The proposed Dolicen facility has already been constructed within the existing 25 ha site in Morocco and the target facilities to be acquired in Nigeria are also all existing. The solar panels will be installed on the rooftops. No land acquisition is, therefore, expected for the project and no impacts as envisaged under PS5 (Land Acquisition and Involuntary Resettlement) are expected due to the project. Additionally, the Morocco and Nigeria facilities are located on land zoned under industrial areas near/within major cities. Hence, no impacts of the project are expected which must be managed in accordance with PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.

 This is a Category B project according to IFC’s Environmental and Social Sustainability Policy 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 Performance Standards (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 hazardous chemicals in line with applicable WBG EHS guidelines; (d) compliance with IFC PSs requirements in the supply chain (for PET bottles sourcing); (e) life and fire safety and emergency response (f) management of community impacts (traffic and security); and (g) community grievance mechanism.                                                  

Environmental and Social Assessment: Dolidol has prepared an Environmental Impact Study for the proposed Dolicen facility in line with the applicable legal requirements in Morocco which includes an Environmental and Social Management Plan (ESMP). The study and ESMP are commensurate with the E&S risks and impacts of the proposed operations. The company will implement the ESMP for Dolicen operations.

E&S policy, risk assessment and management programs: Dolidol has a quality policy and an OHS at work policy. The company is also developing an environmental policy. The company has implemented quality and OHS management systems which are certified as per the requirements for ISO 9001 and ISO 45001 requirements for its operations in Morocco. Implementation of the environmental management system is under progress as per ISO 14001 certification requirements at the Morocco operations. The same management systems will then be extended for Cote D’Ivoire operations. OHS risk assessments have been completed for the operations. Also, specific procedures have been developed and implemented on waste management, chemicals management, undesired events management (includes incident investigation and root cause analysis), personal protective equipment (PPE) management, work permit system, change management, health and safety committee process, internal audit and management of documentation. Dolidol also provides its employees with a safety handbook at the time of joining which includes the OHS policy and information on various OHS aspects (e.g., evacuation plan, emergency situation, general safety, confined space, work at height, electrical safety, work at heights) and their prevention including precautions related to COVID19.

Similarly, the target facilities in Nigeria have an integrated policy and management system on quality, environment and OHS certified as per ISO 9001, ISO 14001 and ISO 45001 requirements respectively. As part of the management system, OHS risk assessment and environmental aspects-impact analysis has been completed for the operations. Key E&S procedures were noted as being implemented at the visited facility.

Annual training plans are prepared at the Morocco and Nigeria facilities which include internal and external environment and OHS training programs.

As the Dolicen facility will be a new operation, the company will ensure that an environment and OHS risk assessment is completed for the proposed operations as per the company environment, OHS procedures and in alignment with IFC’s PS requirements. Based on the risk assessment, required prevention and mitigation measures shall be documented in an action plan to be implemented within agreed timelines. Further, the company will extend the same management systems at the other Moroccan operations to the Dolicen facility as well (ESAP#1).

In addition, for the target facilities, a gap assessment shall be completed of the associated E&S / OHS management systems relative to those of Dolidol’s E&S management systems along with IFC PS requirements. Based on the gap assessment, a corrective action plan shall be prepared and implemented within reasonable timelines (ESAP#2).

E&S organization capacity: Adequate E&S organization was noted to be in place for Dolidol’s operations and the target facilities.  In Nigeria this includes a National Safety Manager reporting to the company’s Chief Operating Officer (COO), who is the most senior management staff responsible for HSE. Additionally, each facility has a HSE coordinator, fire officer and fire captains and a work safety committee.

Dolidol has a quality, health, safety and environment (QHSE) department in place. The head of QHSE department reports to the Operational Excellence Manager, who reports to the Deputy General Manager for Support functions. In addition to the QHSE head, each division (e.g., foam, mattress, Cote D’Ivoire) has a QHSE manager supported by quality as well as health, safety and environment (HSE) supervisors. Fire safety teams are part of the QHSE team. Also, a HSE committee with management and worker representatives has been formed at the facility level. Similar organization will therefore be extended to the Dolicen facility.

