Impacts linked to PS8: Cultural Heritage are not expected since there is no presence of known cultural assets or artifacts within the group’s operational footprint. Mavin Group will assess and manage any issues related to PS8, as needed, as part of its Environment and Social Management System (ESMS).

 The proposed investment is a Category B project in accordance with IFC’s 2012 Policy on Environmental and Social Sustainability. Key E&S risks and impacts from this project are limited, site-specific, and can be readily addressed through generally accepted mitigation measures described in this document and the attached ESAP. The E&S risks and issues are: (i) existence and effectiveness of Mavin Group environmental, health and safety (EHS), human resources (HR) and food safety (FS), and Product Safety management systems at its Farms, Feed Mills, Food and Veterinary Products facilities including legally required environmental permitting and mitigation measures for solid, liquid (manure/organic wastes/waste water), and packaging waste; (ii) organizational capacity for implementing, monitoring and reporting at Group and company ESMS; (iii) labor and safe working conditions of direct employees, and contracted farming operations, including oversight on management on Occupational Health and Safety (OHS) standards; (iv) emergency preparedness and response; (v) compliance of contractor farm operations with EHS/HR requirements; (vi) monitoring of EHS parameters (air emissions, effluents), including water and energy use; (vii) sourcing of raw material inputs for feed mill operations; (viii) animal welfare management practices in pig farms; (ix) stakeholder engagement and community grievance mechanism. IFC PSs, World Bank Group (WBG) Environmental Health and Safety (EHS) General and Sector specific (Food and Beverage Processing; Mammalian Livestock Production; Poultry Production) Guidelines (2007); and the IFC Good Practice Note (GPN) on Improving Animal Welfare in Livestock Operations (2014) are applicable to this investment.

 Environmental and Social Policies. The Group level policy is focused on compliance to prevailing E&S laws and regulations within Vietnam. This commitment results in application of relevant E&S requirements based on respective subsidiaries’ operations. Mavin Feed maintains voluntary certification including ISO 9001 and plans to pilot Global GAP. Mavin Food maintains ISO 22000 and Hazard and Critical Control Point (HACCP) food safety certifications. Mavin Farm pilots VietGAP for its breeding farms. Mavin Vet maintains WHO GMP (World Health Organization for Good Manufacturing Practice) as certified by the national authorities for its production facilities. While these commitments add weight and include some elements aligned to IFC PS1, the Group level needs to expand these objectives and commitments in achieving IFC PS1 E&S objectives (ESAP #1).

Identification of Risks and Impacts. Mavin Group adheres to the national regulatory requirements for new facilities and sites constructed for business purposes. This involves engaging a qualified consultancy to undertake the Environment and Social Impact Assessment (ESIA) study, having this verified by the regulatory authority (Provincial Department of Natural Resources and the Environment - DONRE) that issues the environmental permit prior to construction. Based on the identified E&S risks from the proposed operations, the Group companies are required (by site) to submit periodic environmental monitoring reports. The ESIA reports for the farms typically assess the impacts from construction and operations and include: (i) use of natural resources (water consumption and management of wastes); (ii) odor management and mitigation of gases emissions from animal waste through the application of biogas capture systems and proposed use of methane gas in generation of energy; (iii) and wastewater (monitored in accordance with the prevailing regulations for discharged of treated wastewater to a water body/land application).

The process of Mavin Farm engagement with contracted Porker Farm partners includes a legal due diligence (at point of engagement with any partner) requiring the proposed partner to verify permit documentation held with legal documentation. This legal documentation includes land title/lease, relevant business and environmental permits. 

For its operations, Mavin Group states that it maintains valid environment permits for all the commissioned facilities, including the feed mills, pig breeding and contracted Porker farms, food production and veterinary product operations. There is no centralized system to ensure monitoring and reporting to track legal and regulatory compliance of all entities within the Group, particularly as this relates to the contracted Porker Farm operations under Mavin Farm (ESAP #2). This permits register shall be integrated into the Mavin Group level ESMS (ref. ESAP #5).

