No land acquisition legacies impact on indigenous peoples or cultural heritage were identified for GreenFeed’s existing operations. Any potential risks from GreenFeed’s expansion related to PS5 on Land Acquisition and Involuntary Resettlement; PS7 on Indigenous Peoples and PS8 on Cultural Heritage will be assessed and managed as part of the company’s E&S Management system under PS1.

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

The proposed investment is a Category B project in accordance with IFC’s 2012 Policy on Environmental and Social Sustainability. E&S risks and impacts from Category B project are limited, site-specific, and can be readily addressed through generally accepted mitigation measures described in this document and the attached Environmental and Social Action Plan (ESAP).

The E&S risks and issues for this investment are: (i) existence and effectiveness of GreenFeed’s environmental, health and safety (EHS), human resources (HR) and food safety (FS) management systems at its feed mills and pig farms, including legally required ESIA studies and mitigation measures for solid, liquid (manure), packaging waste, and transportation of livestock / inputs/ products to and from sites; (ii) organizational capacity for implementing, monitoring and reporting on company’s ESMS; (iii) labor and safe working conditions of direct employees, contractors and service providers, including occupational health and safety (OHS) standards; (iv) emergency preparedness and response; (v) compliance of contractors and/or service providers with applicable national EHS/HR requirements; (vi) monitoring of EHS parameters (air emissions, effluents, and LTIFR at all operations), including water and energy use and efficiency; (vii) animal welfare management practices in pig farms; (viii) stakeholder engagement and community grievance mechanism. Applicable World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines include the General and Sector-Specific (Mammalian Livestock Production).

 Environmental and Social Policies. GreenFeed has not yet adopted a corporate level policy for environmental, OHS and food safety issues. GreenFeed maintains voluntary certification, including ISO14001, HACCP, and GLOBALGAP for its feed mills and VietGAP (local certification for Animal Husbandry Practices in Vietnam) for its pig farms. Although the application of the voluntary certifications is a positive sign, going forward, as set forth in ESAP#1, GreenFeed shall develop and implement corporate Environmental, OHS and Food Safety policies/standards which will apply to all its feed mills and pig farms operations in Vietnam. Expected performance-level of these policies will meet applicable national (Vietnamese) legal and regulatory requirements, IFC Performance Standards and WBG EHS Guidelines for Mammalian Livestock Production. These policies will be posted at all operations and will be communicated to GreenFeed staffs, contractors and service providers during worker induction session. Annual audit of implementation effectiveness will be carried out.

Identification of Risks and Impacts. GreenFeed has six feed mills in Vietnam located within existing industrial parks in Long An, Binh Dinh, Hung Yen, Dong Nai, Ha Nam, and Vinh Long provinces. Of the six feed mills, five have been commissioned since 2005 while the latest feed mill operation (Vinh Long feed mill) was commissioned in 2018. The land for the establishment of the feed mill operations are leased for a 50-year period from the industrial park operators. In addition, GreenFeed has four pig breeding farms and five pig fattening farms located in Dak Nong, Hung Yen, Dong Nai, Ba Ria-Vung Tau, and Binh Thuan provinces. Three of these farms are directly owned by GreenFeed and six are leased from existing landowners who built the pig farms and then leased them to GreenFeed for current operations.

The company maintains valid environmental permits for all the commissioned facilities, including the feed mills, pig breeding and pig fattening farms. Copies of the Environmental Impact Assessment (EIA) reports for all the feed mills were provided during IFC appraisal. Review of these reports confirms that E&S risks and mitigation measures have been adequately identified. Effective implementation of the mitigation measures was validated during the site-visit to the feed mills in Ha Nam and Hung Yen provinces. For its pig farms’ operations, environmental assessment has been conducted for the company’s owned and leased farms in accordance with Vietnamese environmental law and regulations, in forms of EIA Studies or Environmental Protection Plan (EPP). Sample of EIA/EPP reports for pig farms were received for review by IFC which confirms appropriate mitigation measures are set out to address identified risks and impacts.

