Based on information available, the locations of the HW treatment plant projects are in industrial parks already developed or under development. The locations of the BW treatment plant projects are still to be defined and will be within or close to urban areas. Based on the review of the available data in the project regions, there are no known populations of Indigenous Peoples groups at or near the locations of the existing plants and the pipeline projects, or along the main transport routes for suppliers of hazardous wastes, and during development of the industrial sites where the plant sites are located, there were no cultural properties discovered or any indications of the presence of such at the project sites. The location of three planned BW treatment plants is undefined.  At the time of the disclosure of this ESRS, no impacts are expected that need to be managed in a manner consistent with PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS 7: Indigenous Peoples, and PS 8: Cultural Heritage. The E&S impact assessment studies for the pipeline projects, however, will screen and assess for risks and impacts to be mitigated and managed according all Performance Standards. Such studies will be disclosed when they become available.

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

  The key E&S issues and risks associated with this proposed investment include: company’s E&S management capacity (including screening and assessment process during project identification and definition/design and its controls on project E&S risks for both construction and operations), historical contamination, air and fugitive emissions, wastewater treatment and discharge, solid and hazardous waste management and disposal, labor and working conditions, occupational health and safety (OHS), fire protection and emergency response, community health and safety, stakeholder engagement, and land acquisition.

 Environmental and Social Assessment and Management System

ALBA Asia hires external experts to conduct E&S assessments for its projects according to Chinese laws/regulations and ALBA Asia’s technical standards. As a new company, ALBA Asia is currently establishing a corporate E&S management system that will be applied to existing operations and pipeline projects. At the asset level, HW Jiangsu Plant’s management systems are certified according to ISO 9001 (quality), ISO 14001 (environment), and OHSAS 18001 (occupational health/safety) standards. The company is also in the process of developing and integrating detailed environmental, occupational health/safety (OHS), and process safety requirements into its EHS management programs.

Currently, all the projects are in early stages, and the studies for the relevant Environmental and Social Impact Assessments (ESIAs) are still to be commenced or are under development. In addition, there have been upgrades at HW Jiangsu Plant without an update of the ESIA. To meet national requirements and obtain the relevant environmental permits for the expansion, ALBA Asia will cover these upgrades in the ESIA for the planned expansion. The ESIAs for upgrades and expansion of HW Jiangsu Plant and for all the greenfield projects will be carried out consistent with IFC Performance Standard’s requirements and will be disclosed locally as well as on company’s website as part of its ongoing stakeholder engagement (ESAP #1). Site and technology alternative analysis will be included in the ESIAs for greenfield projects.   

Policy

E&S policy within ALBA Group (ALBA Health and Safety, Environmental, and Social Guidance, HSE&S Guidance) states the sponsor’s commitments to sustainability and corporate responsibility. ALBA and ALBA Asia’s E&S policy are aligned. The policy promotes E&S risk evaluation for any decision-making process, participatory approach to risk prevention, and dialogue between employees and management, among others. ALBA Asia’s E&S policies are aligned with IFC Performance Standards. As part of this investment and as indicated in ESAP #2, ALBA Asia will align its corporate E&S management with IFC Performance Standards and applicable WBG EHS Guidelines and will develop an implementation procedure to apply corporate E&S policies and procedures to all its projects and operations.

Identification of Risks and Impacts

The company has corporate procedures for E&S risk identification/assessment at the project stage.  These procedures will be aligned with IFC Performance Standards under ESAP #2. When a project enters into operations, E&S risks are identified through inspections and an internal auditing program, and corrective actions identified. As part of the planned expansion associated with the pipeline projects, ALBA Asia will incorporate a requirement for external E&S audit programs by relevant experts. The audit programs will review and assess compliance with IFC Performance Standards (ESAP #3).

Management Programs 

ALBA Asia has its own corporate E&S management program, which is derived from ALBA in Germany. The company has an E&S risk and impact assessment procedure for greenfield and expansion project. It also has an E&S due diligence procedure for mergers and acquisitions to evaluate E&S risk of both historical pollution and operations.

