The services provided by the company are limited to providing diagnosis of grove and tree health through use of technology. Therefore, the project is not expected to have adverse risks and impacts on communities, human health and the environment, including areas of biodiversity importance, indigenous lands or cultural heritage sites. Therefore, impacts to be managed in a manner consistent with PS3, PS4, PS5, PS6, PS7 and PS8 are not expected.

  The proposed investment is a Category B project in accordance with IFC’s 2012 Policy on Environmental and Social Sustainability. Category B projects are defined as those which have business activities with limited number of environmental and social impacts. These can be avoided or mitigated by adhering to performance standards, as described in the following sections. Key E&S  issues reviewed during IFC’s virtual appraisal include: (i) verification of  an E&S management system and implementation progress status; (ii) management of environmental, labor and occupational health and safety practices; (iii) fair and safe working conditions for employees and contractors, including implementation of workers’ grievance mechanism; and (iv) implementation of a Code of Ethics that reinforces customers’ compliance with applicable national E&S legal requirements . 

Environmental and Social Assessment and Management System. While the company does not have standard documented procedures for assessing environmental and social risks of its services, it has some procedures that constitute elements of an environmental and social management system (ESMS). These are contained in procedures for equipment operations and maintenance; material safety data sheet (MSDS) for battery pack, daily checklist for field operations; safety incident procedure; procedures for recruitment and dismissal of personnel, and Code of Conduct (namely 10 Commandments and Guiding Principles). Going forward, in accordance with ESAP Action #1, SeeTree will implement an ESMS, commensurate with the project’s risks and impacts, to meet IFC’s Performance Standards, including identifying and evaluating potential E&S risks and impacts (identification and evaluation matrices); defining relevant management plans and procedures; and incorporating a set of relevant E&S performance indicators into the company’s monitoring/reporting system and for management review. The ESMS will include at minimum; (i) corporate EHS policy that addresses SeeTree’s operations in its countries of operation, and aligned to IFC PS requirements; (ii) assignment of roles and responsibilities for EHS management; (iii) E&S risk and impact identification and management procedures; (iv) contractors/third-party workers’ E&S management procedures; (v) occupational health and safety (OHS) guidelines and key performance indicators (KPIs) for direct-staff and third-party workers; and (vi) any other aspects identified in the company’s risk and impact identification matrices. 

Policy. E&S related aspects are handled on a case by case and through the implementation of operational procedures. An overarching policy will be established defining the environmental, health and safety, and social objectives and principles that guide the company and its operations to achieve sound environmental and social performance, in compliance with the applicable laws and regulations where the company operates, and consistent with IFC PS requirements (refer to ESAP Action #1 above). 

Identification of Risks and Impacts. SeeTree diagnosis and assessments encompass several operational aspects of a fruit and nut orchard, such as irrigation, fertilization, pruning, crop protection and replanting, weather and harvest predictions. However, SeeTree’s scope of work is limited to the identification and early warning of diseases and yield improvement for trees inefficiencies and opportunities. As an example, SeeTree does not prescribe pesticides, as the treatment is the sole responsibility of the farmers with no involvement of the company. As indicated above, once developed, the corporate ESMS will include E&S risks identification and management procedures to guide risk identification and management across the business, consistent with IFC’s Performance Standards. (ESAP Action #1).  

SeeTree does not perform any screening and/or due diligence processes for its customers in terms of EHS standards and labor conditions. Going forward, to improve the comprehensiveness of its diagnostic platform and to contribute to customers alignment with voluntary international agribusiness standards, SeeTree may considered implementing a screening process to assess compliance of its customers against sustainability standards (such as Rainforest Alliance, Global GAP, Forest Stewardship Council (FSC), among others)..In addition, in accordance with ESAP Action #2, SeeTree will develop a Code of Ethics to be disseminated within its customers validating customer’s compliance with applicable environmental and social legal and regulations in countries of operations (e.g. environmental licenses). This Code of Ethics is expected to be reviewed and signed by its customers, partners, suppliers, contractors.

Management Programs. As indicated above, as part of its ESMS, SeeTree will define management programs associated with the company’s risk and impact identification matrices (please refer to ESAP Action #1 above).

Organizational Capacity and Competency. For routine operations, the Chief Operating Officer (COO) oversees environment, health and safety matters at the company. Human resources aspects are overseen by the Chief Financial Officer (CFO) and the Chief Executive Officer (CEO). Risks are managed on a case by case basis and the legal counsel is engaged when needed. A dedicated EHS Manager is expected to be hired in 2023.

Emergency Preparedness and Response. The Company headquarters and its subsidiaries are located in commercial buildings responsible for life and fire safety licenses, emergency plans, and for providing adequate security services that ensure safe premises. The company does not employ any in-house security personnel.

Monitoring and Review. The Company implements procedures to monitor and review E&S aspects associated with the quality of its services. SeeTree services are monitored and evaluated through KPI’s focused on yield improvement and farming efficiency with an overall goal of producing more food with less resources. These KPIs are monitored quarterly and generate environmental benefits, such as: (i) reduction of water use: the service that SeeTree provides allows for optimal utilization of water resources, e.g. by identifying over-irrigated areas (a common phenomenon, in California). SeeTree’s customers can optimize water resources and reduce its use; (ii) improved/reduced application of fertilizers: the company's service enables its customers to optimize fertilization according to actual tree-health needs, thus better utilizing fertilizers where needed while significantly reducing the excessive use of fertilizers where they are not needed. This reduces risks of leachate into surface and underground water bodies; (iii) improved/reduced application of pesticides: the company's service allows farmers to apply crop protection products (CPP) according to the precise measurements of tree heights and canopy volumes. This data can direct variable-rate spraying activities, including the cessation of spraying in areas where there are no trees or small trees. Additionally, the company develops applications that identify specific diseases and the incidence of pests, at the tree level. 

