IFC’s review considered the following Performance Standards (PS) not to be applicable: PS5 (Land Acquisition and Involuntary Resettlement) as the Company acquires (or has acquired) land on a willing buyer/willing seller basis; PS6 (Biodiversity, Conservation and Sustainable Natural Resource Management) as there are no identified sensitive natural habitats or natural resources impacted by BOCOM’s existing and proposed activities; PS7 (Indigenous Peoples) as there are no Indigenous Peoples present in the regions in which BOCOM’s activities occur; and PS8 (Cultural Heritage) because there are no identified artifacts and resources that would constitute tangible or intangible cultural heritage resources in the project affected areas. However, the applicability of these Performance Standards will need to be monitored based on the environmental and social assessments to be undertaken for expansion of the Douala LPG facility, the 4 new LPG facilities to be established and new service stations.

This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on information reviewed by IFC, the project will have limited adverse E&S impacts that are few, site specific, largely reversible, and readily addressed through existing mitigation measures and good international industry practices (GIIP).

Key areas of environmental and social (E&S) focus for this project include: (i) ensuring appropriate E&S due diligence for new facilities (ii) implementation of adequate E&S management systems in accordance with IFC’s Performance Standards (PSs) and the World Bank Group (WBG) Environmental Health and Safety (EHS) Guidelines and ensuring adequate capacity to support such; (iii) fair, safe and healthy working conditions for employees and contract workers in accordance with the applicable legal and PSs requirements; (iv) life and fire safety and emergency response planning; (v) pollution prevention (emissions, leaks, wastewater and hazardous chemicals management) in line with applicable WBG EHS Guidelines; (vi) management of community impacts (accidental material releases, traffic and security); and (vii) stakeholder engagement and grievance mechanism.                 

Environmental and Social Policies and Management System

BOCOM Group has developed an integrated management system based on four policies i.e., an EHS policy, Quality Policy, Drug and Alcohol Policy and the Transport Policy. The EHS policy commits the Group to comply with internal EHS requirements, applicable host country regulations and international EHS standards while providing a framework for environmental and social assessment and management. It defines the company’s zero work accidents and zero pollution objectives, and the management strategy to align operations with ISO 14001 (environmental management) and ISO 45001 (OHS) requirements, respectively. The Drugs and Alcohol policy specifies the zero-tolerance response to the possession or use of the associated substances. The Transport policy outlines BOCOM’s commitment to safe driving of company vehicles by describing speed limits and recommended driving hours in different zones and road conditions, not driving under the influence and the obligation to wear a seat belt, amongst other. These policies are signed by top management and displayed across all work sites and are applicable to all Group employees.

The Group has further adopted a quality, health, safety, and environment (QHSE) integrated management system which is applicable to all affiliates. BOCOM International, the waste management subsidiary, has obtained certification against ISO 9001 (quality management), ISO 14001 and ISO 45001 since 2019 and the Group intends to replicate this to all other affiliates. As of July 2021, the fuel (white products) distribution division has successfully reconducted its ISO 9001 certification while the LPG division has completed the development of the key components of the system and relevant procedures to facilitate certification against ISO 14001 and ISO 45001.

Pre-agreed yearly and monthly QHSE objectives for BOCOM, are discussed with senior Group management and established for all grades of BOCOM workers. Achievements in relation to these objectives are reviewed regularly and presented in periodic reports. In 2021, The Company reported 95% achievement of its EHS objectives with respect to management plans implementation, zero (‘0’) loss time incidents, zero (‘0’) non-compliances resulting from formal EHS inspections and zero (‘0’) non-compliances related to air emissions or spills. In November 2021, the Douala LPG branch undertook a diagnostic in anticipation of ISO 14001 certification and a performance review was conducted to identify opportunities for further improvements. 

