All the proposed project facilities (under construction or being acquired) are located in the designated industrial areas and modified habitat. Also, considering the size and type of operations (mechanical blending, storage and dispatch), the types of risks and impacts envisaged under PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) are not expected. Based on the site visits, consultations and document review, no impacts are expected on Indigenous Peoples and Cultural Heritage.                                                   

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012) as the project is expected to have limited adverse environmental and social risks and impacts that are few in number, short-term and site-specific, and can be avoided or mitigated by adhering to recognized performance standards, good international industry practice (GIIP) procedures, guidelines and design criteria as described in the following sections.

Key E&S risks and issues associated with the project are: (a) implementation of adequate E&S management systems and organizational capacity to manage operations of project facilities in line with IFC PSs and World Bank Group (WBG) EHS Guidelines; (b) assurance of fair, safe and healthy working conditions for employees and contract workers in line with the applicable legal and PSs requirements; (c) management of air emissions, waste and effluents in line with the applicable WBG EHS guidelines; (d) compliance with IFC PSs requirements in the supply chain (i.e. processing platforms in Morocco); (e) community health, safety and security including impacts from transport; (f) land acquisition for the proposed facilities and mitigation of associated social impacts in line with IFC PS5; and (g) stakeholder engagement and grievance mechanism.                                                   

E&S Impact Assessment (ESIA): Environmental Impact Assessments (EIAs) have been conducted for all Cote D’Ivoire, Nigeria and Senegal facilities in line with the applicable legal requirements and include Environmental and Social Management Plans (ESMPs). All facilities except Sokoto have received required EIA approvals from the respective environmental authorities and the EIA for Sokoto is still under review.

For the facilities in Nigeria, EIA process included scoping workshops, socio-economic studies conducted in the affected communities, public displays done by federal ministry of environment (FMEnv) and the draft report review workshops.

The EIAs of project facilities included baseline socio-economic data and public engagement only as per legal requirements and some additional work is needed re. the discussion on social impacts, the analysis of social risks and impacts specifically related to government led resettlement as per IFC PS5 requirements and applicable legal requirements. The same has been described in detail under PS5. OCP Africa will ensure implementation of ESMPs for all the project facilities.

E&S Policy, Risk Assessment, Management Systems and Programs: OCP has implemented an Environmental and Social Management System (ESMS) comprising of a formal sustainability strategy, supported by several policies (last updated in April 2020) and corporate standards. OCP has a number of group level policies which are clustered into different aspects including sustainability, environmental management, climate change, community engagement, human capital, human rights, quality, purchasing, tax and code of conduct. The group has corporate policies on general sustainability, general environmental management, occupational, health and safety (OHS), general climate change policies as well as on specific environmental aspects of biodiversity, waste management, liquid effluent, phosphate stewardship, land use, energy, water, and air emissions. OCP also has policies on community engagement and community relations. Finally, the group has a number of human rights and human capital policies (more details provided under PS2). All the policies are publicly disclosed on OCP website and describe OCP’s commitments, along with the implementation, governance, compliance and monitoring, reporting and review mechanisms for each policy.

To support the implementation of above-mentioned policies, standards/management programs have been developed in collaboration with DUPONT OCP Operations Consulting (DOOC).  Additionally, other operational standards have developed internally by OCP on process risk analysis; works’ authorization/permit to work, HSE audit management, personal protective equipment (PPE) usage, traffic management, work at heights, confined space entry, energy isolation/lock-out-tag-out, emergency response, hygiene and working conditions and management of change.

OCP has a Risk Management Team, which, under the supervision of the Audit and Risk Committee carries out identification, analysis, and evaluation of risks including E&S risks and integrates them into the management plans of each business line in accordance with ISO 31000, ISO 22301, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Enterprise Risk Management Framework (2017) and other best practices.

Accordingly, to ensure implementation of corporate level policies, standards and risk management approach for the project, as per ESAP#1, OCP Africa will complete an environmental and OHS risk assessment for the operations expected/proposed at the project facilities. Also, specific procedures and standards aligned with the corporate management programs and standards will be developed for OCP Africa, which will be implemented at all project facilities within agreed timelines as per the ESAP.