Mavin Farm does not apply active supervision of its contracted Porker Farm operations for E&S compliance. A presented example of compliance monitoring did not include the process for monitoring, assigned roles, the determination on the level of severity, nor the enforcement process for continued noncompliance. As IFC PS1 commitments are applicable to the Group level, at a minimum Mavin Farm needs to apply a consistent/transparent oversight approach to ensure periodic E&S reports (required under environmental permits) are fully completed and submitted by its contracted Porker Farmers (ESAP #3).

All three greenfield breeding farms are within rural locations with secondary data highlighting the likelihood of impacted stakeholder groups, ethnic minorities, risks associated with land acquisition/compensation, and potential biodiversity. Mavin Group will review and update its Site Selection Checklist to ensure that PS5, PS6, and PS7 risks and impacts are addressed (ESAP #4).

Mavin Farm operates (at the date of this due diligence)  (i) five breeding farms with ~3,250 sows, (ii) 15 PS farms with ~15,400 sows, and (iii) total 36 contracted/rental Porker Farms with ~257,000 head. Mavin Feed operates five mills, with Mavin Food and Mavin Vet operating one factory each. All farms applied a strict biosecurity protocol, with one contracted Porker Farm having received VietGap, all mills are ISO9001 certified, with food processing ISO22001/HACCP and Mavin Vet is GMP certified.  There are standardized OHS approaches applied to the feed mills that includes good housekeeping for management of dust related risks and applying permit work processes, but there is no IFC PS 1 aligned formalized and systematic process for management of supply chain related risks for material inputs. There is no proactive oversight on contracted farms, nor on the construction operations for the new farms under this investment (ESAP #5).

Management Programs. Mavin Group does not have a comprehensive EHS Management System in place at the corporate level relying on each entity to manage its compliance with applicable national regulations. Mavin Farm all owned operated, and contracted farms have wastewater treatment (WWT) facilities that meet GoV regulatory requirements. Prior to engaging with farming partners, Mavin Farm do evaluate the sites for compliance, including sighting of biosecurity measures and the quality of the farm infrastructure such as wastewater management. This is also supported by legal verification of the farm’s documentation (incl. environmental permits). Although it is recognized that these approaches address some PS1 elements, the process does not include active E&S monitoring and review of the contracted operations. To ensure greater E&S monitoring oversight and prepare the Group for its future expansion, a Group level ESMS needs to be established based on its updated corporate policies (ref. ESAP#1), renewed commitment to apply IFC PSs and GIIP requirements and define the E&S performance benchmarks for its subsidiaries (ref. ESAP#5). 

Organizational Capacity and Competency. There are no EHS/Sustainability function, nor E&S roles appointed at Group level. The Group has no system in place for implementing a Group-level EHS system and no dedicated EHS roles to oversee, manage and monitor this. With the planned expansion of Mavin Farm operations and increased in compliance and GIIP needs, Mavin Group will require additional human resources to support and guide this implementation (ESAP #6).

Emergency Preparedness and Response. Mavin Feed feed mills have in place firefighting and rescue plans based on the local government regulatory requirements. These plans are supported with firefighting drills with the local fire departments and annual fire drill testing. Mavin Farm includes ERPs for management of biosecurity related needs. Mavin Food and Vet having in place ERPs that include fire, hazardous chemicals spills (Mavin Vet), and COVID outbreaks.  There are no ERP plans for the farms, especially in case of WWT plant spillages that could result in accidental discharge to surface water bodies or the natural environment (ESAP #7).

COVID-19 Impact. There has been no significant health impact due to COVID-19 on the workforce at Mavin Group. The Group approach has complied with the GoV requirements, including regular monitoring of the workforce, and isolation protocols.