Emergency response: Dolidol’s Morocco facility and target facilities have fire extinguishers, fire hydrant, fire hoses, sprinklers, smoke detection and fire alarm system. The facilities also have fire engine and dedicated fire safety teams. Dedicated fire water storage tanks and pumps (including diesel pumps) have been provided for these facilities. Fire safety systems are regularly inspected and maintained. Emergency response plans have been documented for Dolidol and Nigeria facilities for different types of emergencies (e.g. fire, medical) and regular emergency drills are conducted at the facilities.

Based on the risk assessment and as part of the company’s management systems, similar fire safety and emergency response systems shall be extended to the Dolicen facility.

Monitoring and review: Periodic noise, light and work area monitoring (including volatile organic compounds) was noted to be conducted for Dolidol facility. For the target facilities, regular ambient air quality, ambient noise and work area air quality monitoring are conducted. Going forward, as per the ESAP#1, the company will develop and implement 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, relevant and applicable World Bank Group (WBG) Environment, Health and Safety (EHS) Guidelines. Regular monitoring will be conducted for all Project activities as defined above and reports will be shared with IFC as part of annual monitoring reports.

Regular safety tours are conducted for Morocco operations by the HSE supervisors and management of each division. Reports are shared with the QHSE department and division heads. The company has also initiated safety tours by senior management. Finally, external audits like management system certification audits and fire safety audits are conducted.

Similarly, regular internal safety, electrical and environmental audits as well as external fire safety are conducted for target facilities. Audit results are collated across all facilities and reported to management by the National Safety Manager and discussed during a monthly management review.

Dolidol prepares a HSE dashboard for its Morocco operations which includes accident-incident frequency rates, HSE training, compliance rate on safety observations and legal compliance. A similar dashboard is prepared for Nigeria facilities which includes accident-incident, near-misses, audit compliance score (fire/electrical/housekeeping audits), fire drills and PPE compliance.    

Similar monitoring and review systems will be implemented for the Dolicen facility as part of the requirements to extending the company’s management systems to this operation.   

Dolidol employs 840 employees and 400 third party workers in Morocco involved in production, logistics, security. The target facilities in Nigeria employ 374 employees and 535 third party workers. The new Dolicen facility is expected to additionally employ 40 employees and 30 third party workers. 

HR policies, procedures, working conditions and terms of employment: Dolidol has documented HR policies and procedures, which cover operational matters (e.g. recruitment, HR services, company assets, medical and social insurance, managing attendance, exits). Also, the company has a code of conduct which describes the company’s commitments on various integrity and HR matters (including non-discrimination). The policies are accessible in the shared drive folder of the company.

The target facilities have a detailed HR handbook which describes policies and procedures in detail. The handbook includes the company’s commitment on various aspects covered under PS2 requirements e.g. non-discrimination, freedom of association, prevention of child and forced labor and grievance mechanism, amongst  other.

As is clear from a review of the respective HR documentation that there are differences in HR policies of the Dolidol (Moroccan) operations and the Nigerian facilities to be acquired by Dolidol. Thus, as per the ESAP, the company will ensure that common HR policies are documented for both the Dolicen and target facilities which are aligned with IFC PS2 requirements and include all aspects including a grievance mechanism. The same will need to be communicated at all project facilities (ESAP#3). 

Non-discrimination and equal opportunity: Dolidol have principles of non-discrimination included in its HR policy. The code of conduct has a specific commitment to provide equal opportunity in all aspects of employment and not to tolerate any unlawful discrimination or harassment. Similar non-discrimination policy is included in HR policies implemented at the Nigeria facilities.

Freedom of Association and grievance mechanism: Dolidol does not have a documented policy on freedom of association, however, it does not restrict employees’ right to freedom of association. The Morocco facility has an elected workers association/committee which periodically meets and discusses employee welfare issues with the management.

The target facilities in Nigeria have a specific policy on freedom of association through which a commitment has been made to allow workplace structures and associations for employees to present their views to management. The workers of the facilities belong to a union (National Union of Chemicals, Footwear, Rubber, Leather and non-Metallic Product Employees) whereas officers belong to a separate union (Chemical and Non-allied Metallic Products Senior Staff Association). Collective Bargaining Agreements (CBAs) are negotiated through discussions with nominated representatives of various companies in the sector.

