TL is an e-logistics company and does not own or operate any infrastructure or physical assets (e.g. warehouses or distribution centers) with a physical footprint. The only physical assets are office facilities which are leased commercially. Therefore there are no impacts expected that need to be managed in a manner consistent with PS5 (Land Acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), and PS8 (Cultural Heritage), and no impacts are expected which are relevant to PS7 (Indigenous Peoples).    

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.                                       

 This is a category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific E&S impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards and guidelines.

Key E&S risks and issues associated with this project are relevant to the management of the fleet of registered trucks and the truck owners and drivers engaged in the underlying transportation and logistics business. Issues are therefore mainly related to oversight of compliance with applicable labor laws and Performance Standard 2 provisions by the company, its contractors and the truck owners and their drivers; safe driving and transport emergencies, all of which can be readily managed through development and effective implementation of appropriate environmental, health and safety, and human resource policies and procedures.                                                   

   Assessment of E&S Risks and Management Systems:

Truck Lagbe has procedures and practices in place for the day to day operations. As part of its operating system, the company has defined ‘Terms of Use’ which sets up the general terms and conditions of the mobile/web-based application. TL also has a SOP for the truck fleet operating under the platform and that includes (i) the onboarding process, (ii) training process, (iii) payment terms, (iv) completion rate, (v) shipper review percentage (rating) (vi) do’s and don’ts for the fleet owners and truck drivers, (vii) action plan for incident management.

The truck drivers registered with TL are required to carry valid driving licenses. Before registering any truck on the platform, the representatives of the company cross check whether the driver of the truck is carrying a valid driving license. TL also ensures that, apart from having proper driving documents, registered truck drivers and owners are also able to use the Truck Lagbe owner app properly. Going forward, as part of ESAP #1, TL will develop a Code of Conduct (CoC) for fleet or truck owners and truck drivers, compliant with national regulatory requirements and the relevant IFC Performance Standards and will include it in the standard contract/Terms of Use. The CoC will cover aspects such as prevention of labor risks such as child and forced labor, payment of wages and overtime, health and safety of the drivers, working conditions, working hours of drivers, gender-based violence / sexual harassment, safety requirements and road safety, transport emergency, restricted items for transportation, preventive maintenance of vehicles, use of security, and prohibited activities. Relevant training on CoC requirements will be included in the onboarding process. The company will also update its SOP to ensure that registered drivers/owners comply with company policies and procedures as set forth in the CoC.

As part of ESAP #2, Truck Lagbe will appoint a qualified E&S officer to update and align company’s policies and procedures with IFC Performance Standards, provide compliance oversight, and report to management and IFC. TL will define and communicate responsibilities and authorities for its personnel responsible for the implementation and compliance monitoring of various SOPs. The company will train staff on the updated company’s policies and procedures.

TL has an onboarding process for both newly registered owners and drivers, which includes both administrative requirements verification and training.  While TL does not have a direct contractual relationship with the truck drivers, the company provides training to the registered drivers to ensure a quality service, which also addresses basic safety risks. The onboarding training for the drivers outlines customer interface, driver’s behavior and features of the app. As indicated above under ESAP item #1, TL will complement the training sessions for drivers and fleet or truck owners with specific training on the company’s CoC, including defensive driving, driver health and safety, hours of work and road safety.

Monitoring:

Regular reports are submitted to the relevant authorities as per applicable legal requirements. Trips and earnings are monitored for their quality and timeliness. TL indicated that working hours of drivers and accident statistics are not monitored. Regular checks on state and condition of the trucks and safety / personal protective equipment are another area of improvement. As set forth in ESAP #3 Truck Lagbe will develop an Operations Manual to include procedures to monitor driving safety behavior (e.g., truck speed and routes), check state and condition of the truck, and monitor working hours of the drivers (see also under PS2). The Operations Manual will include an Emergency Preparedness and Response Plan and a Road Safety Plan for its operations in compliance with applicable regulations. Available safety performance data (accidents/incidents) of the fleet or truck owners registered in the platform will be collected, monitored and analyzed.

Emergency Preparedness and Response:

TL has 5400 square feet leased office space in Dhaka. As set forth in ESAP #4, TL will develop and implement an Emergency Preparedness and Response Plan (EPRP) for its office facilities. The EPRP will cover all potential emergencies (e.g. fire, short circuit and medical emergencies) and describe roles and responsibilities for relevant personnel (as well as their back-up), training (firefighting and first aid trainings) and requirement for emergency drills at defined intervals. TL will also provide portable fire extinguishers, emergency lights and first aid boxes at appropriate locations in the office area, as per relevant local requirements. All types of fire extinguishers will be labeled with user instruction and effective use period, as per recommendations of the local fire service and civil defense authority. Provision for emergency staircase for emergency evacuation, besides the regular staircase, will be available and free from obstruction. Emergency contact numbers of nearest hospitals, fire service, ambulance etc. will be displayed for easy accessibility.                                                

   The company has 90 direct employees, of which 22 are female, carrying out managerial, technical and support roles based out of the central office and call center in Dhaka. 

