The project will be located within DBL’s existing Mymun complex. No land acquisition is required for the project and no past residential or commercial use of the land was noted. Thus PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. As the complex is located within an urban area, the type of risks and impacts envisaged by PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples), and PS8 (Cultural Heritage) are not present.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. Key Environmental and Social (E&S) issues associated with this project include: development and implementation of adequate EHS management systems; assurance of fair, safe and healthy working conditions in compliance with local regulatory requirements and relevant Performance Standards during construction and operation; resource efficiency (water and energy consumption); monitoring and management of air emissions, wastewater and solid waste disposal; Life and Fire Safety (L&FS) management, emergency preparedness and response including that for COVID-19 pandemic.

 The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. DBL has a corporate Environmental Policy as well as Occupational Health and Safety Policy which applied to the project. DBL has implemented management systems certified as per ISO 14001 (Environment) including existing HTL factory and will be applied to the project.

DBL's facilities undergo assessments as per supplier evaluation programs by various global retailers (H&M, C&A, Puma etc.) against their compliance requirements such as life and fire safety, occupational health and safety, labor and working conditions; including structural and electrical safety (including fire safety) assessments under Accord for Fire and Building Safety in Bangladesh (ACCORD) program.

The Group has a dedicated EHS compliance team headed by General Manager of Environment and Social Compliance and there are separate teams of compliance managements (environment, social and compliance) at each group company.  Existing HTL project has about 10 compliance management officers in charge who will cover the project’s EHS management when operational. DBL also allocates a Director Sustainability who is responsible for reduction of environmental impacts from DBL operations with a focus on five sustainability pillars (People, Process, Product, Community and Environment) including energy efficiency, water efficiency, carbon emissions and waste reduction as well as implementing the Group’s Corporate Social Responsibility (CSR) program.

DBL has documented an emergency response plan for the complex. The roles and responsibilities for various teams responsible for evacuation, rescue, fire-fighting are defined and are displayed at various locations in the factories in the complex. A fire command room is also available at each complex. Fire alarm call points, evacuation route maps and hose reels have been placed at many locations. DBL has a Group Fire Safety in charge and a fire safety team. The compliance team conducts internal audits to ensure implementation of L&FS measure. A number of workers have been trained in fire safety and operation of fire safety equipment every month including construction workers. In response to the COVID-19 pandemic, the company has implemented COVID-19 response plan.

As part of the corporate EHS management, the company monitors key performance indicators (KPIs) such as record of injuries, L&FS measures, usage of personal protective equipment (PPE) and energy consumption covering construction and operation. The KPIs are reported on monthly basis to the compliance management team. All incidents are summarized and discussed in the monthly quality control meeting and the team analyses the root causes and implements corrective action.

DBL employs more than 35,000 workers including its group companies comprising about 60% male and 40% females. All the workers are directly employed by the Group and there are no third-party workers. At HTL, the company employs around 1200 workers and will hire additional ~930 employees for the project. Like all the other factories in the Mymun complex, more than 90% of workers are male as main processes are dyeing and finishing, remaining female employees are hired for administration and office work purpose.

DBL has corporate HR policies and procedures applicable to all employees including code of conduct, anti-harassment policy, grievance procedure, compensation and benefit policy etc. The policies and procedures were noted to be meeting the IFC requirements. Each worker receives a written contract that describes the working conditions and terms of employment. An employee handbook is also provided to each worker explaining the provisions of Bangladesh Labor Act, working conditions and benefits provided. HTL also provides induction training for new workers which includes working hours, calculation of wages, leave policy etc. The same is repeated in the refresher sessions as part of the monthly training.

The Group has a corporate policy on non-discrimination and equal opportunity as part of its recruitment policy. DBL verifies the age at the time of application via national ID cards as described in the code of conduct. DBL runs a female supervisor leadership program with 2 months training for female workers at sewing and quality department aiming to establish 150 in-house female leaders. No instances of non-discrimination, large scale retrenchment, child or forced labor were observed. DBL has included child labor, forced labor and non-discrimination in its induction training for new workers.

Although DBL does not restrict its workers to form worker’s trade unions, there is no union established at the operating factories. Only representative of workers elected to Participation Committee to discuss issues within the workplaces on a regular basis. The Group has a documented grievance procedure which describes the process of grievance handlings including anonymous reporting mechanism. The Company provides regular trainings for workers on the grievance mechanism.

DBL acquired ISO 45001 certification for its dyeing factories. DBL completed a formal OHS risk assessment and review its safety provisions as part of the management programs to reduce the incidents through continuous improvement and awareness rising. No major accidents or fatalities are reported by any of the facilities in the past few years. Mymun complex has a medical center with a doctor available in the day time and an ambulance for medical emergencies available 24 hours to deal with occupational incidents and some common diseases.

