Environmental and Social Policies. Robust has a corporate level Environment and Social Responsibility Policy, which guides the implementation of its Environmental and Social Management System (ESMS). Environmental Impact Assessment (EIA) study, where needed by national authorities, provides for overall EHS monitoring and reporting. The scope of the policy covers all Robust operations (sourcing, storage and processing) and includes third-party suppliers. This policy includes an environmental and social risks checklist for due diligence purpose and a grievance policy mechanism. The policy commits the organization not to undertake projects that unnecessarily harm the environment, women, at-risk communities, or contribute to poverty, social inequality, or gender discrimination. The policy provides steps on how it could be achieved (i) having a clearly defined system to manage the company’s environmental and social responsibilities; (ii) continually observe, track, and provide updates to management on the status of the risks and impacts, including implementation and effectiveness of mitigation measures (e.g. Standard Operating Procedures (SOPs) during the project’s construction and operational phase; and (iii) provide sufficient opportunities for the informed participation of all stakeholders. Based on this policy review, IFC confirmed the alignment and consistency of Robust’s E&S policy framework applying to its operations with PS1 requirements.
Identification of Risks and Impacts. As part of the above mentioned ESMS, an E&S checklist is used for screening E&S risks of the company’s operations against (i) environmental risks and impacts, (ii) safe labor and working conditions, (iii) discrimination based on gender, nationality, race, age, sexual orientation, union membership or political affiliation, (iv) resource efficiency and pollution prevention, (v) community health, safety and security, (vi) biodiversity conservation. The E&S checklist is used as a due diligence procedure that ensure both the organization’s operational facilities, such as its warehouses and processing plants, as well as third party suppliers are complying with the company’s E&S Policy.
The Nigerian Environmental Impact Assessment (EIA) Decree No. 86 of 1992 requires entities to conduct ESIA process for all greenfield projects. As such, Robust will commission an ESIA for the proposed warehouses in Kano and Lagos sites and implement the E&S Management Plan (ESMP) resulting from these assessments (ESAP #1). The ESIA reports will be disclosed locally and communicated through the proposed Robust’s Stakeholder Engagement Plan (ref. ESAP#6 below).
EHS Management System and Programs. As described above, the company has E&S policies which guide the development of the ESMS. Based on IFC review, there is a need to further strengthen the operationalization of the ESMS by developing and effectively implementing SOPs, such as supply chain risk assessment and management, life and fire safety (L&FS), vehicle safety, integrated pest management (IPM), and stakeholder engagement plan (ESAP #2). Given the proposed expansion, Robust is encouraged to obtain certification for ISO 22001 on food safety and ISO 45001 on OHS management system, as part of achieving Good International Industry Practices (GIIPs).
Organizational Capacity and Competency. Robust has an organizational structure that defines roles, responsibilities, and authority to implement the ESMS. The overall responsibility for the E&S function rests with the Head of Impact who reports to the Senior Management. At the country level, the country managers have the overall responsibility and are assisted by the warehouse and processing facilities managers. The Nigeria’s Labor, Safety, Health and Welfare Bill of 2012 requires company to form and train EHS committees. The company is yet to comply with this requirement. The appraisal identified inadequacy of EHS training provided to workers. Going forward, the company will form EHS committees in all its operations, develop an EHS training program based on identified risks and conducts comprehensive EHS training to all its workers and contractors involved in the construction and operational phase of the proposed integrated facilities (ESAP #3).
Emergency preparedness and response plan. Robust has an emergency management policy which requires to have (i) a functional fire alarm and suppression systems at its integrated warehouse facilities which are regularly inspected internally and externally, serviced regularly and easily accessible, and (ii) fully stocked first aid kits that are easily accessible for all offices, warehouses and processing facilities. Potential EHS incidents that could result in emergencies are systematically identified during the EHS screening process using the E&S checklist. Despite having obtained fire safety permits issued by local authorities, Robust will further operationalize this policy by developing an emergency preparedness and response plan at each facility (ESAP #4). The plan for the warehouses and processing facilities will include (i) the designation of an emergency committee responsible for first aid and fire prevention, (ii) identify areas where accidents and emergency situations may occur, the response procedures (for fire, earthquake, flood and hurricanes, civil unrest and theft), (iii) provision of periodic emergency preparedness training (annual) and fire drill (semester) to personnel and contractors, including the participation of the Local Fire Department, and (iv) ensuring existence of clear marking of evacuation routes and assembly points as part of the evacuation plan.
Monitoring and Reporting. As part of its ESMS, Robust has a monitoring and reporting structure that ensure both the organization’s operational facilities, such as warehouses and processing plants, as well as third party suppliers are complying with the E&S policy. Going forward, Robust will develop an internal monitoring system which will include the monitoring of air emissions (point source and ambient) and noise measurements, compliance with national OHS requirements, including accident rates (lost-time accidents), primary suppliers risk assessment and management, and contractors’ EHS performance (ESAP #5).
No standard internal or external reporting was shared during appraisal. Robust is encouraged to adopt Global Reporting Initiative (GRI) Sustainability Reporting Guidelines (GRI G4) for reporting on all its processing operations, which will capture IFCs AMR, E&S DOTS and GHG parameters, among others, and allow for standardization of monitoring/reporting format for all Robust commodity lines and define corporate and product lines KPIs. As part of this project, Robust will continue reporting to concerned country/local authorities and IFC, using required formats.