Going forward and as per ESAP #1 BOCOM will develop and implement an environmental and social management system (ESMS) specific to and suitably scaled for its business activities, applicable to contractors, in accordance with the requirements of IFC’s PS1. In doing so, existing health, safety, and environment (HSE) policies and procedures will be updated to incorporate the construction and operation of the new developments and expansion of the existing facilities where applicable. The procedures are to include KPIs and auditable criteria to be able to continually monitor performance.

Identification of Risks and Impacts

Following national regulations, BOCOM is required to undertake environmental impact assessments (EIA) prior to developing any new business activity including the new LPG facilities and expansion of the existing facilities. Thereafter, operational risks are assessed and captured in the risk register. For the LPG facilities these are undertaken by the respective EHS Officers for the LPG division. . Risks assessed include those related to power failures, equipment maintenance, housekeeping, execution rate of planned maintenance, stock availability and customer satisfaction. Additionally, bomb threats, spill, product leak, fire, explosion, aggression, crowd movement, etc are also performed. All this is described in the emergency plan with the detailed composition of the managers for the management cell.

For the LPG facility in Douala, an EIA was undertaken in 2016 per national requirements. The EIA was followed by a hazard assessment which included modeling of an Unconfined Vapor Cloud Explosion (UVCE) and flashfire, and a boiling liquid expanding vapor explosion (BLEVE) and the associated thermal effects. At the time of appraisal, BOCOM had not finalized designs of the new LPG facilities or that associated with the planned expansions at the Douala and Yaoundé LPG facilities, nor assessed E&S risks. This similarly applies to activities associated with the lubricant plant. To ensure E&S risks and impacts associated with existing and new developments are adequately managed, the following actions will be implemented as defined in ESAP#2, (i) conduct a process safety audit, an Occupational Health and Safety (OHS) audit and hazard and operability assessment (HAZOP) for the existing Douala and Yaoundé LPG plants. Thereafter and based on the findings, agree with IFC on a time-based action plan to address the findings from the respective studies and similarly confirm the findings / recommendations to be applied to the four new LPG facilities to be developed; (ii) undertake an environmental and social impact assessment (ESIA) aligned with the PS’s for the expansion of the Douala LPG plant and this is to include activities associated with dredging, a flood risk assessment and quantitative risk assessment (QRA); (iii) undertake a process safety audit and an OHS audit for the lubricant plant taking into account activities associated with the expansion thereof; and iv) undertake ESIA’s compliant with national regulations and the PS’s for the 8 new LPG facilities inclusive of a QRA if applicable.

Management Programs

BOCOM has developed several E&S management plans and procedures designed to address key issues and risks identified in the project related EIAs and during the ongoing operational risk assessments. These plans and procedures are generally applicable across all the petroleum products lines. Key procedures include related hazardous products storage, transportation loading and unloading, cylinders filling and handling (for LPG), waste management, spill management, emergency response and evacuation, employee QHSE training, Personal Protective Equipment (PPE) use and working in confined spaces, amongst other. The Company has further implemented a permit to work system and accident-incident investigation and reporting systems. As defined under ESAP #3, based on the findings of the process audits, OHS audits and HAZOP’s referred to above, BOCOM will strengthen existing management plans and procedures and develop and implement additional plans / procedures as may be deemed applicable. 

Organizational Capacity and Competency

For white products, QHSE is headed by a QHSE officer who develops the annual strategy as signed off by the CEO (Chief Executive Officer). The officer leads a team of regional operational supervisors and the fuel station managers who are officially assigned EHS responsibilities at their respective stations.

The specialized products department (LPG and lubricant plant) has a dedicated QHSE officer responsible for the annual EHS strategy. At the Douala facilities, this officer is responsible for the quality improvement team (10 people), the EHS team (1 coordinator and 2 EHS inspectors) and the emergency response team (3 fire marshals and acting also as security supervisors). At the Yaoundé LPG facility, there is one EHS technician reporting to the EHS Officer at the Doula plant.