As part of the ongoing process for the development of the corporate level E&S management system, specific EHS management programs are being developed and will have relevant procedures and tools (as required under ESAP #2) to avoid, minimize and mitigate E&S risks, which will include, but not limited to, E&S due diligence procedure for new acquisitions, E&S risk screening procedure for new projects, E&S risk and impact assessment procedure for new projects, legacy land acquisition, historical contamination evaluation during project development, soil/groundwater monitoring, management of change, modification of assessment of E&S risks and impacts due to project scope changes or plant expansions, occupational disease hazard (ODH) assessment and environmental monitoring for biowaste treatment plants, all consistent with IFC Performance Standards. The company’s growth plans include future expansion of existing facilities and acquisition of new sites. In view of this, the company will also adopt a Land Acquisition Policy and relevant procedures to guide land acquisition processes in line with the requirements of PS5 (ESAP #18).

Once fully setup and following implementation of the actions under ESAP #2, the management system will include relevant technical standards, standard operating procedures (SOPs) and work instructions, internal codes for EHS performance, and an inspection/audit program. As part of the management system, the company will standardize its approach to monitoring of environmental performance in terms of air emission and ambient air quality monitoring, liquid effluent controls and monitoring, waste management, and occupational health/safety tracking.  Process safety management will also be integral part of the management system. Performance and non-conformities with respect the E&S policies, procedures and standards will be recorded and monitored through a central EHS management database and reported to senior management.

Organizational Capacity and Competency

At the corporate level, ALBA Asia has an E&S management team, within its ALBA Center for Excellence (ACE), which reports directly to the chief operations officer. ALBA Asia’s team includes a social specialist. In addition a corporate public relations manager is in charge of community liaison officers deployed at each operational site.  ACE is responsible for ensuring compliance with the corporate EHS policy and EHS management program implementation. A corporate EHS database is currently under development and will also be managed by ACE, which will enable corporate management to quickly access data relevant to the EHS performances at each plant directly. 

At each plant site, there is a dedicated EHS team to manage the daily EHS operations according to corporate policies, programs, and procedures. The EHS teams report to plant general managers with dotted reporting lines to ACE. The EHS teams are fully staffed to conduct their responsibilities, including routine EHS performance inspections and management of third-party contractors hired for monitoring of point source emissions, fugitive emissions, effluents, ambient air quality, waste disposals, soil and groundwater monitoring, etc.

The company’s EHS management teams at the corporate level and at the plant level are responsible for the development and implementation of employee’s training program covering EHS management and performance procedures. 

Fire Prevention, Emergency Preparedness, and Response

The documents provided by the company report that there are sufficient firefighting equipment and firefighting water/foams at all production processes, and maintenance records are available. Toxic gas sensors and automatic fire detectors are installed at all critical locations with connection to central operation room. Each plant has documented emergency response (ER) plans as required by the company’s HSE procedures. At each plant, there are quarterly ER drills. The information provided for firefighting and ER will be verified during the IFC visit.

IFC’s review of documents provided by the company found no evidence of drills for some potential emergency scenarios, such as hazardous chemical release, emergency against oil storage leakages or spills, and coordination with plants. As independent fire safety audit for HW Jiangsu plant indicated that fire prevention at office and warehouses needs improvements. ALBA Asia will conduct the first comprehensive ER drill to cover all major scenarios for both production lines and warehouse/office areas, and will develop a fire prevention and safety improvement plan for the warehouses, including enhancements of the hydrogen peroxide storage, among others, at HW Jiangsu plant (ESAP #4). As part of the update of the E&S management system (under ESAP #2), the company will develop and implement a procedure, applicable to all hazardous waste treatment plants, requiring each asset to carry out annual ER drills in coordination with local fire brigades, nearby hospitals, neighboring plants, and community representatives. 

Monitoring and Review

The monitoring programs include point source emissions, fugitive emissions, effluents, ambient air quality, noise levels, waste handling/disposal, and OHS tracking, all with established key performance indicators (KPI) to monitor performance (e.g. emission levels, workplace air quality, total recordable incidents, work permit review, etc.).  Under ESAP #2, the monitoring programs will be reviewed and updated to ensure consistency with IFC Performance Standards and relevant and applicable WBG General EHS Guidelines and EHS Guidelines for Waste Management Facilities.

The plant EHS teams conduct daily inspections for critical processes and report monthly to ACE, which in turn holds monthly meetings with all EHS teams across the company and reviews monthly reports from each plant. ACE also conducts quarterly EHS audits at each plant. Implementation of the corrective actions identified during the audits, consistent with the timelines defined by ACE and plant management, is evaluated at the following inspection/audits. The employees or unit heads are required to report to plant EHS teams for any potential risks and non-compliances. They can also report anonymously to senior managements if they have concerns for health and safety.                                                     

 ALBA Asia has currently around 400 employees to operate the two plants in China.  With six new plants planned under this project, the total number of employees are expected to reach approximately 1,200. As part of this project, an undetermined number of construction workers will be hired by contractors. Based on experience, the company predicts that most of the construction workers will come from local areas.