As set forth in ESAP#2, GreenFeed will develop a consolidated legal/regulatory (permits) register for applicable EHS requirements for all current and planned pig farms operations (owned/leased) which will include (i) all existing environmental permits received for existing (owned/leased) operations, (ii) provide proof of annual monitoring report submissions in accordance with national regulations, including effective implementation of mitigation measures identified during the environmental risk screening process, and (iii) demonstrate compliance to all terms and conditions of the environmental license. These reports shall meet applicable Vietnamese legal and regulatory requirements, IFC Performance Standards and WBG EHS Guidelines, including guideline levels for air emissions and effluents. Any deviations will require a Corrective Action Plan (CAP), including timeline and assigned CAPEX/OPEX resources. For any asset acquisition, Greenfeed will undertake an E&S due diligence. Performance-based requirements applying to this due diligence will include Vietnamese legal and regulatory requirements, IFC Performance Standards and applicable WBG EHS Guidelines.

To further strengthen its corporate EHS management systems (aside from ESAP#1 above in adopting a corporate level EHS/FS policies), GreenFeed is planning to conduct workplace risk assessment at all its own/leased farm in 2020 and to effectively implement its Standard Operating Procedures (SOPs) to encompass all key EHS issues.

No economic/physical resettlement legacies were identified at any of GreenFeeds’ existing mills and pig breeding farms. Going forward, any land leased for the establishment of the new pig farms, will be on a willing lessor/willing lessee basis and where land ownership is not in dispute. The anticipated fivefold expansion in pig farm capacity with this IFC investment will significantly increase the footprint of the pig farm operations. Although GreenFeed has developed a Site Selection Checklist that analyses key criteria, e.g. biosecurity considerations, distance from local communities, access to market and transportation, water and electricity availability, this Checklist does not include any screening on the land acquisition approaches taken by the proposed lessor or consider any formal checks on environmental compliance. As set forth in ESAP#3, GreenFeed will review and update its Site Selection Checklist to include provisions for a comprehensive due diligence of any land acquisition and/or long-term lease to identify potential risks and impacts as per PS5, PS6 and PS7 requirements and avoid, mitigate and address such risks and impacts through corresponding measures. The due diligence should include documented evidence of the process followed by the Government of Vietnam (GoV) to acquire the land and analyses historic land use with assessment against PS5, PS6 and PS7 requirements. Additionally, as set forth in ESAP#4, GreenFeed will adopt a land acquisition policy and ethnic minorities policy in line with IFC PS5 and PS7, as part of its ESMS.   

Management Programs. Currently the company does not have a comprehensive EHS Management System in place at the corporate level, including for its feed mills and pig farm businesses. As indicated above, GreenFeed maintains voluntary certification (ISO 14001, HACCP, and GLOBALGAP) for its feed mills and VietGap for its pig farms, using Vietnamese legal and regulatory requirements as EHS performance benchmark. EHS issues are addressed in review meetings, planning, auditing, and Objective Key Results (OKRs) evaluation. As set forth in ESAP#5, GreenFeed will further establish its corporate level E&S Management System (ESMS) to include the full scope of E&S risks across all its operations in accordance with IFC PSs, WBG EHS Guidelines, and relevant Good International Industry Practices (GIIPs).

Organizational Capacity and Competency. There are currently two staffs appointed as EHS officers at the corporate level, each tasked with ensuring supervision of effective implementation of EHS SOPs, delivery of internal training and guidance in complying with Vietnamese environmental regulations at the six feed mills and nine pig farms respectively. At mill level, a dedicated EHS Working Committee consisting of 5-10 staff from HR and Facility Management Departments monitor and supervise OHS issues. This committee is reporting to the facility manager. At pig farms, the corporate EHS staff supervise and instruct the farms’ environmental staff who is supported by one to three farm workers. Currently, the environmental monitoring and reporting is outsourced by the feed mill/farm manager to qualified consultants. Considering the significant and rapid expansion of the pig farms business, the corporate level E&S organization needs to be significantly enhanced. As set forth in ESAP#6, GreenFeed will further consolidate its EHS functions, including, among others, clearly defining the roles and responsibilities between corporate and operations level, will recruit an EHS Director and increased number of qualified EHS staff to further develop the corporate EHS/FS management systems (one full-time EHS Director and four full-time competent EHS officers at corporate level is expected), and strengthened internal/external EHS monitoring and reporting system.