The ToR for the process safety studies, HAZOP and OHS audits referenced above for the existing LPG facilities and lubricant plant (ESAP #2) will include specific reference to reviewing the EHS organizational capacity at the associated facilities and providing recommendations as to their adequacy including that related to the new LPG facilities still to be developed.

Emergency Preparedness and Response

BOCOM has developed emergency plans and procedures specific to each activity in the company i.e., the service stations, individual LPG facilities and the lubricant plant. Typical emergencies identified include fire, major spills, gas leak (at the LPG facilities), explosion, power failure, threat to persons, property and goods, and natural disasters amongst others. Relevant personnel responsibilities and fire marshal roles are defined.

Fire emergency equipment at the Douala LPG plant includes variable size portable extinguishers (foam and powder), armored hose reels, automatic sprinkling in the loading and storage areas, plant shutdown valves and automatic gas detectors located around the site. There are also gas detectors and four CCTV cameras which are monitored by the control room operator. An automatic sprinkling system is installed at the truck loading bay and trucks are fitted with flame arrestors. All workers at both the Yaoundé and Douala facilities, particularly drivers, are trained in emergency procedures and fire equipment use. Emergency evacuation exercises are also carried out 4 times/year at the LPG facilities in Douala and in Yaoundé.

Based on the outcomes of the process safety audit and HAZOP’s, BOCOM will update their emergency response plans for their LPG facilities and lubricant plant, and this will include that related to transportation. For purposes of the new LPG facilities, emergency response plans will be developed and reviewed by IFC as part of the ESIA’s undertaken for the projects; refer to ESAP#4.

Monitoring and Review

QHSE inspections are carried out at all BOCOM sites with varying frequency. Under the management of the QHSE officers, QHSE objectives and Key Performance indicators (KPIs) are predefined respectively for fuel distribution and for LPG activities and tracked. KPIs tracked include the number of violations identified during local inspections, rate at which recommendations are implemented, number of emergency drills, lost time accidents frequency rates, number of leaks detected, amongst other. Exceedances or non-compliances are documented in a monthly report which is submitted to the CEO. An annual report on both the fuel stations and LPG plants is also due to the local Environmental Authority as per country legislation.

Based on the findings of the process safety audits, OHS audits and HAZOPs the company will augment the QHSE objectives and KPI’s; refer to ESAP #3.                                              

As of December 2021, BOCOM employed 1,121 permanent workers though the majority (54%) are working at the service stations with the remainder at the LPG facilities and lubrication plant. Of the 1,121 permanent employees, 435 are women and there are five women in management positions. In addition, there are construction workers contracted for development of the new lubricant facility and contract workers will be employed during construction of the various new activities as defined.

The Human Resource (HR) function at the Group level is headed by a HR Manager who is supported by a team of administrative staff. BOCOM has a HR head also supported by a team of administrative staff reporting to the Group HR Manager.

Human Resources Policies and Procedures

The recently signed human resource policy for the Group defines the mission and vision of the HR department and the four key HR pillars – transparency, diversity, internal mobility and equity. Under the pillars of transparency and diversity, the HR policy outlines the Group’s commitment to non-discrimination by stating that all recruitment is done regardless of gender, disabilities, origin or culture and valuing diversity of culture and competency in their workforce. Additional HR policies related to recruitment, worker training, employee evaluation, disciplinary management, worker replacement, procedures on employee benefit including details on paid leave, work travel and onboarding for new recruits are also defined.

At the time of contract signing, all workers must present a copy of their birth certificate to verify they are 21 years old or older, the legal working age in Cameroon and to ensure there is no child labor within the company. This document along with their contract is kept in their employee file. During the site visit, a sample of worker files was consulted, and birth certificates were present.

The interior regulation document outlines BOCOM’s policies regarding recruitment, worker onboarding, working hours and approved absence, paid leave, disciplinary measures, and health and safety. Gas station attendants rotate in shifts, so they do not surpass their legally allocated 40 hours per week. The first shift commences at 7:00 am and ends at 4 pm and workers have a 90-minute break. The second shift commences at 4 pm and ends at 10 pm and then there are limited staff from 10 pm to 7 am.