Human Resources Policies and Procedures

ALBA Asia takes the core human resources (HR) values of ALBA in Germany into its own HR policy.  Terms of employment and working conditions are adequately specified and include procedures related to recruitment, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and firing, vacation, other leave, retirement, and respectful workplace, including gender equality and harassment. The company has HR policy training that is part of its induction program for new employees, and all employees have access to this policy. The HR issues are managed at each plant separately, with the corporate HR team to coordinate HR issues across the company and assist the senior management with HR issues.

Working Conditions and Term of Employment

All workers are on ALBA Asia’s or local project company’s payroll. Security and cleaning laborers are contractors from service providers or casual labor. Terms of employment and the rights and responsibilities of workers are formalized into employment contracts and communicated to all direct employees along with the Employee Manual. 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. Overtime work is usually only associated with production emergencies. Staff receive time-off or cash compensation in lieu of any overtime work at rates regulated by the national labor authority. Overtime work during holidays is compensated on the basis of 2 – 3 times base salary. All employees have access to the insurance and pension funds as required by labor law. For contractor employees who work at the site, ALBA Asia has established a contractor management program that requires the contractors to fully comply with national labor laws and company’s HR conducts periodic inspections. At HW Jiangsu site and BW Hainan site, it was identified that overtime working hours have exceeded the statutory limits. As indicated in ESAP #5, the company will review and monitor compliance with overtime working hours at these two sites consistent with regulatory requirements on working hours.

Workers’ Organization

A worker union with elected union leaders is set up at each plant, as required by the All-China Federation of Trade Unions (ACFTU). Company’s management is committed to keeping the union independent from management and allows for collective bargaining outside of labor unions.

Non-discrimination and Equal Opportunity

The HR policy specifies non-discrimination and equal opportunity. No procedures and/or practices have been identified as discriminatory. All the hiring and promotion are merit-based. There is no difference in terms of salary for female and male employees with the same experience. When candidates have equal qualifications, preferences of hiring are given to local residents and females. Currently, approximately 20% of the company’s employees are women. The company has indicated that it plans to recruit more female employees in the new projects and increase the percentage of female employee.  As indicated, the company has provisions relevant to respectful workplace, including prevention of gender-based violence (GBV)/verbal harassment, in its HR policies.

ALBA Asia 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. The company will document its process for the anti-sexual harassment policy and a human resource person will be trained to log and treat GBV grievances as per company’s policy.  The company will also provide training to the workforce and contractors, including during induction on the policy, new procedures and any updating of the grievance mechanism to address sexual harassment/GBV (ESAP #6).

Retrenchment

ALBA Asia has no policy on retrenchment. The company is in a process of expansion; therefore, no retrenchment is expected at any of the company’s plants in the foreseeable future. However, the company will comply with the relevant provisions of IFC Performance Standard 2 and make explicit reference to retrenchment planning in the management system under ESAP #2. Based on the information provided by the company, there has been no retrenchment and the company does not plan any retrenchment due to the COVID-19 crisis.

Grievance Mechanism

The company’s grievance mechanism is introduced to each new employee during induction. The employees can report their grievances to either plant manager, HR managers, or labor union leaders. All the grievances and relevant responses and actions taken by the company are recorded. The HR managers/union leaders are required to report to senior management if they could not solve the grievance. HR email addresses and suggestion boxes are available for anonymous grievances. The company also has policy on protection against retaliation. The grievance mechanism will be reviewed to ensure it can adequately receive complaints around GBV (see ESAP #6 above).

Protecting the Work Force

ALBA Asia has well defined HR policy and procedure for prohibition of forced labor and child labor. ALBA Asia complies with national law and does not hire workers below the age of 18 years. The HR team checks birth and school certificates during the hiring process. No forced labor practices are used by the company.

Occupational Health and Safety

As indicated, the HW Jiangsu Plant is certified OHSAS 18001. All plants have routine OHS training, including new employee training and annual refreshers. Job hazard analysis (JHA) is conducted and updated for each operation position. Based on JHA, OHS operation procedures are developed and required personal protection equipment (PPE) is provided. The OHS procedures (e.g. PPE usage) are required, but not enforced strictly. With implementation of the corporate E&S policy and procedures at each operation sites as part of ESAP #2, OHS management practice will be strengthened, including OHS management and performance tracking for construction contractors. The company will set up key performance indicators targets (e.g., total recordable incidents, work permit review, etc.) for OHS performance. Construction contractors working will be contractually subjected to the same company’s OHS policy and procedures.