E&S organization capacity: The Audit and Risk Committee of OCP assists the Board in controlling operations and reviews financial & non-financial data. The Operational Committee works in close collaboration with the strategic and management committees to determine short, medium and long-term strategies and approves targets.

In 2019, OCP created Sustainability Platform (SP) to coordinate and supervise implementation of the sustainability strategy as well as to discuss, co-create and initiate new ideas. The SP coordinates and supervises implementation of the sustainability strategy in cooperation with other departments such as Human Capital, Industrial Operations, Industrial Developments, etc. In addition to a cross-cutting department, the SP oversees a “circular economy” program (focusing on water and energy, emissions and waste valorization, phosphogypsum, phosphate stewardship, mining reclamation and agriculture) and making the circular economy an essential issue at all decision-making and operational levels of OCP. SP also oversees community engagement, compliance and sustainability external engagement.

OCP has “Health and Safety at Work” entities both at the group level and facilities level. The group level entity is responsible for structuring and leading the OHS management through the definition of standards, management system, processes, skills, best practices and modes of governance as well as supporting the facilities. The facility level entities are responsible for implementing HSE policy and standards, supporting the respective facilities in the deployment of the HSE excellence program and HSE projects.

As per ESAP(2), OCP Africa will assign/appoint a dedicated HSE manager and a community liaison officer from/within the SP or within OCP Africa organization who will be responsible for ensuring compliance of expected/proposed operations at the project facilities in line with IFC PSs requirements and corporate E&S policies. Also, HSE personnel will be appointed at each of the project facilities.

Emergency Response: As mentioned above, OCP has a corporate standard on emergency response planning. The facilities in Morocco were noted to have Crisis Management Plan (Plan de Gestion des Crises - PGC) in place. All three under construction facilities in Nigeria have implemented an emergency response plan. Workers were noted to be trained on emergency response procedures and operating fire extinguishers during the toolbox sessions. Although the drills were expected to be conducted on an annual basis, the same have not been conducted due to COVID19 related restrictions.

For the operation phase, as per ESAP(1), OCP Africa will develop an emergency response plan template considering all potential emergency scenarios, which will be followed at all project facilities. The emergency response plan will include frequency of training and drills as well as provision of required fire safety and emergency response equipment. Regular training and drills will be conducted to train all employees and third-party workers.

Monitoring, review and reporting: As mentioned above, OCP has corporate standards on environmental performance monitoring and HSE performance control. Based on appraisal observations and document review, all facilities conduct regular environment and OHS monitoring. Also, OCP has corporate standards on HSE audit and safety observations. The Internal Audit Group Department, which also reports to the Audit and Risk Committee, performs an independent audit to add value and improve organization’s operations.

As regards external reporting, OCP publishes a sustainability report with the most recent report being for 2019 (available at https://ocpsiteprodsa.blob.core.windows.net/media/2021-03/Rapport_2020_EN_Certifiee_2.pdf).  Third party auditors provide independent assurance statement on the financial statements (part of the financial annual report). Carbon footprint is reviewed annually by carbon certification experts. Additionally, for the sustainability report, a Global Reporting Initiative (GRI) certification organization provides assurance as per GRI requirements covering corporate’s sustainability performance during the financial year. Additionally, OCP discloses performance data / factsheets on specific E&S topics (https://www.ocpgroup.ma/performance-data) including on environmental management (e.g. air emissions, effluents, waste, climate, water and energy), human capital management (e.g. human capital, OHS, freedom of association, COVID19 response) and community engagement. The sustainability report for 2020 is under GRI certification process. Going forward, E&S performance data of the project facilities will be included in the sustainability reporting.             

Specifically, for the project facilities, OCP Africa will develop environmental and workplace monitoring procedures to specify the type and frequency of monitoring to be conducted at the project facilities as per applicable local standards, ESMP requirements and relevant and applicable World Bank Group (WBG) Environment, Health and Safety (EHS) Guidelines. Regular monitoring will be conducted for all project facilities and reports will be shared with IFC as part of annual monitoring reports.                                                   

The Group currently employees 21,000 employees. The project facilities are expected to employ about 24 employees (management staff) and 110 third party workers (for bagging, loading, cleaning and security services) at each facility.