Emergency Preparedness and Response. For the feed mills, based on the use of risk assessment matrix, potential risks are identified, and mitigation measures are implemented, including annual compulsory training on safety to all workers at all sites. For the pig farms, as mentioned above, GreenFeed is planning to conduct workplace risk assessment this year. For all sites, fire response procedures are developed and approved by local fire police as a prerequisite before the facility can operate. Feed mills which are all located in industrial zones are equipped with fire hoses, sprinklers and portable fire extinguishers. Firefighting instructions and first aid boxes are put in easily accessible places. Fire drills are conducted every year with support from local fire police. To further structure its emergency response, as set forth in ESAP#7, GreenFeed will formally develop a documented Emergency Preparedness and Response (ERP) Procedure, as part of corporate-level ESMS.

COVID-19 Impact. As the company’s operations are classified as essential services under the GoV directive, the facilities have been in operation throughout the COVID-19 pandemic with strict enforcement of protective safeguards. Most of the manpower (about 80%) has been working in facilities and remaining Adm/HR/Finance staff have been working from home. There has been no significant health impact due to COVID-19 on the workforce at the feed mills and/or pig farms. The company has established a COVID-19 taskforce led by group-level veterinarians and implemented various safety measures including provision of face masks, temperature checks upon entrance, social distancing, disinfection facilities, safety at canteen by dividing in smaller groups with different mealtimes, shutting access to its farms.

EHS Monitoring and Reporting. External supervision and monitoring of effective implementation of environmental mitigation measures are conducted by independent consultant entities for GreenFeed’s feed mills and pig farms on a periodic basis, as per the Terms and Conditions defined in the Vietnamese’ EIAs and/or the Environmental Protection Plan. Monitoring parameters and frequencies are set out in the approved EIAs for the duration of the operation of the facilities.

Supply Chain Risk Assessment and Management: GreenFeed pig farms are supplied exclusively from its own feed mill products. Those six feed mills in turn source wheat, corn, and other feed grains, from a variety of local, regional, and international suppliers. For example, soybean is purchased from Argentina and Vietnam suppliers, wheat from Russia and South America suppliers, fish meal from Peru and Chile suppliers, corn from Argentina and Brazil, fresh rice bran from Vietnam, cassava from Cambodia, Laos and Vietnam, soya oil and sugar cane molasses from Vietnam.

Using IFC’s Global Map for risk assessment and management of agro-commodity production (GMAP), soybean, wheat, fish, corn, cassava, and sugarcane production in Argentina, Peru, Vietnam, Cambodia are associated with medium to high risks of harmful child or forced labor, significant OHS risks, and risks of conversion of natural/critical habitats (deforestation) leading to biodiversity loss. During IFC appraisal, GreenFeed informed that its soft commodities are mainly purchased through spot purchase and, as such, GreenFeed has limited management control and/or leverage over EHS risk screening of its third-party suppliers.

GreenFeed has adopted a Sourcing (Purchasing) Policy in 2015 which includes technical/quality specifications for its raw material sourcing. These specifications are included into contractual agreement with its suppliers. This Policy does not specify E&S screening requirements, such as verification of social responsibility, environmental and/or ethical aspects for its sourcing operations. No transactions are allowed with suppliers who provide banned ingredients or materials. Going forward, as set forth in ESAP#8, GreenFeed shall reinforce its Sourcing Policy, including supplier evaluation criteria for IFC PS2 and PS6 supply chain requirements (e.g. screening for harmful child/forced labor, significant OHS risks, and potential conversion of natural/critical habitats) and management procedure which will include the development and implementation of a Supplier Code of Conduct. The implementation of this Code will be done through EHS corporate coordinator and/or sourcing team. Verification of the effective implementation of the Supplier Code should be carried out by external/internal auditors.

