All four terminals are in the designated and well-established industrial ports/industrial zones, with no residential communities in the vicinity. The operations within the terminals will not impact any communities outside of the port/industrial zones. Trucks transporting fuel are contracted by the local oil marketing companies and are inspected for safety compliance before loading. Hence no impacts are expected that need to be managed in a manner consistent with PS5: Land Acquisition and Involuntary Resettlement, PS6: Conservation and Sustainable Management of Living Resources, PS: 7 Indigenous Peoples, and PS8: Cultural Heritage.                                                  

 Key E&S risks and issues associated with this project include: adequate development and implementation of a comprehensive EHS and social management system; human resources (HR) management including that of contractors; implementation of occupational health and safety (OHS) measures; adequate management of wastes and emissions; and emergency preparedness and response for fuel storage and handling.

All four energy products storage terminals are located within the port/industrial zones and tank farms are not adjacent to the shorelines. The tank farms have recommended 110% of the biggest tank or 20% of the total capacity of the tanks secondary containment systems. All terminals have established EHS procedures and work instructions for operations. Terminals have vapor emissions control devices on storage tanks of liquid hydrocarbons made of pressure vacuum valves for AGO, HFO and Jet as well as Internal Floating roofs for PMS (gasoline). LPG storage reservoirs are closed systems and not a source of emissions. The potential adverse E&S impacts of this project are therefore limited in number and limited to project sites and may be readily mitigated. This is therefore an E&S Category B project in accordance with IFC’s Policy on Environmental and Social Sustainability (2012).

  Environmental and Social (E&S) Policy and Management System:

As a trading company of energy products, Addax mainly purchases the refined petroleum products from the international spot market. Addax follows its parent company, Oryx’s Health, Safety, Security, the Environment and Quality (HSSEQ) policy and has strict internal EHS procedures to review risks when evaluating fuel storage facilities.

Identification of Risks and Impacts:

Addax‘s environmental and technical risk/impact identification for its operations focuses on storage and transportation of energy products. Oryx/Addax routinely conduct EHS audits for its own storage terminals with both internal technical teams and external consultants. For the partner terminal in Côte d’Ivoire, Oryx/Addax will review partner’s EHS auditing reports and conduct routine walkthrough inspections for this project.

Organizational Capacity and Competency:

Oryx/Addax’s EHS management follows EU regulatory requirements and good internal industry practices (GIIP). Each terminal has a designated safety coordinator, in charge of various aspects of environment, OHS, and operational safety. The safety coordinators routinely check the firefighting equipment, road tanker safety, tank loading, and road tanker filling operations. Besides routine internal safety checks, all terminal management teams also contract third party experts to inspect tank integrity periodically or carry out major maintenance when required.

Emergency Preparedness and Response at the Terminals:

All terminals have fire prevention rules, and emergency preparedness and response plans. All terminals have appropriate fire prevention and response services, including firefighting water tanks, firefighting hydrants and monitors, alarm systems and foam-based firefighting equipment (except for liquefied petroleum gases that do not need foam-based firefighting) . The fire prevention and firefighting systems at all terminals were designed, constructed, and recently upgraded according to EU standards and meet the GIIP. The firefighting systems are properly maintained by its own staffs or third parties at regular intervals. The firefighting systems are also fitted with high pressure water pumps, which can be powered by onsite diesel generators in case of power failure. As part of emergency preparedness and response plans, fire/ER drills are conducted monthly at each terminal.

Monitoring and Review:

Regulatory inspections are conducted by relevant government departments for compliance with local EHS and operational safety regulations. Oryx/Addax conducts annual or biannual EHS/operational safety audits. The partner company in Côte d’Ivoire also conduct its own safety audits. The inspection/audit reports with corrective actions are recorded for implementation and reviews by future inspections/audits.                                                 

   Oryx/Addax currently have 187 employees in four West African countries for this project. Due to the nature of storage terminal management, the number of employees is low and there will be no new hiring for this project.