A documented grievance mechanism is in place for the target facilities for both individual and collective grievances. The mechanism includes commitment to ensure no retaliation for raising any grievances. However, Dolidol currently does not have a documented grievance mechanism in place; this will be addressed via ESAP #3.

As part of the alignment of HR policies as mentioned above, the company will also develop and implement a grievance mechanism, which will be accessible for employees and contract workers and allow for anonymous filing of complaints at all project activities. Also, the company will ensure communication of the grievance mechanism to all employees and contract workers for all project activities. For prevention of sexual harassment complaints, a separate investigation and grievance handling procedure is to be developed and this is to ensure confidentiality of such complaints.

Prevention of child and forced labor: The HR policies for the target facilities include specific commitments not to employ child and forced labor. As per applicable legal requirements, only people 18 years and above are employed in the Dolidol operations. The policies will be aligned for the Project activities to ensure this requirement is enforced per ESAP#3.

Occupational, health and safety (OHS): As mentioned under PS1, the Moroccan and target facilities have implemented a certifiable OHS management system and have completed an OHS risk assessment for all operations. Also, key OHS procedures on personal protective equipment (PPE) usage, chemical handling, work permits for hazardous work, accident-incident recording and investigations have been implemented. Regular training is provided to employees and contract workers. During the visit to the target facility, no significant unmitigated OHS hazards were noted employees were wearing appropriate PPE including in the foam manufacturing area (where significant chemicals are used). Similar certifiable OHS management systems will be implemented for the proposed Dolicen facility.

Regular health checks are conducted for all employees in Morocco and target facilities. However, it was noted that the tests conducted are mainly physical examination with audiometry and spirometry as required based on the area of work. As the foam manufacturing process includes usage of toxic chemical like Toluene Di-isocyanate (TDI), as per ESAP #3, the company shall undertake an assessment of all relevant workers at the target facilities to confirm no past exposure to these chemicals. Also, results of the past health checks (for target facilities) shall be reviewed by Dolidol to establish a baseline of workers’ health conditions and appropriate corrective and preventive action plans shall be prepared to mitigate any OHS impacts due to their work locations within the facilities.

Third party workers: At the Moroccan and target facilities, third party workers support various manufacturing and ancillary operations. The workers are hired through external service providers under service agreements signed by the respective facilities. HR staff monitors compliance with labor laws. All third-party workers are provided safety induction as per OHS management systems and procedures of Dolidol/target facilities before starting work at the facilities and hazardous activities are controlled through permit-to-work issuance systems. HSE management teams monitor compliance of contract workers with the requirements of the OHS management systems.

For the solar panel installation, similar system will be followed. HSE requirements will be included in the contracts signed by the contractors and contractors’ activities on-site will be controlled by HSE teams through issuance of work permits and regular safety inspections.

Supply Chain: The Dolicen facility will initially rely on imports of PET bottles from EU countries. Subsequently, the company will establish a supply chain with Morocco and source PET bottles through aggregators. Considering that such a supply chain can have potential child labor involvement, as per ESAP#4, the company will:

(a)   Document clear compliance requirements for its suppliers which would include IFC PS2 requirements (i.e. no child labor, no forced labor, no significant safety risks/hazards) and basic legal compliance;

(b)   Before initiating local sourcing, screen its supply chain partners (i.e. aggregators of PET bottles) with respect to documented compliance requirements;

(c)   Include the compliance requirements in the contracts signed with the supply chain partners;

(d)   Establish a process of regular monitoring and inspection of supply chain partners to ensure continued compliance.    

Resource Efficiency: Dolidol’s Morocco facility has an on-site roof-top solar photo voltaic (PV) plant with 1 MW capacity, which supplies 35 to 50% of the facility’s consumption. About 2,550,000 units are generated from the plant on an annual basis. The visited facility in Nigeria uses solar lights for perimeter lighting.  As part of the project, additional solar panels with1.3kVA capacity on the rooftop of the Moroccan facility will be installed and same amount of electricity is expected to be generated from the plant. As part of the mattress manufacturing (in both Nigeria and Morocco), the foam waste is utilized internally or sold to external vendors for filling in pillows.