HR policies, procedures, working conditions and terms of employment: OCP has publicly disclosed corporate policies on general human rights, general human capital, social dialogue, diversity, and inclusion and working conditions. All the policies clearly describe OCP’s commitments, implementation, governance responsibilities, reporting and review mechanisms.

The general human rights policy includes a commitment to respect the human rights of its employees by developing policies and processes with the aim of achieving uniform worldwide application. The working conditions policy includes commitment to fundamental rights in the eight International Labour Organization (ILO) core conventions including freedom of association and effective recognition of the right to collective bargaining, elimination of all forms of forced or obligatory labor, effective abolition of child labour, elimination of discrimination in employment and occupation. Through the policy, OCP has made specific commitments on working time, remuneration, physical and mental working conditions, social dialogue and retirement. Therefore, OCP’s corporate policies are aligned with PS2 requirements.

As the project facilities are still under construction (in Nigeria) or under planning (Senegal and Cote D’Ivoire), no specific HR policies have been developed or implemented for these facilities. As per the ESAP(#3), OCP Africa will document and implement HR policies and procedures in line with the corporate policies and PS2 requirements. Also, OCP Africa will ensure communication of policies to all employees through induction.

Non-discrimination: As mentioned above, OCP has a corporate policy on diversity and inclusion which includes commitments to non-discrimination practices, providing equal opportunities, creating a workplace free of harassment, implementing supportive internal mechanisms for special needs. OCP Africa specific procedures will be developed and implemented in line with this policy as per ESAP(#3).

Freedom of association: OCP has made public commitments to freedom of association under its general human rights and working conditions policies. OCP’s social dialogue policy makes specific commitments to freedom of association. OCP has workers union at its facilities in Morocco. Also, there are unions of the contractors active at the under-construction facilities of Ogun and Sokoto. OCP Africa specific procedures will be developed and implemented in line with corporate policy on this as per ESAP(#3).

Grievance Mechanism: Through its corporate policies on social dialogue and diversity and inclusion OCP has committed to implement grievance mechanisms across all OCP Group operations which are legitimate, accessible, available in the local language of each location in which it operates and explained to employees efficiently. As per the ESAP(#3), OCP Africa will develop grievance mechanism in line with the corporate policies, which will be accessible for employees and contract workers and allow for anonymous and confidential filing of complaints. Also, OCP Africa will ensure communication of the grievance mechanism to all employees and contract workers.

Occupational, health and safety (OHS): As mentioned under PS1, OCP has a publicly disclosed its corporate OHS policy. Also, the company has corporate standards/tools on workstation risk analysis, incident-accident investigation, HSE management for contractors and safety and environment visits and observation. Also, operational procedures have been developed on process risk analysis, permit to work, personal protective equipment usage, hygiene and working conditions, management of change, working in confined spaces and at heights, vehicular and machinery safety and EHS audits. OCP Africa will develop complete an OHS risk assessment for operations of project facilities, accordingly, OHS management procedures will be developed and implemented at all project facilities. 

All under construction facilities in Nigeria have implemented COVID-19 related preventive measures as per the government requirements including “no-mask-no-entry” policy, temperature checks, and sanitising and hand washing facilities for workers and visitors. Work has also been rescheduled on-site to reduce overcrowding and meetings are conducted observing social distancing. All expatriate staff are required to complete COVID testing.

Based on the site visit observations, the HSE guidelines were noted to be adequate commensurate to the risks. Usage of PPE was noted to be adequate. Safety signages were noted to be provided. All workers are provided with EHS induction prior to working on site. The HSE manager and officer conduct regular monitoring through random checks and inspections. Incidents/accidents are tracked and reported. Daily, weekly and monthly reports are prepared by the PMCs. No significant OHS hazards were noted on-site during the visits. No accidents/fatalities reported to have occurred at any of the three facilities except first-aid cases and near-misses. HSE guidelines will be implemented in similar manner at Senegal and Cote D’Ivoire facilities during construction.

Third party workers: Currently, about 200, 130 and 130 third party workers are employed at Ogun, Sokoto and Kaduna facilities for construction, respectively, employed by the project management consultants (PMCs), construction contractors and their sub-contractors. OCP’s HSE guidelines for contractors have been included in the contracts signed with the PMCs and contractors which include appropriate environment and OHS requirements. In addition, plans on accident and emergency response, waste management, construction traffic management, environment management and dust suppression have been developed for construction activities.