Nigerian’ environmental, labor, industry and food safety authorities undertake monitoring of Robust’s operations, mostly for operational permit renewal purposes. As indicated above, major customers also undertake third-party audits against own company policies and/or industry benchmarks. Based on information provided during appraisal, Robust did not incur over the last three years any material regulatory penalties, fines or sanctions for contraventions or non-compliance with statutory obligations, as well as not reported any fatalities on sites at any of its operations.
Supply Chain Risk Assessment & Management. The two main commodities (sesame seeds and RCN) are purchased either at farm gate from smallholder (of more than 1 ha) growers or through a network of Licensed Buying Agents (LBAs) or aggregators who cover the main production areas. There are about 10 LBAs per region making a total of 40 LBAs across Nigeria, who work primarily for Robust. These LBAs are responsible for finding good stock, clearing the quality check in conjunction with Robust’s own testers, and transporting the goods to Robust’s warehouses. Micro-sized smallholder farmers (those with <1ha of land) are often encouraged to aggregate with other farmers to sell their stock as a cooperative. However, the company is yet to establish the database and supplier mapping of its sourcing for its two main commodities. The company is committed to have 100% traceability by 2025.
Robust has a HR policy and Supplier Code of Conduct which provide guidance on procurement requirements and guaranteeing that commodities are sourced in a responsible and ethical manner. The requirements are largely drawn from Ethical Trading Initiative (ETI) and International Labor Organization (ILO) conventions, including (i) requiring provision of good working conditions (e.g. contracts, health and safety, equal opportunities), opposing all forms of child labor, forced labor and all other forms of abuse and exploitation, (ii) adopting a Supplier Code based on the compliance of all suppliers with human and business rights, and health and safety, environment, and business integrity requirements. Every third-party supplier is required to commit to the policy by signing the Supplier Code. Robust’s legal department ensures continuous compliance. In case of material non-conformity, Robust may terminate an agreement with a supplier. All country officers are familiar with suppliers’ requirement.
The E&S risk procedures adopted by Robust to proactively avoid and mitigate E&S risks associated with its sourcing operations are contained in an E&S Risk Assessment Checklist, with a desk review conducted by management and full review and site-visit conducted by the country managers. While the checklist has some alignment with IFC Performance Standards, going forward, (ESAP#7), Robust will strengthen its contextual level screening and its pre-appraisal risk screening procedures applicable to PS2 and PS6 supply chain requirements through using country and commodity level risks screening (e.g. IBAT, Global Forest Change) to further support a risk-based approach to avoid social and deforestation risk in sesame seeds and RCN supply chain. Robust will then provide the risk assessment’s results to inform its sustainability sourcing strategies including achieving full traceability by 2025. In addition, Robust will be required to review and strengthen its Supplier Code (ESAP#8). The Code will apply to its primary suppliers over which Robust has a management control or leverage through long-term contractual or financial agreements. The Code will encompass the following steps: (i) initial screening of all agro-commodities sourced by Robust against IFCs PSs related supply chain requirements (harmful child/forced labor, significant OHS risks leading to life-threatening situations and risk of conversion of natural/critical habitats leading to biodiversity loss) to identify E&S risk factors and potential risk mitigation strategies; (ii) further screening using the risk management methodology outlined in IFCs Good Practice Handbook on assessing and managing E&S risks in Agro- Commodity Supply Chain; (iii) establishment of supplier database/mapping and supplier due diligence using tailored E&S questionnaire and supporting evidence of suppliers compliance with risk outlined in Robust’s Supplier Code; (iv) final risk assessment of suppliers and agreement on increasing sustainable sourcing strategies over time; (v) legal representation of supplier through signing Robust’s Supplier Code. As part of this project, Robust will select and implement digital mapping of the perimeters of all its registered and prospective sesame seeds and RCN (ESAP #9) as part of the traceability plan. The digitalization of these farms will validate avoidance of existing National Parks, Protected Forest Areas and recently converted natural or critical habitat. The digital platform will also capture socio-economic data (e.g. number of children, proximity to school) to prevent any risk of harmful child and forced labor. Upon selection of a suitable digital platform, Robust sourcing team will roll out the tool through farmer’s onboarding session and field survey.
Based on review of Robust’s HR and Supplier Code of Conduct, E&S Risk Assessment Checklist, and interviews with country manager and sourcing teams, IFC concludes that Robust has an effective foundation to manage E&S risks associated with its sesame and RCN sourcing in a manner compliant with IFC PS requirements. However, some enhancements are required, as discussed above and included in ESAP#7, #8, and #9.
Stakeholder Engagement Plan and Community Grievance Mechanism. Recognizing that the current and the proposed warehouses will be located in industrial zone, the company works with selected individual large farms and LBAs in rural areas with direct operational interface with local farmers. This is in addition to the induced traffic generated by sesame and RCN sourcing and related third-party harvester/transport companies operating in rural access roads. Going forward, Robust will develop and maintain a Stakeholder Engagement Plan (SEP) (ESAP #6), in accordance with IFCs PS1, and will include identification of stakeholders, determination of their level of interest and influence in the project (by importance and relevance), establishment of appropriate methods for engaging each group, and identifying strategic and forward looking programs and activities to support and partner with affected communities. The SEP will include a Community Grievance Procedure. Each warehouse manager should act as community liaison officer (CLO) to manage and respond timely to any community grievances on EHS risks and impacts associated with the company’s operations.