 GreenFeed had 2,752 employees, of whom around 1,995 persons worked at feed mills (1,641) and farms (354) as of December 2019. There were 306 employees working at different functional departments at the head office and 451 persons working for the food business, including 77 seasonal labors. The total employee ratio is 81% male and 19% female. With the commercial growth of its pig farms in the coming years, new employment opportunities will be generated in low-income rural provinces in Vietnam.

Human Resources Policies and Procedures. GreenFeed has adopted an Internal Labor Regulation which covers most of the six objectives of PS2, including, among others, working hours, overtime limits and payments, annual and maternity leave, salary and benefits, social insurance, health insurance, accident insurance, and resolution of labor disputes. The HR Regulation and procedures are communicated during job induction session, called Integration Program, at meetings and posted on notice boards. The HR function are managed by a corporate HR team which is overseeing the effective implementation of the HR Policy in accordance with the GoV labor regulations and ensuring standardized HR SOPs. Day-to-day implementation of HR procedures is managed at each Business Unit (BU) by the facility HR department composed of three persons. GreenFeed maintains employment policies and procedures that are approved by the Long An Provincial Department of Labors, Invalids and Social Affairs (DOLISA) and comply with prevailing labor regulations.

Working Conditions and Terms of Employment. Terms of employment and the rights and responsibilities of workers are formalized into employment contracts and communicated to all direct employees along with the Internal Labor (HR) Regulation. Under the employment terms that strictly follow the national labor law, workers are employed initially on fixed term contracts which are renewable subject to satisfactory performance and availability of work. All workers are paid in excess of their respective regional minimum wages. Working hours and overtime work are as per national labor law requirements, i.e. not more than 48 hours a week. Feed mills employees work in a shift system of three eight-hour shifts on six-day week schedule with limited overtime while farm workers work eight hours per day, six days a week. Employees receive time-off or cash compensation in lieu of any overtime work at rates regulated by the national labor authority. All employees are enrolled in social insurance, covering pension, unemployment, medical, injury, and maternity. In addition, all employees and their families are also covered with accident insurance, life insurance, and medical insurance. On top of the basic salary, facility employees are also provided with various allowances, including hazard pay, allowances for frontline workers at the pig farms (living-away-from-home allowance, meal allowance, etc.), mid-shift meal allowance, per diem, mobile phone expense, uniform and personal protective equipment expense, rental allowance. IFC’s review found each employee is entitled to access additional training needs for continual professional and personal development. Employees also receive annual health check and workers at the production area undergo checkup every six months, covering physical examination and laboratory/radiological tests (e.g. urine and blood test, X-ray).

Given biosecurity concerns and lengthy quarantine periods associated with gaining access to and working in the pig farms, the workers are provided with living accommodation on the farm and meals in the canteen. While strict biosecurity protocols need to be met, there are no undue restrictions placed on employees’ freedom of movement, and they get scheduled time off consistent with labor law requirements. Accommodation is shared by four employees and is male/female segregated, except for married couples who take up family housing units. Each room is about 24m2 in size with bed and secure place to store belongings. Toilets, washing facilities, and gym/entertainment area are provided. The observed workers’ accommodation during appraisal confirm the compliance with IFC/EBRD Workers’ Accommodation Guidelines.