EHS Monitoring and Reporting. In accordance with environmental permits, WWT plant discharge will be monitored for the farm operations by third party consultants and submitted to the DONRE on a quarterly basis. Monitoring on treated wastewater are conducted for biological and chemical oxygen demanders, total suspended solids, ammonia, pH, phosphorous and nitrogen levels. This is particularly relevant for treated water discharged into land application. Mavin Feed, Food and Vet are submitting reports on ambient air, workplace, waste, and wastewater discharge on a quarterly basis. No active monitoring oversight is applied to the contracted Porker Farms (ref. ESAP #2 and #5).

Supply Chain Risk Assessment and Management. Mavin Feed sources wheat, corn, soya, and other feed grains from a variety of local, regional, and international suppliers. The main supplying countries for maize, soyabean/meal and wheat include Brazil, Argentina, India and USA (~200,000 metric tons per annum). Cassava and rice are sourced from Vietnam, Laos and Cambodia (~16,000 metric tons per annum). GMAP and risk screening for targeted commodities sourced from Argentina, Brazil, Cambodia, India, Laos, and Vietnam highlights risks related to child and forced labor and natural habitat conversion. Although it is acknowledged that Mavin Feed has minimal control over spot acquisitions from international traders, Mavin Feed does acquire wheat bran, rice related products and cassava domestically and from Cambodia and Laos (ESAP #8).

Mavin Group head office has 43 workers (gender breakdown at 1:1).  Mavin Feed has 574 direct employees (gender breakdown at 3:1 male to female). Mavin Farm owned and controlled farms has 565 workers (gender breakdown at 1:1), and Mavin Vet has 110 workers (1:1 gender breakdown).

Human Resources Policies and Procedures. Mavin Group and its subsidiaries adhere to the labor law of Vietnam which is demonstrated following the reviews of the Group, and subsidiary level collective labor agreements/HR policies and procedures. This review confirms general consistency with IFC PS2 objectives, including, among others, working hours, overtime limits and payments (for Mavin Food only), annual and maternity leave, salary and benefits, social insurance, health insurance, accident insurance, and resolution of labor disputes.

Working Conditions and Terms of Employment. For all Mavin Group’ subsidiaries, terms of employment and the rights and responsibilities of workers are formalized into employment contracts and communicated to all direct employees along with the Internal Labor (HR) Regulation. Under the employment terms (that strictly follow the national labor law), workers employed within Mavin Group’ companies are on full time contracts. All workers are paid in accordance with the labor law. Working hours are per national labor law requirements, i.e., not more than 48 hours a week. All employees are enrolled in social insurance, covering pension, unemployment, medical, injury, and maternity. All employees and their families are covered with accident and medical insurance. In addition to basic salary, facility employees are provided with various allowances, including hazard pay, allowances for frontline workers at the pig farms (living-away-from-home allowance, meal allowance, etc.), mid-shift meal allowance, per diem, uniform and personal protective equipment expense, and rental allowance. Employees also receive annual health check. It was noted in the review of HR regulations that only Mavin Food included references to voluntary overtime and the compensation scales. Given biosecurity concerns and lengthy quarantine periods associated with gaining access to and working in the pig farms, the workers are provided with living accommodation on the farm and meals in the canteen. While strict biosecurity protocols are required there are no undue restrictions placed on employees’ freedom of movement with scheduled time off consistent with labor law requirements. The observed workers’ accommodation confirms the compliance with IFC/EBRD Workers’ Accommodation Guidelines.

Sampled labor agreements reviewed for contracted Porker Farms defined terms and conditions, hours and location of work, benefits and entitlements all aligned to the national labor code. This confirms the company requirement to ensure compliance for contracted farms to national labor regulations. There was no process in place to monitor this compliance (ref. ESAP #2 and #5).

Workers’ Organization. As per the provisions of the Vietnamese Labor Code workers have the right for freedom of association and collective bargaining. This provision is explicitly reflected into Mavin Internal Labor (HR) regulation and its existing collective labor agreement.