All construction contractors and PMCs have personnel on-site with HR responsibilities who monitor compliance with various labor law requirements.

For operational phase, third party workers will be employed for bagging, loading, cleaning and security services. OCP has a corporate supplier’s code of conduct which includes requirements for suppliers (including service providers) to comply with the applicable legal requirements, respect workers’ rights, not employing child and forced labor, and ensure safe, non-discriminatory and harassment free workplace. OCP Africa will need to ensure labor service providers’ compliance. Therefore, as per the ESAP and as part of the HR policy development, the Group will put in place procedures on contractor management to supervise and review compliance with applicable legal, IFC PS2 and OCP suppliers code of conduct requirements. The same will be implemented at all project facilities.

Supply Chain: As mentioned above, OCP has a corporate supplier’s code of conduct, which includes requirements on health and safety as well as prevention of child and forced labor.

Some of the inputs (DAP, , MAP, TSP, etc) for the fertilizers to be blended in the project facilities will be sourced from OCP’s processing platforms in Morocco (Jorf Lasfar and Safi). As OCP has required policies and procedures in place and considering the operations, no risks of child and forced labor are expected at Jorf and Safi facilities. Based on the visits to these facilities, no instances/issues on child or forced labor were noted.

In the past few years (in 2017 and 2019), among other issues, OCP’s operations in Morocco were alleged to be responsible for causing air pollution impacting the workers’ health (in addition to local communities). OCP’s corrective actions on this were reviewed during appraisal.

As per continual improvement approach and reduction of its environmental footprint, OCP has implemented a number of measures to improve its environmental performance about air emissions:

(a)   A real-time air emissions modelling system – Plumair, has been installed in 2015 at Safi and 2018 at Jorf Lasfar, which is linked to digital control room to monitor environmental parameters – Sulphur Dioxide (SO2), Particulate Matter (PM10), Hydrogen Fluoride (HF) and Ammonia (NH3). The system integrates real time monitoring data, weather factors and pollutant characteristics. This real time risk modelling enables immediate decision-making depending on the scenario.

(b)   OCP developed a SO2 capture process named “Sulfacid” which was deployed on five production lines (three at Safi and two at Jorf Lasfar) out of nine lines that reduces SO2 emissions by up to 99% to a level typically below 15 ppm. As per OCP’s Sustainability Report 2019, four additional lines will be equipped with Sulfacid by 2025 with reduction in SO2 load by 86% in Safi (by 2023) and 46% in Jorf Lasfar (by 2028) as compared to 2018 levels.

(c)   For reduction of PM, OCP implemented progressive shutdown of phosphate drying units and filters for all dry phosphate grinding units.

(d)   Upgrading of old sulfur melters at the two sites has been carried out in 2019 and construction projects for washing units for hydrogen sulfide gases are ongoing and expected to be completed by the end of 2021. These projects include the installation and commissioning of on-line gas analyzers hydrogen sulfide on all chimneys.

(e)   Also, OCP has been working on implementing required pollution control measures to achieve compliance with WBG EHS Guideline limits for key air emissions parameters. This is monitored through Plumair system and CEMs.

(f)    OCP conducts regular work area air quality study (once in three years) for its facilities in Morocco. The last study as completed in October 2019. The results were noted to be in compliance with Moroccan regulatory VME (Average Exposure Value) thresholds where they exist and with French VME thresholds when they do not exist (as for SO2 and dust) except for higher dust levels (beyond the VME threshold) in two of the workstations in Jorf Lasfar and higher HF levels in one of the workstations in Safi. Considering this, as per the ESAP(#4), OCP will share their corrective action plan and implementation timelines for these areas with IFC. Also, annual monitoring of the work area air quality will be conducted for the Morocco facilities to assess continued compliance.

(g)   OCP publishes fact sheets on a number of E&S issues on its website including one on air emissions. Last one was published in May 2020, which describes the work OCP has undertaken and planned on air emissions [https://ocpsiteprodsa.blob.core.windows.net/media/2020-11/A_OCP%20Air%20emissions_ENG_HD.pdf  ].

