural habitat conversion. The appraisal identified agri-commodity supply chain risks in terms of risk of conversion of natural/critical habitat in these regions. There is also potential for overlap of production areas with protected and/or internationally-recognized areas, however, the company currently has no visibility of the geographical sourcing areas of its supply chain beyond purchasing centers, which include traders, agents and factories. The supply areas around purchasing centers at the aggregator/warehouse level have been categorized into high, medium and low risk for natural habitat conversion using satellite-derived land cover change data. The capacity to ground-truth conversion risk in supply areas is limited, due to lack of farm-level traceability, and security risks in some areas AKF will develop a supply chain risk assessment and verification procedure detailing the approach to verify areas of lower risk in high-security-risk areas, and ground-truthing land use in areas of low security risk (ESAP#2c). Smaller Suppliers from medium-high risk areas will be excluded from future sourcing, and AKF will work with larger suppliers to identify areas of lower risk through more detailed risk analysis methods (e.g. GIS analysis of land cover change from remotely sensed imagery) and shift sourcing to these areas. AKF will also directly contract private farms in consolidated agricultural landscapes which can comply with AKF’s full traceability requirements to account for approximately 10% of their supply.

ESAP#2c (above) describes measures that AKF will take to align supply chain management with the PS1 and PS 6 supply chain requirements.

AKF has developed a stakeholder engagement approach as informed by local environmental law and its own customer engagement policies and procedures. Direct consultations with communities and industrial neighbors are undertaken during the preparation of the ESIA studies and EHS audits undertaken for licensing and permitting purposes. AKF will develop and implement a formal Stakeholder Engagement Plan (SEP) at its feed mill and grain storage facilities. External communication procedures and community grievance mechanism will be integrated into the SEP. The grievance mechanism will be equipped to handle complaints and feedback from known and anonymous members of the surrounding community. It will also allow for specific measures for identification and management of complaints related to gender-based violence and sexual harassment (GBV&SH) for community members who interact with project staff and where necessary, extended to respond to such complaints related to its principal contractors and raw materials suppliers (ESAP#16).

Company Name: Alema Koudijs Feed PLC
Point of Contact: Piet Schutter
Address: Ziquala Road, Bishoftu, Ethiopia
Email:piet@alemakoudijs.com