Workers’ Organization. As per the provisions of the Vietnamese Labor Code, workers have the right for freedom of association and collective bargaining. This provision is explicitly reflected into GreenFeed’s Internal Labor (HR) Regulation and its existing Collective Bargaining Agreement (CBA). All employees who sign a permanent contract with GreenFeed join, by default, such union. A CBA was agreed in 2011 and revised every three years with the most recent update occurring in November 2019 and registered to the Long An Provincial DOLISA in December 2019. This agreement complements GreenFeed’s Internal Labor Regulation and related procedures.

Non-discrimination and Equal Opportunity. HR policy explicitly specifies non-discrimination and equal opportunity. No procedures and/or practices have been identified as discriminatory. All the hiring and promotions are merit-based. There is no difference in terms of salary for female and male employees with the same experience for the same type of jobs. GreenFeed has a Code of Conduct on respectful workplace and relations between company and its employees and among employees, but no specific policy related to workplace harassment, including that related to Gender Based Violence (GBV). GreenFeed does not have documented process for the anti-sexual harassment policy as well as no dedicated focal point to receive allegations of sexual harassment in the workplace. As set forth in ESAP#9, GreenFeed shall amend its employment terms and conditions to include a zero-tolerance approach for proven cases of Gender-Based Violence (GBV) or reports of sexual harassment and shall include a mechanism for receiving complaints that protects the identity of the complainer, investigates the process based on a survivor centered approach, applying remediation in accordance with the HR policies and procedures and national regulations. 

Worker and Contractors’ Grievance Mechanism: HR procedure for workers’ grievance is reflected in its Internal Labor (HR) Regulation and its CBA. As per the procedure, employees can raise their grievances through mailboxes which are placed at the canteens and production areas of each feed mill or pig farm operation. In addition, employees can raise their grievances through regular face-to-face meetings, by talking to HR department or through the labor union. No channel is available for anonymous filing of grievances or concerns. As set forth in ESAP#10, GreenFeed will update its worker grievance mechanism procedure which will be available for its permanent, casual and contractual workers, as applicable. This procedure will include steps to be taken by workers to manifest any concerns, engage in a mediation process, contact responsible persons, and provide timely feedback. The company will also reinforce the policy of confidentiality and non-retribution, along with ability to raise anonymous grievance.

Protecting the Work Force. All workers exceed the minimum age of 18 years, records of proof of age are kept, and there is no evidence of forced labor practices. No children were seen working at feed mills and/or pig farms operations during site appraisal.

Workers Engaged by Third Parties: Security, cleaning, and loading / unloading laborers are recruited from service providers. Due diligence of service provider is not carried out with compliance of Vietnamese Labor Code (2012) and OHS issues, including payment of minimal salary, social benefits, OHS training and provision of PPEs. As set forth in ESAP#11, the HR Department will undertake such annual due diligence and mechanism to monitor ongoing compliance of any third-party service providers while EHS corporate officers and plant-level EHS officers will ensure effective implementation of OHS training and use of PPEs.

Occupational Health and Safety: Implementation of the OHS management system is led by an assigned Group-level EHS officer with the support of plant-level OHS supervisors. For the feed mills, the mill manager is responsible for OHS issues. Each mill has established an OHS Working Committee composed of 5-10 persons (from HR, storage, QA, maintenance, and shift supervisor). The Committee defines its annual workplan and targets and is responsible for monitoring its timely implementation, including assignment of budget, training plan, accident reporting and investigation, etc. GreenFeed has adopted an OHS policy in 2015 based on the 5S approach (sorting, straightening, systematic cleaning, standardizing, and sustaining a safety workplace). The company has conducted a workplace risk assessment for its feed mills in 2017 and accident reporting. Review of its approaches and effectiveness to maintain continual improvement is based on reporting KPIs (OHS leading and lagging indicators). Based on the risk assessment at each working station, a suite of OHS SOPs have been developed and included boiler, air compressor, electrical equipment, conveyor, forklift, working at heights, chemical use, among others for feed mills. Training and provision of PPE, including boots, helmets, dust masks, ear plugs, and cloths are provided accordingly. Annual trainings on OHS are also provided by certified professionals at all feed mills and pig farms (e.g. firefighting exercises, work safety, sanitation and emergency rescue).