Air Emissions: The main sources of air emissions at the Dolicen facility will be gas-based steam boiler and diesel generator (DG) sets provided for power back-up. Similarly, the main sources of air emissions at the Nigeria facilities are DG sets for power back-up.

Although regular ambient air quality monitoring is conducted for target facilities, no stack emissions monitoring was noted to be conducted for the emission sources. As per ESAP#2, the company will include monitoring for all emission sources in its monitoring and review procedures for the Project facilities (mentioned under PS1). Regular monitoring will be conducted to ensure compliance against national standards and the WBG EHS Guideline limits. The reports will be shared with IFC as part of the annual monitoring reports.

Water and wastewater treatment: The main source of water for the Morocco facility is the industrial area water supply. For the Dolicen facility, additional needs for domestic water will be about 1750 m3 per year (or 6 m3/day). The industrial water consumption will be mainly for washing of PET bottles before recycling. The water will be circulated in a closed loop with treatment of wastewater generated and recirculation in the system. Additional water consumption for make up for water losses will be about 4000 m3/year (or 13 m3/day). Thus, the total consumption will be about 19 m3 per day.

As the mattress making is mainly a dry operation (except for water requirement for pigments), the main water consumption at the Nigeria facilities is domestic. Two of the target facilities have on-site borewells and water treatment plants. The other facility  buys water from outside.

Domestic wastewater in all facilities will be treated in the on-site septic tanks. No significant industrial wastewater is expected to be generated from the operations of Dolicen or Nigeria facilities.

Hazardous materials management: The key hazardous chemicals used in foam manufacturing include Polyol and Toluene Di-isocyanate (toxic chemical). In addition, pigments are used in foam manufacturing for adding colors. These chemicals also have fire safety risks. Material safety data sheets (MSDSs) are maintained for the chemicals used at the Morocco and Nigeria facilities. Staff working in chemical processing areas are trained and are provided appropriate PPE. Spill kits are made available for leaks.

Chemicals were noted to be stored in covered areas with secondary containment in Morocco. However, during the site visit, many chemical containers were noted to be stored in open areas without secondary containment at the visited Nigeria facility. As per the ESAP#2, the chemical storage and handling at target facilities will be specifically reviewed (as part of the gap assessment mentioned under PS1)  to assess their adequacy and required measures will be included in the action plan to be implemented within agreed timelines.

Waste management: Key waste streams generated from mattress manufacturing (at Morocco and Nigeria) include off-cuts of foam, plastic, paper/cartons and products containers (hazardous and non-hazardous). All waste streams in Morocco and Nigeria are disposed of through authorized agencies. In Nigeria, containers holding hazardous chemicals are decontaminated, cut into pieces (on-site by an external contractor) and transported off site.

Greenhouse Gas (GHG) emissions: The annual electricity and fuel consumption for the project activities is expected to be approximately 18 million units, 520 tonnes of liquefied petroleum gas and 100 tonnes of Diesel. At the same time, approximately, 2.5 million units will be generated from solar power plant.

Therefore, the GHG footprint of the project is estimated to be around 11,000tons CO2 equivalent per annum (tpa CO2 equivalent) including 2,000 tons (direct) and 9,000tons (indirect). Also, because of installation of the solar panels, the expected GHG emission savings are expected to be 1500tons per year.

Security forces: Morocco facility employs unarmed private security guards.

At target facilities, unarmed security guards are hired through a service provider and also, armed security personnel are engaged occasionally through formal request to the Nigeria Police Force. Nigeria facilities have a documented security policy, however, it does not include requirements/guidelines on use of force as well as processes on background checks of the guards. 

As per the ESAP#1, the company will document a specific security policy/code of conduct which will include behaviour with the community, workers 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 at all project facilities. In addition, the community grievance mechanism (discussed under stakeholder engagement) will also allow for complaints related to security forces.

Transport: Although the Morocco facility is located on industrial land, there are communities present nearby. Same is the case for two of the target facilities. Therefore, there can be traffic related impacts on local communities due to movement of raw materials and finished goods. Dolidol provides training to its drivers on road safety and is in the process of implementing road safety systems as per ISO 39001 requirements. The same will need to be extended to the target facilities and therefore, as per the ESAP #1, the company will develop and implement a traffic safety management plan to minimize risks and impacts on the communities from the project facilities.