In the disciplinary section of the interior regulation document, a list of prohibited behaviors is noted including all forms of sexual or moral harassment, which may result in employee dismissal. Articles 18: Sexual Harassment and Article 19: Moral Harassment define both forms of harassment and possible disciplinary actions. BOCOM has recently developed an anti-sexual harassment policy that still needs to be signed and communicated to workers.

As per ESAP #5 the company will sign and communicate the anti-sexual harassment policy to all staff through worker training and posting of the policy in suitable areas. In addition, the company will implement continuous communication to employees on all the company’s HR policies.

Working Conditions and Management of Worker Relationship

Most workers are employed on a permanent basis with open-ended contracts; contract terms are communicated at the time of employment. Example contracts were provided to IFC and payments into social security, health insurance, paid leave and salary are clearly indicated. Following interviews on site, workers stated that they understand their terms of employment including payments into social security, insurance, and paid leave.  Those who are not permanent are either in their trial period or on an internship at the corporate headquarters.

Workers’ Organization

An election of worker delegates is mandated by the Cameroonian Government’s Labor Code and their role is defined in article 128 of the Code. 52 worker delegates are elected by the Company workers for a period of two years. Their number depends on the size of the workforce in any given BOCOM region.  Although no workers are members of unions, worker delegates serve as a liaison between workers and management by transmitting worker grievances or other concerns. The worker delegate grievance register is shared with the labor inspector and the Company. Most concerns to date are regarding job location and salary levels. Although no workers belong to unions, BOCOM noted that they fully support freedom of association, although the company has no freedom of association policy. As for a collective bargaining agreement, BOCOM adheres to the national level agreement that is applied to all petroleum operators in Cameroon.

As specified in ESAP#5, the company will develop and implement a Freedom of Association Policy to be included in the suite of HR policies.

Grievance Mechanism

There is currently a worker grievance mechanism in place, however there are no procedures to receive and address grievances. When workers have a grievance, they can communicate with their supervisor, a worker delegate or directly to Company managers. Worker delegates also record grievances in a government mandated register to be shared with the Labor Inspector while BOCOM HR also follows up on noted grievances.

In accordance with ESAP#6, the company will document the worker grievance mechanism already in place and clearly define a procedure on how workers can raise a grievance, either in person or anonymous, and how the grievance will be managed. In addition, the company will specifically define the approach to managing sexual harassment related grievances.

Occupational Health and Safety

As referenced in PS1 above, the company has developed a policy defining BOCOM’s commitment to zero accidents and incidents and is aiming to be certified against ISO 45001. Standard operating procedures have been developed as per certification requirements and based on outcomes of the available EIAs and internal /operational risk assessments. These include hazardous products handling and transportation, loading/unloading of tankers, LPG cylinders filling and handling, work permit system, emergency response and evacuation, accident-incident management. For accident-incident management, they (including commuting accidents) are identified, investigated and categorized; and are then logged in the central QHSE incident register for further analysis. Performance targets are predefined respectively for the white products and specialized products divisions as part of the QHSE yearly dashboard. These targets include lost time incidents (LTIs) frequency rates and severity rates. From the review of the last 3 years OHS reports, no fatalities were noted and LTIs were within the agreed target.

Associated roles and responsibilities are specified for each procedure as applicable. Employee training is a key component and includes a session on predefined modules and weekly toolbox talks on basic awareness of quality, environmental and OHS issues. Good housekeeping and hygiene are a priority at fuel stations and LPG plants visited. It was also noted that personal protective equipment (PPE) is provided to employees and to contract workers.

At the Douala LPG site, it was noted that the relevant safety equipment was installed on tanks e.g., safety and pneumatic valves, gas leak detectors, etc. Similar systems will be installed at the new facilities.