Based on the above, OCP has taken corrective actions to mitigate significant safety hazards for its workers.                                                   

Energy use and air emissions: Typically, the main power source at the project facilities will be the national grid. In addition, back-up diesel generator (DG) sets will be provided at the facilities in case of power cuts. Considering the current power scenario in the countries where project facilities are being established, DG sets are expected to be the main source of  power for some time at these facilities. For construction phase at Nigeria facilities, currently, the power is being sourced from DG sets. Also, dust suppression through water spraying is implemented at the facilities.

As part of ESMP implementation and monitoring and review procedures (covered under PS1), regular air quality and stack emissions monitoring will be conducted at the project facilities to ensure their compliance with applicable national and local standards and WBG EHS guidelines. Summary of these reports will be shared as part of the annual monitoring reports submitted to IFC.

Water supply and wastewater Treatment: The operations at the project facilities will not require water and therefore, the consumption of the water is only expected to be for domestic and drinking purposes. The facilities are expected to rely on state water supply grid or borewells (e.g. at Sokoto and Kaduna facilities in Nigeria).

No industrial wastewater is expected to be generated from the project facilities. Septic tanks will be provided to treat and dispose of domestic wastewater at the facilities. Run-off will be disposed of in the respective industrial area’s drainage system. Quality of the run-off will be tested for all project facilities as part of the monitoring and review procedures prepared under ESAP(#1) and PS1 against applicable World Bank Group (WBG) Environment, Health and Safety (EHS) Guidelines.

For ongoing construction of Nigeria facilities, at Ogun facility, the water is sourced through an external service provider whereas Sokoto and Kaduna facilities have on-site borewell(s). For drinking, packaged drinking water is sourced in dispensers/bottles/sachets. Mobile toilets have been provided at the site for workers.

Management of solid and hazardous waste: Considering the operations, the waste generation is expected to be limited to be non-hazardous waste (paper, plastic, metals), which will be sold to authorized agencies for recycling.  Used oil and oily waste will be generated on the site from DG sets and the company will identify a suitable authorized agency for disposal of this waste stream. As per the ESAP(#1), a waste management plan will be prepared for all project facilities. The plan will describe storage, handling, and disposal facilities for all waste streams.

A waste management plan has been prepared for all under construction project facilities in Nigeria. As per the plan all waste streams are identified (e.g. paper waste, food waste, cement bags, metal containers, metal and glass waste, used oil and oily waste) and segregated. Each site has identified a government authorized vendor which collects the waste from the site. Oil and metal containers are reused on-site. Similar waste management plan is expected to be implemented for construction of other project facilities.

Greenhouse Gas (GHG) emissions: based on the expected annual electricity and fuel consumption at project facilities, the GHG footprint of the project is estimated to be around 12,000 tons CO2 equivalent per annum (tpa CO2 equivalent) including 11,000 tons (direct) and 1000 tons (indirect).                                                   

Security forces. Unarmed private security guards are employed at all project facilities, however, Ogun and Kaduna facilities have armed security from the local communities and state police. As per the ESAP(#), OCP Africa will document a specific security policy/code of conduct (applicable to all project facilities) which will include Community conduct, Code of Ethics, Gender based violence aspects and implement clear guidelines on use of force as well as processes on background checks of the guards. The policy will be contractually binding for the private security provider and communicated to the security guards as part of the induction, as well as refresher training. In addition, the community grievance mechanism (discussed under stakeholder engagement) will also allow for complaints related to security forces.

Transport: Considering that these project facilities are being established in newly developed industrial areas, there can be traffic related impacts on local communities due to movement of raw materials, finished goods and construction materials. Therefore, as per the ESAP (#), OCP Africa will develop and implement a traffic safety management plan to minimize risks and impacts on the communities from the project facilities.  

Other construction impacts: There can be other community impacts due to dust and noise from construction. Based on visits to the under-construction project facilities in Nigeria, dust suppression plans have been developed and required measures like water spraying have been implemented. Construction hours are regulated to ensure no significant impacts due to noise.

To assess any potential community risks and impacts, as per ESAP(#1), OCP Africa shall complete a community risk assessment and any improvement areas identified should be included in the CAPEX for the proposed facilities. The improvements shall be made as per agreed timelines with IFC.