PS5, Land Acquisition and Involuntary Resettlement is not applicable as all the expansion is within the existing MAL facility footprint and no new land purchase/acquisition is required for the project and no physical or economic displacement is expected due to the project. PS6: Biodiversity Conservation and Sustainable Natural Resource Management is not applicable because PRAN facilities are situated in rural areas qualified as modified habitat. PS7: Indigenous Peoples and PS8: Cultural Heritage are not applicable for the project because neither indigenous peoples nor culturally sensitive sites are present.                                                  

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. 

Key E&S issues related to this project include: (i) MAL’s capacity and systems to assess and manage E&S risk and impacts of the Project during both construction and operations; (ii) assurance of fair, safe and healthy working conditions for all workers including contract workers; (iii) utilization of equipment and operational practices that maximize conservation of energy, water and process materials including recycling and reuse initiatives; (iv) handling of solvents used in manufacturing of packing materials and management of air emissions, wastewater treatment and effluent discharges in compliance with national standards and World Bank Group (WBG) EHS guidelines, and solid and hazardous waste disposal; (v) community safety during construction and operations.       

Environmental & Social (E&S) Assessment: Considering that the expansion is within the existing footprint and no significant changes are expected in the nature of operations, no separate E&S assessment is required for the project. All new activities will be covered in PRAN’s risk assessment procedures as described below.

E&S Policy and Management Systems: PRAN has approved a corporate environment, health and safety (EHS) policy in Jan 2019, which is adopted by all its companies and implemented at all facilities. This EHS policy and Manual of Procedures (SOPs) covers all E&S risks and impacts of PRAN’s operations and is communicated to all workers, and other relevant stakeholders through displays. As required in previous ESAP agreed upon in previous IFC investments, PRAN has implemented an integrated management system (IMS) covering quality, environment and occupational, health and safety (OHS) aspects as per ISO 9001, ISO 14001 and ISO 45001 standards at MAL. The facility also obtained food safety and quality certifications as per British Retail Consortium (BRC), Hazard Analysis Critical Care Point (HACCP) and Halal. 

As part of IFC’s E&S Technical Assistance to PRAN, PRAN had drafted a corporate E&S management framework (ESMF) in 2016. The corporate ESMF has been adopted by PRAN senior management and relevant procedures have been implemented at MAL facility including on (i) risk assessment (aspect-impact analysis, hazard identification), (ii) EHS communication and training, (iii) resource efficiency objectives and targets, (iv) OHS procedures (e.g. permit to work, use of personal protective equipment, accident reporting and investigation), and (v) stakeholder engagement (external grievance mechanism).

Organizational Capacity and Competency: PRAN has a General Manager (GM) for its EHS function at corporate level, who has the overall responsibility of coordinating the effective implementation of E&S management system at all facilities, including MAL. At the facilities level, assigned EHS coordinators are responsible for the day-to-day implementation of the EHS management system. MAL has assigned a Deputy GM for EHS issues supported by a sub-assistant manager, who report to MAL’s Head and PRAN’s GM for EHS. In addition, a facility level EHS committee has been formed at MAL which discusses EHS issues on a monthly basis. Departmental level EHS committees have also been formed and are responsible to ensure implementation of corrective measures discussed in the facility level meetings. Existing EHS resources and technical capacity are considered to be adequate to ensure effective management of E&S risks and impacts at MAL.

Emergency Preparedness and Response: An emergency response plan (ERP) has been prepared for MAL. During the appraisal site visit, it was noted that required emergency response infrastructure has been implemented, including identified emergency routes, exit markings, displayed evacuation plans, marked assembly points, fire alarms (visual ones for high noise areas), smoke detectors (in unmanned areas) and firefighting systems (fire hydrants and fire extinguishers). Regular mock drills are conducted, and emergency wardens have been trained to support the effective implementation of the ERP. As the company uses Ammonia as cooling agent for its refrigeration system, Ammonia leak detection sensors and alarm have also been installed in the relevant areas.