Human Resource (HR) Policies and Procedures : The company has a HR Manual which cover all operational matters as well as the grievance mechanism, safety and health procedures, prevention of sexual harassment mechanism, confidentiality, conflict of interest, equal opportunity, maintenance of reliable records, anti-corruption policies and controls, etc..

The company has committed to a policy on equal opportunity, workforce diversity and non-discrimination. The policies are communicated to the employees during the induction process by the HR department. All employees have a written appointment letter from the company explaining the working conditions and terms of employment; and their salaries are paid through the bank accounts. These policies are consistent with PS2 requirements. 

The company developed a grievance handling procedure and has implemented a formal grievance mechanism. As part of ESAP #5, it will update the grievance handling procedure by making provisions of anonymous complaints and inform the employees about the availability of the procedure during training sessions.

Workers’ Organizations: The company does not restrict or discriminate against freedom of workers’ association and will document it as a policy which will be included in the HR Manual, as part of ESAP #5. TL will inform the employees accordingly.

Work Force Protection:

Considering the operations and nature of the workforce, no child or forced and bonded labor is expected in the company’s own operations. The company’s Employment Policy as described in the HR Manual includes: (a) collection of age proof documents of all employees at joining; (b) employing persons above 18 years; (c) providing details of salary and deductions to all employees through offer and appointment letters.

Impact of COVID-19 Pandemic on Workforce:

The company implemented measures to protect workforce. A disinfection procedure was implemented the company’s offices, and COVID-19 protection awareness posts and blogs were posted. The company also reached out to registered drivers to follow company’s policy on social distancing. In addition TL has carried out disinfection services for the trucks.

Truck Drivers: 

At the time of IFC’s appraisal, TL had ~26,000 verified drivers. Drivers are either self-employed or employees of the fleet or truck owners. As indicated above, Truck Lagbe does not have a direct contractual relationship with the truck drivers, who are connected with customers through the platform. Truck owners and drivers are onboarded through the platform, where they submit the required documentation which is followed up through a document verification process by the company. TL manages its relationship with registered drivers through a Fleet team and a Customer service team. As indicated above, drivers receive training on app usage and ‘behavioral’ training.

Requirements regarding safety for drivers are set through the Bangladesh Road Transport Association (BRTA) and a Fitness Certificate. According to Truck Lagbe’s Terms of Use, customers are responsible for collecting all documents required by Bangladeshi law for the transportation of goods from truck owners. Long working hours are a potential source of health and safety risks. While truck owners are responsible for compliance with legal requirements, including working hours and safety of drivers, going forward TL will establish health and safety policies applicable to truck owners and drivers; conduct health and safety trainings specific for owners and drivers; ensure driver hours are appropriately managed, including through contractual requirements with truck owners; through Fleet and Customer service teams its monitor owners and drivers regarding health and safety issues and concerns; and ensure drivers are aware they can raise concerns regarding health and safety issues through the available grievance mechanisms. All this will be defined as part of the Operations Manual under ESAP #3.

Occupational Health and Safety (OHS):

Considering the type of operations, occupational health and safety (OHS) risks for TL employees are limited and related to sedentary work, ergonomics and visual fatigue. In 2020, the company organized eye checkup for employees and drivers.                                                 

 As indicated, TL does not own or operate any infrastructure or physical assets (e.g. warehouses or distribution centers) and therefore there are minimal risks and impacts that need to be managed in accordance to PS3. The company does not have resource efficiency and pollution prevention policies; however, it requires that registered fleet or truck owners submit the vehicle maintenance inspection certificate annually. The relevant requirements for fleet or truck owners are captured in the SOP for the fleet operating under the platform.                                               

   Community Safety: Road safety is key E&S issue and the company recognizes that it needs to be managed. TL does not have a specific road safety program involving registered trucks providing services under the company’s platform. The company’s app supports a GPS that allows to track the location of the truck. As part of the project, the GPS tracking system will be upgraded, and the company will consider features to support monitoring of driving safety behaviors. As indicated under PS1, the company will develop a Road Safety Plan and will work with fleet and truck owners to promote defensive driving training for drivers (ESAP item #3).

Security Personnel: TL does not hire security personnel and does not have (or procure the service of) any armed security escorting trucks or merchandise.