In line with ESAP #7, ALBA Asia will develop a standard operating procedure for waste acid unloading zone at HW Jiangsu plant, requiring sufficient pipe rinsing between different waste streams to avoid reactions. As required in ESAP #8, ALBA Asia will develop an ODH assessment and annual ODH monitoring program for biowaste treatment plants, which will meet local regulatory requirements and be consistent with good international industry practices (GIIP). The OHS management system, updated as per ESAP #2, will also incorporate labor health protection measures which have been developed to prepare and respond to COVID-19 health risks and other public health issues.

Workers Engaged by Third Parties

Labor compliance and OHS performance are part of the procurement’s qualification criteria developed when evaluating potential contractors for construction or other major works. ALBA Asia has established a contractor management program aimed at ensuring compliance in terms of labor management, OHS performance, and other legal aspects relevant to construction contractors and other third parties hired for company’s projects and business activities. The contractor employees also have access to the company’s worker grievance mechanism. The contractor management program will be integrated in the E&S management system aligned with IFC PS2.

Supply Chain

The hazardous wastes treated at the company’s plants are generated mainly from chemical industries and manufacturing plants. ALBA Asia has its own trucking fleet to collect biowastes from restaurants or residential communities and does not rely on the informal sector to collect waste for its facilities. 

ALBA Asia has developed Supplier Codes of Conduct that contains principles to ensure suppliers’ ethical conduct in labor, including prohibition of child labor and forced labor, working conditions, environmental protection and community health and safety. At the site level, a detailed Supplier Management Procedure has been developed. While at BW Hainan site, its suppliers are required to sign the Commitment to Environmental and Social Responsibilities, at HW Jiangsu site, there is no requirement on labor issues for the main suppliers. As part of ESAP #2, HW Jiangsu plant and all future plant sites will include appropriate procedure to assess main suppliers’ policies and procedure to prevent child labor and forced labor.                                                  

   Resource Efficiency and Efficiency Projects

With the implementation of the expansion plan  under the proposed investment, ALBA Asia’s operation in China will consume approximately a total of 418,000 metric-tons of water and 58,000 MWh electricity per annum, with the biowaste treatment plants being more water and energy intensive operations than HW treatment plants. At the existing plants, water is supplied by the industrial parks and electricity is from the national grid. Natural gas and liquid fuels are also used for steam generation and waste incineration. Given the locations within industrial areas, it is expected that similar arrangements for energy and water supply will be implemented at the pipeline projects.

All the wastewater streams from the HW Jiangsu plant are pre-treated onsite and recycled back to the process. ALBA Asia plans to improve wastewater collection at the truck washing area of HW Jiangsu plant to recover all wash water and avoid contamination. Resource efficiency varies significantly among different plants due to types and composition of different wastes. ALBA Asia plans to establish its own water/electricity consumption benchmarks for each type of wastes to improve the resource efficiency.

GHG Emissions

Based on the current operations and their expansions and with the establishment of the six pipeline projects included in the proposed investment, the company will generate approximately 68,000 tons of CO2 equivalent, mainly from consumption of electricity/natural gas and from fugitive emissions of natural gas from the anaerobic process at the biowaste treatment plants. The anaerobic process will generate approximately 7,000,000 m3 methane per annum, which will be manufactured onsite as CNG and sold as vehicle fuel to replace gasoline/diesel.

Soil, Groundwater, and Surface Water Contamination

A soil and groundwater investigation was conducted at HW Jiangsu site in January 2019. No concentrations were detected above the intervention value of applicable Chinese standards (i.e. Soil environmental Quality Risk Control for Soil Contamination of Development Land GB36600-2018 and the Class IV limits of the Standard for Groundwater Quality (GB 14848-2017).

In line with ESAP #9, the company will develop a site investigation and soil/groundwater monitoring program, which will be part of the corporate management system. The company will conduct site investigation for all proposed new plants or mergers/acquisitions, and will establish soil/groundwater baselines for each site. If there is any historical pollution at any given site that cannot be remediated to meet Chinese soil/groundwater standards, the company will not proceed with the project. For all its hazardous waste and biowaste treatment plants, ALBA Asia will also implement a procedure as part of its management system (ESAP #2) to systematically conduct routine soil/groundwater monitoring at its operational sites and ensure soil/groundwater is not impacted by its operations.