For its pig farms, each farm has one assigned OHS officer who is responsible for both environment and OHS issues with the support of the administration office and three other workers. This function reports to the group-level EHS officer. Except for the biosecurity protocol, GreenFeed does not have in place a detailed list of OHS risk points with detailed SOPs linked to each type of risk which describes required mitigations. Going forward, as set forth in ESAP#12, in order to ensure sound OHS management practices, GreenFeed will assign a dedicated OHS officer at corporate level, who will have relevant technical background and operational experience of pig farms on a fulltime basis with responsibilities in (i) assessing workplace risks; (ii) determining risk avoidance, minimization and mitigation hierarchy through SOPs development and training plan; and (iii) aligning OHS auditing reporting and inspection process, including keeping records of OHS leading and lagging KPIs.

The internal accident register identified four Loss-Time Accidents (LTA) in the last three years, where only one of them happened at feed mill with 94 lost working days (other three accidents were transport related accidents during workers commuting to and back from work). An accident investigation report listing the location, date, and description of the incident was available although did not describe the incident in detail nor provide root cause analysis leading to lessons learned and implementation of prevention-oriented actions. The company’s incident investigation and reporting system will need to be reinforced, to reflect root cause analysis and systemic lessons learned approach. As set forth in ESAP#13, GreenFeed shall undertake a detailed OHS review of its feed mills and pig farms’ operations, to ensure that: (i) its incident investigation, classification, and recording system are updated in line with IFC PSs, GIIPs, and WBG General EHS guidelines, including incorporation of a root cause analysis approach, monitoring/reporting of OHS leading and lagging indicators, and implementation of corrective measures; and (ii) the company annually benchmarks its OHS performance with representative Vietnam and international hog production industry/sector performance numbers. This should cover all workers, including temporary and third-party workers .

 Energy and Material Efficiency Projects. GreenFeed’s operations source electricity from the national grid. On-site backup generators are available in case of power shortage. Electricity demand for all six feed mills was ~46 million kWh in 2018, with all pig farm facilities is ~56 million kWh in 2018. Based on an average consumption of ~6 million kWh per annum per farm, a planned expansion of production is estimated to increase energy demands to ~1.3 billion kWh per annum. Energy audits are conducted annually for feed mills. The company is increasing water use efficiency by reusing the water retrieved from the wastewater treatment process.

Water. For the pig farms, groundwater is pumped from drilled wells at site for production activities and domestic usage and is treated to meet national quality standards for drinking water. The groundwater extraction is permitted and licensed by the provincial authorities with registered number of wells and water volume.

For pig farms, the extracted water is used for pig bathing, pen cleaning, and waste treatment, with the largest amount water for the 60,000-pig farm of about 800m3 per day (0.01 m3 per head of animal per day). For the pig farms, bottled water is provided for drinking purposes of workers. The planned expansion of up to 200 sows and pig fattening farms, with an additional circa 1.2 million heads will consume about 16,000m3 of water per day.

For the feed mills, water supply is guaranteed for both quality and quantity by the industrial park operators. Consumption is not considered significant as no process water is required for production of feed. Most water is used for domestic purposes (drinking, cooking, toilet, gardening) and steam generation for boilers; on average, a feed mill consumes 140m3 / day for such purposes.

GHG Emissions. GHG emissions estimation from current energy consumption data (2019) is estimated at about 92,000 tCO2-equivalent for 9 pig farms and 6 feed mills. With the plan to expand the commercial pig stock to ~1.2 million by 2022, the livestock emissions (both methane and nitrogen) to be considered by the total future animal headcount is estimated at about additional 69,500 tCO2-eq per year. It is also anticipated that based on the projected expansion of the pig farms and increase in energy consumption the GHG emissions profile of the entity could exceed ~500,000 tCO2e per annum. As such GreenFeed will report on its GHG emissions through IFC’s Annual Monitoring Report (AMR).