Non-discrimination and Equal Opportunity. There is a policy on non-discrimination and equal opportunity within the Mavin code of conduct. No procedures and/or practices have been identified as discriminatory. All the hiring and promotions are merit-based. There is no difference in terms of salary for female and male employees with the same experience for the same type of jobs. Mavin has a Code of Conduct on respectful workplace and relations between company and its employees and among employees in accordance with Vietnamese laws and regulation. The company has a documented process for the anti-sexual harassment policy and mechanism to receive allegations of sexual harassment in the workplace. This process will benefit from strengthening its mechanism for receiving complaints that protects the identity of the complainer and investigates the process based on a survivor centered approach.(ref. ESAP #9).

Worker and Contractors’ Grievance Mechanism. HR procedure for workers’ grievance is reflected in the Grievance Policy. As per the procedure employees can raise their grievances through mailboxes placed at each facility. In addition, employees can raise their grievances through face-to-face meetings, by talking to HR department or through the labor union. No channel is available for anonymous filing of grievances or concerns and responses to anonymous grievances. Confidentiality and non-retribution policy are not explicitly mentioned in the existing Grievance Policy (ref. ESAP #9).

Protecting the Work Force. All workers exceed the minimum age of 18 years, records of proof of age are kept, and there is no evidence of forced labor practices. However, there is no explicit policy and process related to child and forced labor from any Mavin Group’s operations, including contracted farm arrangements. (ref. ESAP #9).

Workers Engaged by Third Parties: Labor agreements between contracted security staffs was found to be non-compliant to the labor law and PS2 requirements with gaps identified in working hours, confirmation on compliance to minimum wages, licensing requirements nor any clarity and training standards for codes of conduct for security (ESAP #10).

Supply Chain: There are three channels of supply chain workers within the Mavin Group: (i) contracted farmers of Mavin Farm; (ii) Mavin Feed; (iii) Mavin Feed and slaughterhouse operations supplying the meat processing facility. Mavin Food engages with a third-party slaughterhouse to cull and process its pigs, as such shall have labor practices evaluated as a provider of core business services (ref. ESAP #10).

Occupational Health and Safety:  Mavin Feed have in place an OHS function based under the HR and administration department. There are specific OHS requirements for maintenance teams as overseen by the relevant facility’ head of maintenance. Specific procedures include: (i) Working at Heights; (ii) Hot Work; (iii) Confined Space, and (iv) Lock Out Tag Out. All these procedures and general OHS needs for operations are included within the Good Housekeeping Guidelines. Mavin Food have in place a similar arrangement with defined protocols for equipment shut down for deep cleaning and electrical maintenance. Mavin Farm have in place appointed OHS function at the sites owned and controlled with general OHS procedures for work operations. For contracted Porker Farms the Mavin Farm relies on the contracted partner to comply with regulations (ESAP #11).

 Energy and Material Efficiency Projects. Mavin Farm’s expansion plans are anticipated to increase porker fattening stock to 900,000  head with ~100 additional contracted Porker farms by 2025.  Mavin Farm energy consumption in 2020 is estimated at 475,000 KWH per year/farm. Energy consumption for all Mavin farms is estimated to be 26.5 million KWHs per annum. Future energy consumption is expected  to reach ~50 million KWH per annum. The Mavin Group has no energy nor water efficiency policy or management plan in place (ref. ESAP#1 and #5).

Water. Mavin Farm operations use tube wells at site for production and domestic usage with basic pretreatment/filtering. Water for worker consumption is provided in bottled and containerized form. Farm groundwater extraction is permitted and licensed by the provincial authorities with registered number of wells and water volume (captured within the environmental permit by site). The extracted water is used for pig bathing, pen cleaning, and waste treatment. Average consumption of water per farm is estimated at 90-100,000 liters per day based on drinking, cleaning and other use. 

GHG Emissions. GHG emissions estimation for Mavin Farm based on current energy consumption data (2020) of ~26.5 million KWH is estimated at about 11,000 tCO2-equivalent for 51 pig farms and five feed mills, and the two factories (Mavin Meat and Mavin Vet).  With the plan to expand the commercial pig stock to ~900,000 head by 2025 (including porkers and weaners), the GHG energy related emissions are expected to increase to ~22,000 tCO2e per annum. Combined with other Mavin Group entities energy consumption total GHG emissions shall exceed 25,000tCO2e per annum as such Mavin Group will be required to report its GHG emissions in the AMR.