The fire safety systems in the solvent storage and handling areas of Packmat are not considered adequate (see details under PS2). The company has completed an initial fire safety assessment for these operations. The company will prepare a corrective action plan based on this assessment and share an implementation plan with IFC (refer to ESAP #1, under PS2 section). The plan will be implemented in agreed timelines.

Monitoring and Review: MAL has implemented a monitoring and reporting program for regular monitoring of ambient air quality, stack emissions, effluent quality and work area noise, temperature and humidity in accordance with Bangladesh requirements and WBG EHS guidelines. Additional EHS indicators have been adopted to monitor resource consumption (energy/water), waste generation and training. All accidents/incidents are monitored, investigated, and corrective actions implemented, if necessary. The EHS coordinator conducts facility inspections and reports unsafe acts and other EHS issues to the facility management and PRAN’s General Manager for EHS. The GM-EHS also conducts regular facility visits, reviews implementation effectiveness of the ESMS, including EHS performance indicators, and follows up on the implementation of corrective actions. Based on these monitoring activities, a monthly EHS report is sent to PRAN’s GM-EHS, who then prepares a monthly corporate level report (covering all group facilities including MAL) for PRAN Group’s senior management review. MAL will regularly report summary of relevant parameters to IFC as part of the annual monitoring report (AMR). 

MAL has a total workforce of approximately 1850 workers including ~550 internees and trainees (workers who are in their probation period of three or six months, respectively). About 40% of the workforce is women engaged in variety of production activities.

Human Resource Policy, Working Conditions and Terms of Employment: PRAN has HR policies which have been documented in a HR handbook. The handbook includes specific policies on non-discrimination, freedom of association, harassment and abuse, prevention of child labor and forced labor and a worker grievance mechanism. The handbook also includes OHS guidelines on first-aid, emergency response, usage of personal protective equipment (PPE) and cleanliness. The HR department at each facility is responsible for implementing these Group-level HR policies.  The company provides meals to workers and childcare facility.

Terms of employment, such as wages, working hours, overtime, social security, medical insurance, pension and other benefits were noted to be in line with Bangladesh Labour Law and PS2 requirements. These are described in detail in all workers’ contracts and provided to workers at hiring stage. HR policy and procedures are communicated to all workers during induction, through their appointment letters and HR handbook.

Freedom of association and Grievance mechanism: A documented policy on freedom of association has been included in the HR handbook and it does not restrict workers to organize or bargain collectively. Currently, PRAN does not have a union at any of its facilities. Worker committees have been formed at MAL with equal representation of nominated workers and management and are tasked to discuss and resolve workplace issues.

The company has adopted the corporate grievance mechanism that utilizes multiple forums to receive grievances based on the type of grievance, including suggestion and complaint boxes through which workers can submit grievances anonymously. The grievance mechanism includes clear procedures to receive, register, and address grievances. Written grievances are reviewed by MAL’s Welfare department and escalated in case resolution is not achieved at the level of HR. The mechanism is extensively communicated throughout the facility through induction and displays. All grievances received were noted to be filed and recorded. Necessary actions are taken to address gaps within reasonable timelines.

Like all PRAN facilities, MAL has an anti-harassment policy (including sexual harassment) and has conducted training programs for all workers on this policy. Additional areas of improvements in the implementation of this policy are required. The company will conduct special awareness sessions for all supervisors and managers on prevention of sexual harassment (ESAP #2).

Additionally, IFC is working with PRAN on a Women Employment Advisory Program which will help PRAN develop, implement and promote gender-smart business policies and action plan. This will include policies on childcare, sexual harassment, OHS and gender awareness training for management. The program is initially focused on PAL and NAL and will be extended to MAL. This will further help PRAN’s implementation of PS2 related policies.

Non-discrimination: The company is an equal opportunity employer and has a specific policy on non-discrimination included in the HR handbook.

Prevention of child and forced labor: The company has a specific policy on prevention of child and forced labor. Age proofs are collected for employees and trainees/internees. No instances of child labor or forced labor were reported by the MAL facility.