As described in BOCOM’s interior regulation document, workers must undergo a medical checkup at the time of employment and have annual follow ups.  All workers are provided health insurance for the duration of their employment. Approved clinics provide medical treatment for all workers either for checkups or in the case of accidents. There are also first aid kits at all fuel stations.

The two QHSE officers oversee the OHS management system for the white fuel operations and for specialized fuels; the officers will also be responsible for new projects. Per ESAP#2 the company will undertake OHS audits for the Douala LPG facility and lubrication plant.  Based on the findings thereof, the company will implement enhancement measures as applicable and the outcomes will also be applied to the new LPG facilities to be constructed.

Contractor Management

The company employs limited contractors for operations, and they are mainly focused on cleaning and construction activities. Going forward and as per ESAP #7, BOCOM shall develop and implement a contractor management plan aligned with IFC’s requirements.                                             

Resource use

Electricity for BOCOM’s operations is provided from the grid and all individual plants / service stations are sited within reasonable distance of transmission lines. As the grid power is unreliable, BOCOM has equipped fuel stations with backup generators of 80 kva capacity as an alternative power source to guarantee permanent lighting, air conditioning and for the fuel and water pumps. At the concession in Douala there is a 750 kva backup generator to power both plants if required. A 100kva backup generator is installed at the Yaoundé LPG plant. The Company shall similarly install backup generators at each of the new facilities, to ensure permanent power availability.

Water and fuel Consumption

Water usage at the BOCOM sites is typically for cleaning and sanitation, however, at the service stations, additional quantities are required for car washing. Aside from the service stations, to meet water requirements BOCOM obtains authorization for connection of facilities to the municipal water distribution network. All service stations have boreholes linked to 2,500-liter tanks to ensure independent and permanent provision of water. Besides domestic uses (cleaning and sanitation), at the LPG plants water is required to keep LPG storage tanks and trucks cool during loading or unloading operations or when ambient temperature is higher than average. The water requirement at the lubricant plant is exclusively for domestic use.

To meet workers’ drinking water needs, the company purchases bottled water from local suppliers. At some of its urban service stations, BOCOM has developed drinking water points connected to its water boreholes, to supplement communities' water needs where local distribution falls short. Per ESAP#8, the company shall develop a water management plan which will include as a minimum a water quality testing program for all water used for potable means and quantities used for annual reporting as required by local regulations.

The total amount of fuel consumed for all BOCOM’s activities in 2021 amounted to 20,573 liters, inclusive of 8,250 liters for service stations generators, 5,923 liters for LPG distribution and 6,400 liters for the lubricant plant.

Air Emissions and Ambient Air Quality

Main air emissions at service stations are composed of volatile organic compounds (VOCs) arising from the handling of fuel and refueling of vehicles. However, concentrations are considered acceptable given these activities occur in an open environment.

At the Douala and Yaoundé LPG plants, cylinder refilling is undertaken manually, resulting in uncontrolled LPG emissions. Gas detectors are installed in the filling areas to alert for explosive concentration levels. In addition, as per local regulation, BOCOM is required to install air quality monitoring equipment at its LPG facilities and report annually to local authorities; the monitoring equipment is yet to be installed though.  Given the nature of the activities at the lubricant plant i.e., blending and packing of lubricants, air quality impacts are not an issue.

Greenhouse Gas Emissions

Based on the projected maximum production, BOCOM’S gross CO2 emissions amount to 848 tCO2eq/year, inclusive of GHG emissions from back-up generators, vehicles fleet and grid electricity consumption. This amount is well below the 25,000 tCO2eq/year IFC benchmark for annual reporting.

Pollution prevention

Other than sanitary wastewater, which is discharged to septic tanks, no other wastewater is generated from BOCOM’s operations. At service stations and lubricant plant, water from cleaning and stormwater is discharged via oil water separators. The oily fraction is collected while the remaining water is released to the municipal stormwater system. These systems need regular maintenance to ensure proper functioning.