Pollution Prevention. Mavin Farm apply a standardized animal waste management system by site for the treatment and management of waste (manure). Under proposed expansion ~300,000 additional tons/year of animal waste will be generated. For contracted Porker Farms, Mavin Farms stated that all environmental permits and business licenses are confirmed as part of the legal due diligence at point of engagement. Mavin Farm places full responsibility for E&S compliance on the contracted party but employs no system to continually monitor this (ref. ESAP #2 and #5).

Wastewater Treatment. Vietnamese environmental permits and prevailing regulations require all pig farms to have in place sufficient WWT capacity and comply with minimum standards for pollutants at points of discharge. On average, one pig will generate 5.5 liters of manure per day and the average number of pigs per farm is estimated at 3,100 heads. As such, on average, each farm will produce 6,200m3 of wastewater per annum or 17 m3 per day. This varies contingent on the farm, number of head and growth stage of the animals. The process of pig manure treatment is described as follows: (i) the pig manure and wastewater from the pens go through three sedimentation tanks (clarifiers) to remove heavy solids by settling and separating from the liquid; (ii) the separating screens between the sedimentation tanks is removing the solid waste; (iii) this solid waste is pumped to a dehydrator (dewatering separator); (iv) the dehydrated manure is then transferred to the drying yard, and after a period of bio-composting is sold to third parties as organic fertilizer; (v) the remaining liquid effluent is then pumped to the biogas digester (a pond with a plastic membrane to trap CH4 and N2O); (vi) material is stored in this digestor for a period of 8 weeks before being pumped to settlement ponds, transferred through a filter tank where the water is screened, and finally discharged (through land application to the surrounding buffer zone or into the boundary of the farm for general landscape and pen cleaning purposes). Wastewater from production activities is treated in accordance with GoV regulations (QCVN62-MT:2016/BTNMT). One monitoring report for Mavin Farms wastewater has been sighted confirming compliance to national regulations, with other similar reports (remaining 50 sites) not being available as at the time of this appraisal (ref. ESAP #2).

Site visits to two contracted Porker Farms with biogas capture and WWT systems took place during IFC appraisal. Wastewater settlement ponds were at capacity (based on the number of animals on site). Sighting of these locations re-enforced the need for proactive E&S monitoring and enforcement from Mavin. It was noted that land application outside the external boundary of the visited farms was occurring near watercourses. Vietnamese regulations require animal farming facilities with wastewater discharge volume larger than 5m3/day to install biogas capture and, if installed, to be operational.

Leaching and run off from incorrectly applied land application for disposal of treated wastewater can also result in contamination of surface water bodies. Any discharge through land application must be conducted in a manner that is compliant to the agreed environmental permit, with monitoring at point of discharge. Land application must be applied in a manner that does not allow the discharged material to gain access to surface water with the land area having sufficient absorption capacity to enable the material to be drained without risk to aquatic, human, or other habitats. Pig manure is high in ammonia, pathogens, suspended solids, and chemical and biological oxygen demanders. To avoid such risks WWT facilities must be maintained and monitored with land application applied in accordance with best practices and a recognized safe distance (factoring disbursement models, landform, and drainage capacity of the soils) from any water bodies (ESAP #12).

Mavin Food and Feed wastewater is discharged to licensed wastewater removal agent and municipal system respectively. Mavin Vet WWT is compliant to national regulations with sighted environment reports confirming this. It is noted that coliform count for discharged wastewater did exceed WBG EHS guidelines values by 5x (ref. ESAP #5).