Occupational health and safety: As per the requirements of PRAN’s ESM mentioned above and OHS management systems, MAL has completed an OHS workplace risk assessment at its operations. The company has rolled out OHS management programs, procedures and working instructions, such as work permit system, lock-out-tag-out, use of personal protective equipment (PPE) and accident/incident investigations. The company has established a Safety Committee comprised of both worker and management representatives, which meet on a regularly basis to develop and implement OHS corrective action plans. PPE was deployed at locations visited and equipment noted to be adequate to the workplace’s risk. In terms of housekeeping, work areas are clearly demarcated and safety signage displayed throughout the plants. All accidents and incidents are investigated to identify root causes and define corrective and preventive actions.

Significant quantities of solvents (Toluene, Methyl Ethyl Ketone, Ethyl Acetate, Iso Propyl Alcohol and Methyl Isobutyl Ketone (MIBK)) are used in the Packmat’s printed packaging manufacturing area. The OHS management practices need significant improvement as:

(a) the area did not have adequate ventilation and solvents are used in open containers;

(b) the PPE used by the workers were not appropriate for solvent handling;

(c) no work area air quality monitoring has been done in the area; and

(d) the area did not have flameproof electrical fixtures.

The company will study the viability of replacement or significant reduction of quantities of Toluene and MIBK solvents with other solvents (ESAP #1). Additionally, it will prepare and implement a corrective plan which will cover (among other measures):

(a)   Reduce the total quantities of solvents used by - precise dosing; elimination of leakage and spilling; elimination of open containers; reduction of open surface areas with solvents; and/or

(b)   Provide local exhaust ventilation for all emission points for organic solvents and ensure the exhaust system is capable of handling flammable substances and the exhaust vent is placed in a safe point away from air inlets, etc.;

(c)   Ensure provision of flameproof electrical fittings and required fire safety systems in solvent storage and handling areas;

(d)   Ensure PPE is available for all employees to mitigate risks to an acceptable level (e.g. through half mask with organic vapor cartridges for mixing and pouring activities, suitable gloves to prevent skin contact during mixing and pouring and when in contact the solvent or “wet” areas and eye protection);

(e)   Conduct personal exposure testing and health checks for operators immediately as well as on annual basis a suitable qualified specialist;

(f)    Regular volatile organic compounds (VOCs) monitoring in the work area;

(g)   Restrict the maximum quantities stored in the production areas and number of dosing allowed in day;

(h)   Provide suitable storage and mixing areas on the production floor with ventilation and secondary containment;

(i)     Install explosion detection and alarm systems in the storage and handling areas;

(j)     Create awareness among workers on handling of solvents; and

(k)   Dispose waste solvents properly.

The corrective plan will be shared with IFC and will be implemented within the agreed timelines (with priority actions highlighted above to be implemented first).

Third party: PRAN has several contractors providing services for its operations. All companies are legitimate enterprises and as part of the contracts, PRAN includes EHS requirements, including compliance with national labour and OHS legislation. Workers engaged by third parties have service contracts with a duration ranging from daily to yearly. Their terms of employment are aligned with IFC PS2 requirements and compliance is actively monitored at site by PRAN’ HR department. MAL’s EHS coordinators monitor the EHS performance of its third-party workers.

Any construction activity within the facilities is undertaken by Property Developments Limited (PDL), a group company. PDL has a documented safety manual which has been updated as part of previous ESAP to integrate IFC PSs and WBG EHS Guidelines requirements. Basic PPE usage (shoes, helmets) at the construction areas was noted to be adequate. Also, a safety induction is conducted for all construction workers. The workers accommodation (for construction workers) were noted to have improved, with reasonable size of rooms, basic sanitation facilities, fire extinguishers, drinking water, and access to other basic services.

Resource Efficiency: Water and energy consumption are monitored at MAL and reported in the monthly EHS reports. MAL has resource efficiency targets for electricity and water consumption for each of its production areas. Additional targets have been fixed for gas consumption for production and electricity/steam generation, reuse/recycling of back wash and other wastewater. The performance against these targets is monitored on a monthly basis and reported in the monthly report to the GM-EHS who then benchmarks all PRAN group facilities on various parameters, including resource efficiency. Required plans are then implemented at facility level to achieve improvement on these targets. As per the latest monitoring reports, MAL has higher per unit water consumption in confectionary production compared to other PRAN facilities. The company shall identify and implement required cleaner production audits and improvement plans for reducing the water consumption in confectionary production (ESAP #3).