To prevent soil/groundwater contamination, all process areas of the two plants in operations have hard surfaces with impermeable HDPE layers. As part of its ongoing improvement plans, ALBA Asia will check and improve the impermeable layer integrity for the trenches and pits in the treatment area, waste storage area, and truck washing areas at both HW Jiangsu and BW Hainan plants (ESAP #10). All storage tanks have double containments or additional dykes to hold at least 110% volume of the largest vessel. The initial (15 min) rainwater first flush is considered as contaminated water, which is collected in the onsite storage ponds. If it meets discharge standards after testing, it is discharged to municipal drainage system or recycled back to production If not, it is treated before discharge or recycling. Any firefighting water used at the process areas is also collected for testing and treatment. The same prevention measures will be implemented in the pipeline projects. 

BW Hainan site is near an established municipal waste landfill. As required in ESAP #11, the company will conduct a soil and groundwater investigation to evaluate the potential off-site impacts and to establish a baseline and prevent liability risks in case of any potential remediation  in the future.  If the results show a potential contamination associated with the presence of the landfill, the company will report such results to the competent authorities. If a source of contamination is detected at the plant site, the company will eliminate such source and implement remedial measures consistent with GIIP.

Pollution Prevention– Hazardous Waste (HW)

All wastewater generated from HW Jiangsu plant is pretreated onsite and recycled back to process. The available environmental reports for HW Jiangsu Plant indicate that the current soil, groundwater, point air emissions, and ambient noise at the project site meet the regulatory requirements and are within the applicable and relevant WBG EHS Guidelines with the exception of volatile acid fume (hydrochloric Acid - 10 mg/m3). The plant will upgrade its alkali scrubber performance to reduce volatile acid fume point emissions and meet WBG EHS Guidelines performance level for hydrochloric acid (ESAP #12). The plant is also installing acid mist collection hoods at pressure filtration process to reduce fugitive emissions. Gypsum and all other solid wastes generated from the treatment process are sold as byproducts to other industries. According to the new regulation, ALBA Asia will test gypsum by toxicity characteristics leaching procedure to identify whether gypsum is to be classified as solid non-hazardous or hazardous waste. If it is hazardous waste, it will be disposed of at a licensed hazardous waste landfill.

Organic hazardous waste treatments, including incineration and solvent recycling, are planned to be installed at HW Hebei, HW Henan, and HW Guangdong plants. The company will design the treatments as per GIIP and consistent with the applicable WBG EHS Guidelines, in terms of wastewater discharges, fugitive and point emissions, and waste disposal (ESAP #13). For incineration operations, ALBA Asia will conduct match test (reactivity check) for each batch of waste before incineration and prepare daily loading sequences to ensure there is no violent reaction (or explosion) in the incinerator. For solvent recovery, the company will minimize usage of organic chlorides or other carcinogenic solvents to ensure workplace safety. If an onsite hazardous waste landfill is required, ALBA Asia will construct and operate a hard-layer landfill, which consists two concrete/HDPE impermeable layers and a working space of 2-m height between two layers for leak check, all consistent with the applicable WBG EHS Guidelines for Waste Management Facilities.

Pollution Prevention– Biowaste Waste (BW)

At BW Hainan plant, wastewater and leachate from the anaerobic digestion of restaurant and sanitary wastes are sent to a nearby industrial park wastewater treatment plant (WWTP) for further treatment and discharge. Wastewater generated from BW Hainan plant accounts for less than 10% of the WWTP capacity and its quality are monitored for WWTP influent criteria. From the available reports, the effluents from the WWTP meet local regulatory requirements. The effluents from the anaerobic digestion of agriculture wastes are sent to nearby contracted farms for land application. The digestion sludge is also sold as organic fertilizers for seed crops. Since the digestion temperatures are all in mid ranges, the effluents and sludge from the plant are exclusively used to seed crops to minimize potential pathogen impacts.

While the available point emissions and ambient air quality measurements at BW Hainan plant meet local regulatory requirements and applicable and relevant performance levels of the WBG General EHS Guidelines and the EHS Guidelines for Waste Management Facilities, fugitive odor emissions were found by the local environmental authorities to exceed the relevant national standard. A negative pressure zone will be built at the human waste unloading area to minimize fugitive odor emissions (ESAP #14).  While at the time of the acquisition in 2019, air emission monitoring program was not fully implemented at the plant, the monitoring program was resumed in 2020 according to local regulatory requirements.