Air Emissions and Odor. Mavin Feed air emissions are generated mostly from boiler emissions while dust is generated from machine activities. The air quality impacts are assessed as insignificant based on results from the latest environmental monitoring reports where all air quality parameters were monitored and found compliant with the national regulations and WBG EHS Guidelines. This was mirrored in monitoring reports viewed for Mavin Food and Mavin Vet. Farm odor is managed by installation of fans to maintain air flow within the site (and temperature control), and sighting of farms to reduce concerns from impacted stakeholders. (ref. ESAP #16)

Solid and Hazardous Waste Management. Mavin Food’ organic waste is managed in accordance with its environmental permit with weekly removal by a licensed waste management vendor. The liquid waste is stored in tanks and removed biennially by a licensed vendor. Mavin Feed and Farm (owned and operated) stated that hazardous waste storage areas are properly roofed, partitioned with waterproofed flooring. Hazardous wastes include chemical containers, medicine packages, used syringes, used light bulbs, oil absorbent rags. Hazardous waste is registered with the local DONRE and collected, treated and disposed by environmental service providers through valid contracts. Daily waste from workers’ activities and used packages is treated as non-hazardous solid waste and gathered in containers of various sizes equipped in sanitary facilities, production areas, kitchen, and domestic waste storage house and disposed of in accordance with the environmental permit and prevailing regulations (ref. ESAP #3). Dead carcasses are considered as Hazardous Wastes and Mavin Farm states it maintains two management approaches for disposal, these being: (i) incineration where the biogas generation is operating; and,  (ii) buying in limestone powder coated pits. During this appraisal disposal of pig carcasses at the visited farms were not fully consistent with stated practices i.e., allowing insect and vermin to feed on these (ref. ESAP #5).

Mavin Vet hazardous wastes includes packaging, air filters, absorbent materials, and hazardous liquids resulting from pharmaceutical manufacturing or laboratory use. Other office materials and general wastes are also included, such as ink cartridges and bulbs. The materials are labelled stored and removed by a licensed vendor.

Hazardous Materials. Marvin Farm (owned and controlled sites) hazardous materials consist of veterinary products and other materials such as insect and pest repellents, lubricants, petroleum products and cleaning agents. Cleaning agents are required for the purpose of pig stall and vehicle disinfecting. All hazardous materials are properly labelled and stored in the designated room in the sites as per the permit conditions. Mavin Food, hazardous materials include cleaning agents and diesel fuels (sufficient to maintain backup generator systems). Mavin Feed, diesel fuel (backup generator), cleaning agents, and formaldehyde (formalin) (for sterilizing duck eggs). Mavin Vet, hazardous chemicals are limited to reactive agents for chemical testing and sterilizing and used in a controlled and regulated manner in accordance with the GMP certification needs.

  Community Health and Safety. Mavin Farm ensures that, for all sites owned and operated a 3-5 km buffer zone exist to protect its farms. Access to and from these locations uses public roads. All new contracted Porker Farms are required to have a minimum 1km buffer zone between it and the local communities. Mavin Feed mills are in industrial zones and in semi-rural locations with one site in particular adjoining local communities. Mavin Food is located within an established industrial park with no adjoining communities. Marvin Vet is in a stand-alone factory location with no adjoining communities. It is recognized that all farms and feed facilities will have significant volumes of traffic entering to and from sites and this will impact local communities on roads leading into these locations (ref. ESAP #16).

Security Personnel. Mavin Group subsidiaries used licensed security companies to provide security guards and related services on a 24-hour basis. No armed security forces are engaged for any facilities.

 Mavin Feed, Food and Vet facilities are located within industrial parks or semi urbanized areas and far from any recognized key biodiversity areas (KBAs). Therefore, impacts from the existing facilities are deemed insignificant for PS6 risk of conversion of natural and critical habitats.

The proposed three breeder farms (to be primarily supported under this investment) are located within identified forest locations, with one site overlapping with potential ranges for natural habitat indicators. Specifically, the project within K’Bang District Gia Lai is located close to a KBA and two Protected Areas (PAs). These include: Kon Ka Kinh KBA and Tram Lap – Dak Rong KBA and Kon Ka Kinh National Park. Within this location, 18 recorded Critically Endangered animals including Civets, Loris, and Pangolins are present. The review of the approved ESIA for the K’Bang location highlights that the site is considered as degraded/modified with limited flora of fauna presence.