Pollution Prevention. For the pig farms, GreenFeed has developed an Animal Waste Management Plan for the treatment and management of waste (manure). In 2019, the total volume of pig manure from the nine farms (with number of pigs ranging from 600 to 70,000) was reported at about 12,900 tons. This implies, that under the planned expansion supported by this project, that about ~300,000 additional tons/year of animal waste will be generated across all the facilities.

GreenFeed has a standard approach for the management of animal waste aligned with the environmental permit conditions, which includes anaerobic composting and is also piloting vermicomposting. As set forth in ESAP#14, Greenfeed shall evaluate its approach to animal waste against WBG EHS Guidelines (Mammalian Production), with recommendations for improvements integrated into the revised Animal Waste Management Plan, which will be integrated in the updated ESMS (ref. ESAP#5) and implemented for the future farms.

Wastewater Treatment. Wastewater and wastes from the pig farms are collected by closed ditch system and sent to the settling tank, where solid manure is separated to make pressed manure to produce fertilizer, while the wet sludge and sewage is sent to the anaerobic digestion chamber (biogas), where it is then decomposed by anaerobic microorganisms. This decomposition process produces gas, sludge and sewage. Wet sludge is pumped out every 20 - 40 days on average for complete decomposition, dehydrated and treated to make agricultural fertilizer. Wastewater from biogas chamber is collected and treated separately, after regulation and stabilization the material is disposed through land application. Wastewater generated by production activities and manure treatment is treated in accordance with GoV regulations (QCVN62-MT:2016/BTNMT) and reused within the farms for watering the trees in buffer zone. Wastewater quality is ensured by internal check and testing by the farm’s environmental staff and periodic monitoring by a third-party environmental service as prescribed by the requirements within the environmental permit. Results of the latest monitoring reports demonstrate full compliance with prevailing regulatory requirements. No wastewater is discharged to outside environment and/or surface waters. Location of pig farm siting by GreenFeed is done to ensure farms are located away from water bodies to avoid any potential surface water contamination.

Air Emissions and Odor. Air emissions from GreenFeed’s feed mills are generated mostly from boiler while dust is generated from machine activities. The air quality impacts are assessed as insignificant according to the EIA reports for feed mills and this in asserted by results of the latest environmental monitoring reports where all air quality parameters monitors are compliant with the national regulations and WBG EHS Guidelines. At the pig farms, the latest monitoring reports also indicated that air quality values are all within the current GoV standards for ambient air quality.

During IFC appraisal, it was identified that one pig farm has been associated with complaints from the nearby communities’ in the past over possible odor impacts from the farm. While there are no national standards for odor impacts originating from the pig farms, GreenFeed acknowledged the comments from local community and implemented a series of mitigation measures, including (i) adequate buffer zone distancing from the existing residential areas as a key site selection criteria; (ii) creating tree buffer zone around the farm; (iii) designing sealed manure collection and tranfer system; (iv) using odor net trap with deodorizers at the ventilation outlet of pens; (v) applying regular sterilization and deodorization at key odor sources inside the farms, including wastewater pond, sludge drying yard, and carcass disposal pile. Ref. to ESAP#15 on stakeholder engagement and community grievance mechanism.

For dead pig carcasses, after a postmortem to determine cause of death, GreenFeed disposes of carcasses through a two-stage composting process: primary – decay of tissue (3 months) and secondary – further decaying of other parts (2-6 months). This process uses rice husk and sawdust to decompose dead pigs at a temperature of 45-55oC. The waste from this process is sold to tree gardeners once a year. Carcasses of diseased animals are treated based on biosecurity and disposal guidance from Vietnam Ministry of Agriculture & Rural Development, Dept. of Animal Health.