Power Supply and Air Quality: MAL generates electricity on-site through its gas engines (three nos. with a total capacity of 11.5 MW) and sources electricity from the rural electricity board grid connection (~2.5 MW). Diesel generator set (1.5 MW) provides backup power as required. Gas based boilers are also used for steam generation for the process. Ambient air quality and stack emission monitoring are conducted on an annual basis and the available results reviewed during appraisal indicated compliance with Bangladesh standards and WBG EHS guidelines. The company will ensure stack emissions and ambient air quality are monitored regularly and the results will be shared as part of the AMR sent to IFC.

Water Supply and Effluent management: MAL sources water from its own ground water wells (4 nos.) and the groundwater extraction is monitored on a daily basis. The water is treated in-house for various uses through filtration and softening. The average water consumption at MAL is around … m3/day.

Domestic sewage is disposed in septic tanks and soak pits. Effluent treatment plant (ETP) is available at MAL with secondary treatment (activated sludge process) for treatment of industrial effluent. The effluent quality is tested regularly (internally on daily basis and by the Department of Environment every six months) and results showed compliance with Bangladesh standards and WBG EHS guidelines. MAL will regularly report effluent quality results in the AMR submitted to IFC.

Solid and Hazardous Waste: The main waste streams generated from the MAL operations are empty metal and plastic containers, paper/plastic packaging waste, cardboard boxes, and empty containers of solvents. Waste from MAL is stored in a scrap yard. Containers are washed and reused or sold whereas paper/plastic and other packaging material are segregated and sold to recyclers. All hazardous waste (used batteries and used oil) are disposed through authorized entities. The ETP sludge is stored in a concrete pit as there are no centralized waste disposal facilities. Records are maintained for waste stored at and disposed from the facility.

Hazardous materials management: The facility has a chemical handling and storage procedure which mainly covers solvents. During the site visit, fuel (diesel) and other oils were noted to be stored with adequate secondary containment. However, storage and handling of solvents requires significant improvement as (a) the solvents storage area did not have adequate secondary containment; (b) solvents stored in the production area did not have any secondary containment; (c) significant quantities of solvents were stored; (d) employees handling the solvents did not have appropriate PPE (gloves, masks, eye protection). Also, as mentioned above under PS1 and PS2, the production area did not have appropriate safety systems. MAL will develop and implement a corrective action plan as described under PS2 (refer to ESAP #1).

Greenhouse Gas (GHG) Emissions: Expected GHG emissions from the project are anticipated to be approximately … tonnes of CO2 equivalent (tCO2) (… tonnes direct and … tonnes indirect).

 The nature of the MAL operations does not present significant safety and security risks to nearby communities. However, there can be impacts due to the movement of vehicles on the access road to the facilities. Transport is used for receipt of raw materials or delivery of finished product. The company has prepared traffic management plan as well as external grievance mechanism to mitigate the risks.

The company does not employ armed security guards at its facilities. Security guards are appropriately trained to interact with the neighbouring communities and workers.                                                  

Apart from being a significant employer for the neighboring communities and a significant buyer of agricultural commodities, PRAN undertakes several initiatives to help nearby communities. Focus areas of these initiatives include education and health support.

As per previous ESAP, PRAN has developed a community grievance mechanism which will include clear procedures of receiving, processing and responding to community complaints and providing feedback to the complainant. This mechanism has been implemented at the MAL facility..                                                                                                      

 The company will disclose this ESRS and ESAP locally at the following address:

Mymensingh Agro Limited

Mulgaon, Kailgonj

Gazipur, Bangladesh.

All inquiries and comments on the project may be directed to:

Mr. Nirupam Dutta

PRAN-RFL Center

105 Middle Badda

Dhaka-1212, Bangladesh.

Telephone: +88-2-9881792

Fax: +88-2-8837464