With the upgrade of the Company’s ESMS, as per ESAP Action #1 above, SeeTree will review and implement a corporate level procedure for monitoring E&S performance across all its operations, in line with applicable regulatory requirements and relevant and applicable sections of the World Bank Group (WBG) EHS guidelines (e.g. WBG EHS Guidelines for perennial crop production, 2015). The E&S monitoring system will define the KPIs, such as human resources, OHS incidents, waste management, (in addition to the KPIs related to the quality of services) to be monitored and the frequency with which these will be monitored. This system will link to and build upon the company's existing internal reporting and quality control systems.

 At appraisal, the company had 120 workers, including 49 direct employees and 71 third-party workers. Approximately 43 percent SeeTree’s workforce is female.

Human Resources Policies and Procedures. SeeTree has implemented human resources (HR) procedures related to recruitment and dismissal. The company has also developed an internal Code of Conduct (10 Commandments and Guiding Principles), which includes commitments with its personnel, customers and partners for equal opportunities, treatment and recognition regardless of their origins, gender, beliefs or physical condition and clearly prohibits any forms of discrimination or harassment. In addition, SeeTree developed the Prevention of Sexual Harassment Bylaws, which are guiding rules for sexual harassment prevention. The company, however, does not currently have an HR Policy in place that covers the guiding principles of this Performance Standard. In accordance with ESAP Action #3, SeeTree will develop an HR policy and related procedures, consistent with PS 2, including requirements related to: (i) working relationship; (ii) working conditions and terms of employment; (iii) worker’s organization; (iv) non-discrimination and equal opportunity; (v) onboarding and training; and (vi) grievance mechanism. As part of its HR Policy and in alignment with the company’s Code of Conduct, SeeTree will also emphasize its zero-tolerance approach for any case of gender-based violence (GBV), or workplace harassment. The policy will also outline roles, responsibilities, accountability and disciplinary procedures.

Working Conditions and Terms of Employment. Terms of employment and working conditions are defined in the contracts that SeeTree signs with its employees, and are consistent with the provisions of national labor regulations.

The company offers its workers competitive salaries, all mandatory benefits guaranteed by law (such as pension plans), and additional benefits (such as option grants to selected employees, educational fund, bonuses according to management's discretion, holiday gifts and other benefits), in order to attract and retain high performing staff. SeeTree has a documented approach to hiring and to terminating employment, should the case arise. All workers are allowed to associate with a union as the company does not restrict union membership.

Grievance Mechanism. SeeTree will establish an internal complaint mechanism to provide employees, including third-party workers, service providers, and other suppliers with a confidential channel to raise grievances about any misconduct or about any other issue in the workplace and improve governance and the working environment (ESAP Action #4). The Company will inform the workers of the grievance mechanism, which will include procedures to address concerns and grievances promptly, using an understandable and transparent process that provides timely feedback to those concerned. The mechanism will allow for anonymous complaints to be raised and addressed, and will not impede access to other judicial or administrative remedies available under the law or through existing arbitration procedures.

Protecting the Work Force. SeeTree systematically applies all national legislation and regulations on labor standards, including respect for labor rights, minimum age requirements, and prohibitions against child and forced labor.

Occupational Health and Safety. As observed during virtual appraisal, the Company does not have a structured OHS procedure for its operations in place. The main risks associated with OHS within SeeTree relate to field teams performing field work, i.e. visiting farms, flying drones, and driving ATVs to collect images and data.

SeeTree agreements with its customers include statements that the Company guarantees that all its staff (whether they are employees and other service providers) involved in the actual activity on the farms for which the services are provided comply with the safety rules.

As part of its ESMS, the Company will develop and implement OHS guidelines and KPIs for direct-staff and contracted workers, which will include (i) identification of potential hazards to workers; (ii) provision of preventive and protective measures; (iii) training of workers; (iv) documentation and reporting of occupational accidents, diseases, and incidents; and (v) emergency prevention, preparedness, and response arrangements (when applicable). KPIs will be reported to the Company’s senior management and board of directors. (please refer to ESAP Action #1 above)

Workers Engaged by Third Parties. Approximately 60 percent of SeeTree’s workforce consists of third-party workers performing different functions within the Company, such as engineering and software development engineers, desk analysts, and drone operators. All third-party workers have a contract detailing their terms of employment and working conditions, which are in line with country regulations. As discussed under ESAP Action #1 and #4, SeeTree will develop and implement a corporate procedure to formalize the management of its contractors, subcontractors, and other third parties working for the Company, aligned with its PS2 requirements and SeeTree Code of Conduct.

  SeeTree will establish a grievance mechanism to receive and facilitate resolution of external stakeholders, including customers and communities surrounding customers’ farms, about the Company’s environmental and social performance (such as field teams behaviour, disturbance associated with drones flying outside of SeeTree’s customers’ farms, etc.). The mechanism should seek to resolve concerns promptly, using an understandable and transparent process that is culturally appropriate and readily accessible, and at no cost and without retribution to the party that originated the issue or concern. (ESAP Action #5) 

Contact Person: Tzafi Erlich

Company Name: SeeTree Systems, Ltd.

Address: 114 Yigal Alon Street, Tel Aviv, Israel

Email: tzafi@seetree.co

Phone: 972-546-595099

Facsimile: N/A