Solid and Hazardous Waste Management. All feed mills and pig farms have hazardous waste storage areas which are properly roofed, partitioned with waterproofed flooring. Hazardous wastes include chemical containers, medicine packages, used syringes, used light bulbs, oil absorbent rags. Hazardous waste is registered with the local Dept. of Natural Resources and Environment and collected, treated and disposed by environmental service providers through valid contracts. Daily waste from workers’ activities and used packages is treated as non-hazardous solid waste and gathered in containers of various sizes equipped in sanitary facilities, production areas, kitchen, and the domestic waste storage house and disposed of in accordance with the environmental permit and prevailing regulations (ref. ESAP#2).

Hazardous Materials. Hazardous materials on pig farms consist of diesel oils and veterinary products, as well as other materials such as insect and pest repellents, lubricants, petroleum products (diesel for generators), and cleaning agents. All hazardous materials are properly labelled and stored in the designated room in the sites as per the permit conditions. 

Community Health and Safety. All six feed mills are in industrial zones, therefore, there is no direct adverse impact from these operations on the nearby communities. Since 2013, the company’s biosecurity guidelines require all the new farms to be located approximately two kilometers distance from the residential areas. It is noted that three farms constructed prior to these guidelines were developed within 400m of the nearest local communities. It was confirmed by the company that since these facilities were constructed before the revised biosecurity protocol and the revised government regulation on the establishment of large-scale animal husbandry farms, these sites are considered as compliant.

Community Exposure to Disease. GreenFeed employs a range of biosecurity measures in order to minimize the risk of disease infection and transmission at its production facilities, and to and from each of its facilities. These measures include, among other things, (i) keeping pigs at indoor production facilities with only introduction of boars for genetic gain; (ii) access control; (iii) isolation procedures for workers entering the farms (four day downtime) with all food prepared on farm and introduced product is fumigated; (iv) trucks entering require a complete washdown and drying while the driver does not leave the truck, the breeding farms have dedicated drivers and trucks to reduce the chance of cross contamination from other farms; and (v) constantly monitoring the health of livestock with serology testing of all sudden death pigs. GreenFeed has produced a Biosecurity Manual to ensure all staff are informed of the need for and the operational characteristics of biosecurity practices.

Security Personnel. All GreenFeed’s feed mills and pig farms used licensed security companies to provide security guards and related services on a 24 hours basis. No armed security forces are engaged for all facilities. 

 All feed sites are located currently within established industrial parks, and far from any recognized key biodiversity areas (KBAs). Therefore, impacts from the existing feed facilities are deemed insignificant regarding PS6 risk. As for the current pig farms, results from IFC’s Integrated Biodiversity Assessment Tool (IBAT) carried out during appraisal indicated overlaps with KBAs for all nine farms within proximity of 10-50km. The expansion of the pig farms will be located on agricultural land (modified habitats), and as such, represent limited adverse biodiversity impacts on those locations. To ensure avoidance of any risks to biodiversity, going forward, GreenFeed will mainstream a biodiversity risk screening as part of its updated Site Selection Checklist (ref. ESAP#3).

Sustainable Management of Living Natural Resources. In accordance with the IFC Good Practice Note (GPN) on Improving Animal Welfare in Livestock Operations (2014), IFC’s scope of appraisal included verification of compliance of GreenFeed’s animal welfare management practices with the OIE (World Organization for Animal Health) Guidelines. Based on a completed animal welfare survey, GreenFeed complies with these guidelines. In 2019, GreenFeed applied for local certification (VietGAP) for certifying its animal husbandry practices in Vietnam. Going forward, as set forth in the IFC advisory engagement mentioned above, GreenFeed will undergo a comprehensive IFC’s HACCP-methodology based Biosecurity, Animal Welfare and Use of Antibiotics (BAWA) Audit Protocol leading to the development of a BAWA management system at corporate and farm-level. Greenfeed shall certify its animal husbandry/welfare management practices against a recognized certification standard benchmarked against GIIP for all farms going forward (e.g. Global Gap for Livestock). Ref ESAP #5.