During the COVID-19 pandemic, the company did not conduct nor plans to lay-off any workers, and there have been no salary cuts or such. The company has implemented several COVID-19 response measures for its operations including: temperature checks; regular cleaning and disinfection; installation of disinfectant chambers at the factory entrance; and providing awareness trainings on COVID-19 safety etc. There was no significant health impact due to the pandemic on the workforce, except for a few positive cases found. All those employees have returned to work with necessary certification from the doctor.

Safety guidelines for the construction workers have been documented and cover key areas of EHS at construction sites. Construction safety, health safety and L&FS trainings are provided by compliance team to all construction workers. DBL has appointed a construction manager and compliance team in charge of the new factory construction for the project. The construction manager oversees the projects through daily site inspection and compliance management team monitors and reports on safety performance. DBL has also asked to have a safety officer on-site from construction company. The COVID-19 response measures are also applied to construction sites. The company did not suspend or cancel contracts due to COVID-19 pandemic. All the construction workers and contractors were paid as agreed and there was no reduction in workforce.

Through IFC led Advisory PaCT program, HTL has been actively improving its resource efficiency including better effluent treatment and water reuse. As a result, HTL reduced natural gas and water consumption by 1.4 million m3/year and by 328,000 m3/year respectively in the period of 2018-2019. DBL also closely monitors resource consumption i.e., process water, gas, electricity and chemicals. The process water consumption is reported to be 5.6 liters/kg of fabric which is below the water consumption benchmark for knitted fabric finishing as per the World Bank Group (WBG) EHS Guidelines for Textiles Manufacturing.

The main source of air emissions from the project will be gas-based power generators and two steam boilers. Additional power will be supplied through national grid but not be used commonly. DBL monitors stack emissions and ambient air quality on a yearly basis. The monitoring reports indicate compliance with the applicable legal requirements.

The main source of water is the on-site borewell and DBL obtained the permissions of water intake. The existing usage of water is 700 m3/day at HTL factory. The water is treated in the Water Treatment Plant (WTP) with iron removal, filtration, softening and pH correction. For the project, an additional WTP will be installed with similar treatment processing.

The industrial effluent generated from factories in Mymun complex is treated in the two existing Effluent Treatment Plants (ETP) based on secondary biological treatment. Since current ETPs have enough capacity for effluent from the project, no additional ETPs planned. The effluent is tested in the internal laboratory on a weekly basis. The monitoring reports indicate compliance with the legal limits as well as the limits specified in the Table 2 of WBG EHS Guidelines for Textiles Manufacturing. All the treated effluent is discharged in the river adjacent to the Mymun complex. Domestic wastewater is treated by the sewage treatment plant and released to the public sewage system. Stormwater is treated in the rainwater harvesting system in the complex to recharge groundwater.

The ETP sludge is dewatered using a filter press and is disposed of after 6 months of drying to an on-site reinforced cement concrete pit. DBL has hazardous and non-hazardous waste management procedures including the system of appropriate sorting, handling, storage and disposal, recorded by waste inventory data sheet and is consistent with the applicable legal requirements.

The GHG emission from current HTL operations is estimated to be 15,000 tons CO2/annum. Accordingly, the GHG emissions from the project are expected to be less than 25,000 tons CO2 eq/annum.

 Since the project is located within DBL’s existing industrial complex and plans to expand existing finishing processes, no significant additional impacts on local community are expected. In order to deal with any local traffic increase, DBL raises driver’s awareness on safety drive and speed limit during traffic.

DBL has developed community grievance policy and implemented a documented process of community engagement and grievance mechanism. A complaint box placed outside of the complex gate and at community which are opened regularly. No complaints received so far.

DBL has a Bandhan Fair Price Shop where workers can buy daily commodities including food and housekeeping items at factory price. Also, a daycare services program developed with UNICEF has provided to employees with young children in the Jinnat complex.

The facility has its own security workers who are unarmed, and some limited number of armed security provided from Ansar (paramilitary auxiliary force), if security situation warrants. HTL will document a specific security policy/Code of Conduct consistent with the requirements of PS 4 and incorporating the relevant guidelines of the Voluntary Principles on Security and Human Rights. This will include the guards’ behavior with the community, workers and clear guidelines on use of security force. The policy shall be communicated to the security guards as part of the induction as well as refresher training (ESAP#1). Regular monthly training program are conducted by the company for the security workers on the standard operating procedures for their job including human rights and code of conducts.