HR Policy, Working Conditions, and Terms of Employment:

Oryx/Addax HR policy and procedures are compliant with applicable Swiss labor laws. The corporate HR department is currently working to harmonize the HR policy and procedures across the group, including talent management, compensation/benefits, etc. A new corporate HR information system will be put into use for all employees across the group in later 2021 or early 2022. The employees in four West African countries for this project are covered by the corporate HR policy.

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.

Currently, approximately 25% of employees in four West African Countries are women. Women also hold management positions in these countries, including managing director in Sierra Leone. The HR policy has provisions relevant to respectful workplace, including prevention of gender-based violence (GBV).

Workers’ Organizations and Grievance mechanism:

Oryx/Addax allows collective bargaining and employees are free to join the unions that fit their needs in the local situations. All the employees can raise grievances anonymously through the union or HR management tracks. The HR policy has a grievance procedure which articulate how the grievances will be handled and resolved. The procedure is communicated to all employees as part of induction.

Occupational Health and Safety:

There have been no serious accidents or fatalities in the past 10 years in any terminal. Workplace risk assessment and monitoring are performed annually in compliance with the local regulations and Oryx/Addax procedures. OHS audits are also included in the routine EHS audit programs. Oryx/Addax provides all workers with appropriate personal protective equipment (PPEs) and enforces the PPE use strictly. Annual OHS trainings are also provided to all the staff handling hazardous materials. Regular HSSEQ meetings are performed in all terminals as well as weekly safety talks (toolbox meetings) to improve OHS and operational safety.

Supply Chain:

Addax purchases energy products on the international spot market. Since Addax’s suppliers are mostly large crude refining companies and traders supplied by such crude refiners who do not rely on low labor costs for competitiveness, child or forced labor are not expected to be encountered among Addax suppliers.                                                

 Resource efficiency:

All terminals have two main energy sources: the national grid and standby diesel generator. All pumps are well maintained to ensure energy efficiency. Since no production process is involved in the terminals, the resource consumption is limited for this project.

Fuel Storage:

All four terminals are old, but all were upgraded according to the EU standards and the current GIIP in the past four years (2016-2020). All tank storages areas have secondary containment dikes which hold at least 110% of the large tank volume. Specialized third parties are contracted to clean tanks and inspect tank integrity periodically. All the road tankers are inspected for safety before allowing to enter the terminals. The safety inspection includes permits check, exhaust spark prevention, brakes, PPE for staff, checklists, etc. Loaded tankers are also inspected to ensure road safety before leaving the terminals.

Greenhouse Gases (GHG) Emissions:

There is no manufacturing process in this revolving credit facility transaction. Current GHG emissions from the existing operations (based on electricity and fuels) are limited and well below 25,000 tons of CO2-equivalent per year. No new or additional GHG emissions are expected due to the proposed project.

Pollution Prevention:

There are vapor recovery installations for volatile fuels (e.g LPG) to prevent emissions to air of volatile organic compounds (VOCs). Fugitive emissions are minimized through enhanced routine checks and equipment maintenances. There is no other significant air emission source at any terminal. The only wastewater is sanitary wastewater, which is discharged to port/industrial park sewage system. The solid and hazardous wastes are limited (mainly oil absorption pads) and are collected by port/industrial park for disposals by approved local environmental contractors.

Coastal Environment Protection: The coastal environment will not be impacted in case of any catastrophes, such as structural failure or earthquake. There are barriers between all fuel storage tanks and the shorelines. The loading jetties were constructed or upgraded to EU requirements in respect to emergency shutdown, firefighting, and spill prevention features. Oryx, together with the port authority, conducts routine ER drills for coastal environmental protection according to International Maritime Organization (IMO) procedures.

The petroleum tankers are required to comply with all applicable environmental standards of IMO. The characteristics of the tankers must be certified to the standards by an independent control specialist in the field and approved by the manager of the terminals. Besides the certification, the petroleum tankers used for transportation of products financed under the Facility must be less than 20-year old.