Sustainable Management of Living Natural Resources. In accordance with the IFC Good Practice Note (GPN) on Improving Animal Welfare in Livestock Operations (2014), IFC shall only engage with clients that are compliant to OIE (World Organization for Animal Health) Guidelines and have a commitment and plan to remove use of gestation crates, moving to group housing as part of a defined commitment to adhere to the GPN (no retrofitting of existing farms is expected). IFC’s scope of appraisal included verification of compliance of Mavin Farm animal welfare management practices with the OIE (World Organization for Animal Health) Guidelines. Mavin Feed has in place protocols on biosecurity, as well as defined guidance on the use of antibiotic treatments. Within the procedures it is clearly stated that these chemicals shall only be administered by a qualified person. Under proposed IFC investment, Mavin Group animal husbandry standards including biosecurity, animal health and welfare and use of antimicrobials will need to be further developed to meet best international practices and a leading position regionally over the course of the investment (ESAP #14). In addition to this, Mavin Farm shall require all farms to achieve a recognized international sustainability standard for its livestock operations (ESAP #15).

 As described under PS5 above, K’bang project involves land acquisition causing economic displacement of nine households belonging to three of the 54 government-recognized ethnic minorities in Vietnam: Bahnar, Tay, and Nung. The Tay are the second largest ethnic group in Vietnam after the majority Kinh ethnic group while the Nung are the sixth largest and primarily located in the Northern provinces of Vietnam. The Bahnar, on the other hand, are primarily located in the Central Highland provinces of Gia Lai and Kon Tum. In the case of Tay and Nung ethnic minority, it was determined that they are recent arrivals to the project area and the project-affected land was not their ancestral territory subject to collective attachment or use and therefore it did not meet the criteria for the purpose of PS7 application. The Bahnar households have been living for years in the Central Highland region. The Bahnar population in Gia Lai Province 104,997 people, or 45.9% of the total Bahnar population in Vietnam and constitute 20.5% of the So Pai commune. It was determined that Bahnar people have ancestral presence in the project’s area and meet the definition of indigenous people, as per PS7 definition. Nevertheless, given that the project impacts were limited to individual household-level land use, as opposed to collectively held or used land under traditional ownership or customary use, the impacts will be mitigated in accordance with PS5 as described above taking into consideration their vulnerability and any cultural differences.

There are different levels of integration of these communities into the broader population, and no significant differential impacts resulting from project activities are expected. Nonetheless, during the preparation of the LRP and CDP (ref. ESAP #13), Mavin will ensure that the households receive copy of all relevant documents in the corresponding language and will further assess if any of these households require any additional support considering that they are vulnerable and will ensure that livelihood restoration measures, communications and information are provided in a culturally appropriated format and language.

Given that Mavin’s farm is in the area with presence of mixed ethnicities, its community development efforts will be designed and implemented taking into consideration the input and needs of ethnic minority and non-ethnic minority groups. For future land acquisition, any potential impacts on ethnic minorities will be assessed and managed in accordance with PS5 and PS7 per the Group’s LAPP (ref. ESAP #4/#13). It must be noted that PS7 application by IFC discussed above does not affect the legal status of the relevant ethnic minorities in the country.

Stakeholder Engagement

Stakeholder mapping / analysis. Mavin Group key stakeholders included its employees, suppliers, contractors, clients, consumers, and rural community residents in the vicinity of its feed mills and pig farms. These communities often report their concerns and grievances, if any, to the CPCs in the area with the CPCs acting as a conduit for the information to the company/business unit. There is no mechanism in place to record grievances for following up and mitigation (ESAP #16).

Ongoing Reporting to Affected Communities. At the site level each operational team conducts information disclosure during the EIA process as legally required. There is no formalized mechanism in terms of ongoing reporting to affected communities during operation phase (ref ESAP #16).