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	AKF will develop/revise and implement corporate policies (Environmental, OHS, and Supplier Code) to align its E&S performance against IFC PS requirements for its feed mill, silos and raw material sourcing. Specifically, the policies/Code will be aligned with the nine elements of PS1 requirements and will address the identified PS gaps as provided in the ESRS.These policies and procedures will be availed and communicated to on-site AKF staff, contractors and service providers during worker induction sessions. Annual audits of implementation effectiveness will be carried out. The company will develop and implement an environmental, health and security, food safety and social (EHSS) management system and document the related plans and procedures. The EHSS will incorporate all AKF operations and will be aligned with Good International Industry Practices (GIIPs), especially for resource efficiency, ambient air emissions (dust), noise, solid/hazardous waste, hazardous material (fuel) storage, food safety, traffic safety, security, contractor/supplier management and community engagement. AKF will also develop a legal register for tracking compliance with local E&S permits, licenses and approvals.AKF will expand the EHS/HR monitoring and reporting to include KPIs per applicable PS and WBG EHS requirements to AKF operations. This will include, but not be limited to, implementation effectiveness of the ESMP, corrective actions resulting from E&S audits, EHS SOPs and management programs, emergency preparedness drills, OHS leading and lagging indicators (including accident statistics), resource efficiency (energy/water use and efficiency), ambient air quality (dust) and noise, and grievances from workers and external stakeholders.	03/31/2027
2	AKF will develop and implement a PS-compliant procedure for identifying and assessing risks and impacts of the proposed expansion.	10/31/2026
3	AKF will undertake an ESIA study for the proposed storage facilities in accordance with PS and WBG EHS Guideline requirements. The ESIA Report will include the construction phase environmental, health, safety and social management plan (CEHSSMP) that will be implemented and overseen by a qualified E&S officer.	10/31/2026
4	AKF will update its Sustainable Procurement Policy and Supplier Code to align its supply chain performance requirements with PS6 requirements, including a commitment to no conversion of natural habitat in the supply chain. AKF will include PS2 and PS6 related clauses in supplier contracts and provide training programs and workshops to help staff and suppliers understand and implement PS2 and PS6 requirements effectively. AKF will also undertake supplementary child labour risk assessments at regional level establish systems for reporting breaches of AKF’s Supplier Code of Conduct including child labor, forced labor, and life-threatening OHS risks among its Tier I suppliers (warehouses, factories, commercial farms). AKF will undertake training of its current aggregators and suppliers on PS 2 requirements for identifying, responding to, and remediating child labor risks/cases in the supply chain, including large-scale suppliers. AKF will commit to achieve PS2 and PS6 compliance of its directly contracted suppliers. AKF will commit to a strategy aimed at obtaining the majority of their primary production supply from areas at low risk of habitat conversion by 2029. AKF will develop a supply chain verification procedure detailing approach to identify areas of lower risk and ground-truthing land use in areas of low security risk.	08/31/2027
5	AKF will hire a suitably qualified E&S Officer on a full-time basis reporting directly to AKF’s General Manager and establish an E&S risk and impact management function within the company. The E&S Officer’s responsibilities will include: (i) the development and implementation of the ESMS; (ii) oversight of continuous legal and regulatory compliance of all AKF operations; (iii) E&S risk assessment / audit for existing and proposed operations; (iv) development of EHS SOPs and management programs; (v) enforcement of contractors’ E&S provisions; (vi) stakeholder engagement plans and community grievance mechanism. Monitoring and reporting on environmental and OHS Key Performance Indicators (e.g. leading/lagging indicators, energy/water use and efficiency, dust and noise management, waste management) and the Food Safety Management System will be under the responsibilities of the Production Director and the Quality Manager respectively. The OHS Officer will receive OHS training (e.g. NEBOSH or similar)	07/15/2026
6	Development of a Staff Training Plan covering improvements in E&S Management Plans, Programs and Procedures.Training service providers will be engaged to deliver training on specific topics (e.g., emergency preparedness, first aid, supply chain risk screening).	03/31/2027
7	AKF will commission an ATEX review and implement the necessary engineering controls and operational procedures to prevent dust explosion. As a minimum, these should cover housekeeping procedures to avoid dust accumulation, hot work permit system, safe electrical equipment in areas at risk, use of spark proof materials, explosion vents in silos, and a program for maintenance of grounding & bonding for the prevention of accumulation of static charges	03/31/2027
8	AKF will complete a hazard risk assessment of the types of emergencies it may be exposed to and develop/implement site specific EPRPs. The EPRPs are expected to cover power outages, fire, explosion, flooding, workplace accidents, security threats and suspected sabotage. AKF will subsequently install and maintain appropriate emergency response systems (alarms/detectors, appropriate firefighting equipment, etc.) and integrate expert training by an external service provider and appropriate drills into its updated Training Plan.	03/31/2027
9	The company will review and update its GRM policies and procedures to ensure alignment with IFC requirements and guidelines on anonymous reporting as well as prevention and management of general harassment, sexual harassment and GBV risk/related complaints in the workplace. The updated workers’ GRM will be communicated to workers through sensitization and training activities.	03/31/2027
10	AKF will develop an OHS Program as informed by appropriate OHS risk assessments encompassing both its current and proposed operations, in accordance with IFC PSs requirements and WBG EHS Guidelines. The program will have provisions for operation/site specific risk registers and management plans commensurate to the level of OHS risk to workers, including management/monitoring of outsourced workers and contractors’ staff on company premises. AKF will upgrade its accident and emergency procedure to incorporate incident reporting and investigation procedures and reporting systems. The OHS program will be supported by an upgraded worker training program, worker exposure monitoring (see PS3 section below), an annual health check-up for staff exposed to occupational diseases in the workplace (e.g., noise and dust), and an appropriate OHS corrective action & performance improvement program	08/31/2027
11	AKF will ensure that the necessary contractual clauses are included in construction contracts, stipulating the environmental, labor and OHS measures and controls that will be enforced during construction activities.AKF will develop a project specific contractor management plan to facilitate monitoring and audit of the contractor(s) E&S performance, as well as close out of corrective actions in accordance with PS2 requirements.	10/31/2026
12	AKF will develop a procedure to monitor compliance with local labour laws and PS 2 by the youth enterprise providing outsourced workers for loading/unloading materials. The company will also develop an outsourced labor policy and develop labor compliance clauses aligned with PS 2 requirements.	12/31/2026
13	AKF will conduct ambient and occupational air quality monitoring to verify the efficacy of dust collection systems and to identify the need for any additional mitigation measures.	12/31/2026
14	The company will conduct ambient and occupational noise monitoring and implement mitigation measures based on monitoring results.	12/31/2026
15	AKF will formalize their waste management processes into a waste management plan, which will reflect the company’s commitment to reduce the impact of its operations on the environment through proper disposal of its waste streams.The waste management plan will include waste sorting and storage, record-keeping, disposal of waste via government-accredited service providers, periodic review of service providers, and evaluating alternatives to disposal such as composting of organic wastes.	03/31/2027
16	AKF will ensure appropriate pollution prevention measures are in place for existing and any future tanks i.e. secondary containment for AST; risk assessment, secondarily contained (double-walled) tanks and piping and continuous leak detection system (interstitial monitoring), monitoring well, leak response procedure etc. for any underground storage.	12/31/2026
17	AKF will develop an Integrated Pest Management Plan (IPMP), which will describe pest control and prevention procedures to fight rodents and insects at the feed mill and storage facilities. This will entail implementing an integrated management approach for maintaining a clean environment inside the facility (by preventing the accumulation of organic matter and removing all waste immediately), preventing entry (screened windows and keeping doors/windows closed), monitoring and repairing all potential cracks in walls, and keeping the exterior of the plant clear of vegetation. Pest control devices will include the use mechanical traps inside the feed mill. AKF will ensure the existing rodent control service provider adheres to this procedure and undertakes regular monitoring of traps to identify early on the potential need for more aggressive pest treatment	03/31/2027
18	The company will undertake an assessment of the risks and impacts on communities due to the project’s use of security personnel. Based on the assessment findings, the company will develop a Security Management Plan that will incorporate: (i) a security staff Code of Conduct, (ii) guidelines on appropriate use of force and use of firearms, (iv) training on company human rights commitments, and (v) mechanisms within the AKF community GRM to address community complaints related to AKF security personnel.	08/31/2027
19	AKF will incorporate a PS 5 aligned assessment of land acquisition risks (if any) into the site ESIA. The ESIA findings will determine any additional support needed by AKF to meet PS 5 requirements.	10/31/2026
20	AKF will develop a formal SEP commensurate with the company’s environmental and social risks. External communication procedures and community grievance redress mechanisms will be integrated into the SEP.	08/31/2027