The non-biodegradable materials separated from initial screening are sent to a nearby municipal waste incinerator for disposal. The other byproducts are sold to other industries as raw materials, including oil/grease for biodiesel, digester bottoms for organic fertilizer, etc.

The pipeline projects are still at an early stage of development and the biowaste treatment plants will be designed to meet national requirements and applicable and relevant WBG EHS Guidelines, including emission and wastewater performance.                                                

 Community Health and SafetyThe operational plants and the HW treatment plant projects are or will be located in industrial parks. The facilities will be designed and operated as per GIIP and therefore it is expected that their normal operations will have limited impacts to the local communities. As indicated under PS1, the company will develop and implement a procedure requiring each asset to carry out annual ER drills in coordination with local agencies, nearby hospitals, neighboring plants, and community representatives. In line with ESAP #15, ALBA Asia will development a community emergency response plan for both production site and transportation in consultation with the communities and healthcare facilities, including awareness raising and periodic drills. ALBA Asia’s community grievance mechanism allows the nearby communities to report their complaints / concerns related to community health and safety issues.  In addition, as part of the corporate E&S policies developed under ESAP #2, ALBA Asia will have a corporate procedure for the ESIA process requiring (i) the development of stack and fugitive emission models for all its projects and acquisitions of BW and organic HW treatment plants, coupled with the required ambient air quality monitoring, and (ii) the development of quantitative risk assessments for all its projects and acquisitions of organic HW plants.

Inorganic/organic hazardous wastes are transported by licensed hazardous waste transportation companies. ALBA Asia only contracts with transportation companies that, in addition to the hazardous waste transportation licenses, defensive driving programs, acceptable safe driving records, and the required emergency response methods. Biowastes are transported by company’s own fleet, which follow the similar requirements for contracted transportation companies, and undergo thorough cleaning and disinfection after each unloading at the treatment plant. All the waste transportation trucks are equipped with GPS system to ensure the trucks can only be driven on designated routes and complying with speed limits.

Security Personnel

The company contracts an external private security provider for plant site security that conducts routine ID checks at the gates and security monitoring. All security personnel are unarmed. For any serious issues, security personnel is required to report to the police stations inside the industry parks.                                                  

  Stakeholder Engagement, Communications, and Grievance Mechanism

At the corporate level, Stakeholder Engagement Plan (SEP) has not been developed and there was no stakeholder mapping and analysis conducted by ALBA Asia. Up to this point, for the current operations, ALBA Asia has taken an ad hoc approach to stakeholder engagement. The communities near the industry parks are the company’s key stakeholders. There is a public relationship officer at the corporate level to coordinate the engagement with main stakeholders. Each plant has a dedicated community liaison officer. The liaisons officer holds regular meetings with key stakeholders. Since all the local communities are outside of the industry parks and not adjacent to company’s plants, the liaisons reach out to the local communities though the social media (WeChat). The general public can report their concerns and grievances though WeChat. All the grievances are recorded for follow-up and mitigation.

As indicated in ESAP #19, the company will develop and adopt a Stakeholder Engagement Plan (SEP)in accordance with the requirements of IFC PS1, which will include details on stakeholder mapping and analysis, engagement strategy, and information disclosure. As part of the SEP preparation, the Grievance Redress Mechanism will need to be further formalized and strengthened to (i) receive and register external communications from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) analyse systemic issues and adjust its processes, as appropriate.

Information Disclosure and Ongoing Reporting to Affected Communities

ALBA Asia’s HSE&S Guidance requires that subsidiaries should conduct E&S information disclosure where appropriate. At the site level, each site conducts information disclosure during the EIA process as legally required. During operation, there is no formalized mechanism in terms of ongoing reporting to affected communities. As part of the ESAP #19, the ongoing reporting mechanism will be further formalized and strengthened. Key E&S performance data across ALBA Asia’s main operation and construction businesses will be disclosed to affected communities through an appropriate form and language.                                                   

  ALBA Asia will disclose this document in Chinese at its website (https://www.alba.info/cn/chinese-welcome.html). For inquiries or concerns about the environmental and social impacts of this project please contact:

Contact Person:  ZHAO Mingxi

Company Name: ALBA Group Asia Limited

Address:   1401 Air China Century Plaza, 40 Xiaoyun Road, Chaoyang District, Beijing, P.R. China, 100027

Phone:    +86 10 5643 6666