Thus, going forward and as defined in ESAP#9, BOCOM will develop and implement; i) a procedure to ensure regular maintenance and cleaning of oil water separators; and ii) implement a monitoring system for the septic tanks and stormwater prior to release to the environment. In addition, and as identified per government environmental inspectors, the company will finalize the hard standing areas (access roads and refilling area) hall and formalize the stormwater management systems at the LPG facilities.

At the service stations, fuel is stored in underground storage tanks (USTs). Government inspectors ensure USTs are installed per regulatory requirements prior to commissioning (either double-walled USTs or if single walled these are installed in a concrete lined area). However, no inspection records are available to confirm that the concrete structures are built adequately and that there are no uncontrolled leaks.

LPG storage tanks at Douala and Yaoundé are designed and installed in accordance with applicable European standards EN 13445 and 2014/68 / CE. Similar standards will apply to the new facilities. At the lubricant plant, oil storage tanks did not have secondary containment during the visit.

Going forward per ESAP#10, BOCOM will; (i) implement regular fuel monitoring at service stations to assess for leaks and ensure USTs are designed and installed in alignment with Good International Industry Practice (GIIP) and WBG EHS Guidelines with, as a minimum, a double walled tank or tanks situated in suitably impermeable concrete pit; and (ii) construct adequate secondary containment for all storage tanks at the lubricant plant consistent with the WBG EHS Guideline requirements i.e., 110% of tanks capacity. 

Waste Management

General waste – The service stations generate limited waste which is of a general nature. The waste is collected by HYSACAM, the municipal waste collection company and disposed of at public facilities. At the Yaoundé LPG facility, waste is similarly disposed via the municipal service.

Waste from the Douala LPG and lubricant plant is collected by ‘BOCOM International’ an accredited waste management company owned by the Group.

Hazardous waste – BOCOM International manages and collects hazardous waste for all BOCOM’s facilities including the service stations, LPG plants and lubricant blending facility. Hazardous waste includes used engine oil, used filters, spent grease, electronic components, ink cartridges among others. The approach to disposal depends on the waste e.g., used oil is sold for reuse and used filters are incinerated at the BOCOM International government approved facility. A similar approach will be applied to all new facilities.

Hazardous Materials Management- BOCOM has developed a hazardous material handling and storage procedure applicable to all activities and applied by the entire workforce.                                               

Community Health and Safety

There are no communities in proximity to the Douala and Yaoundé LPG facilities and the lubricant plant. At the LPG plant, equipment and vessels are installed according to the applicable French and European standards with a comprehensive maintenance program. This includes ensuring that containers, valves and piping are painted, free of corrosion and in good condition. Potential impacts to communities associated with the new LPG facilities will be assessed in the respective ESIA’s.

Risks associated with the service stations include explosion or fires while offloading fuel into underground tanks or vehicles or gas leaks. Impacts to communities are assessed in the EIA’s undertaken for the individual projects and where applicable the service stations have installed a government mandated fire wall which is inspected annually by the Ministry of Environment.

Transportation Safety

The transport of bulk LPG from Douala facility to other distribution points and equally from the Yaoundé plant is undertaken by a variety of distributors with varying degrees of safety measures.

Transport of LPG in cylinders from the LPG plants to distribution points is done either by contractors, large scale wholesalers or by the Group’s logistics and transport company (ILP).  Offloading and onloading of LPG bottles is closely monitored and transport safety measures implemented with the associated safety risks are clearly noted on all transport vehicles.

As per ESAP#2 above, the process safety and OHS audits will include a review of the approach to the transportation of all BOCOM materials (LPG, lubricants etc.) against the requirements of the WBG EHS Guidelines and GIIP. Based on the findings thereof, BOCOM will implement the associated recommendations in accordance with a time-based action plan agreed with IFC.

Security Personnel

Security at the service stations is provided by unarmed guards via a private security company. At the LPG facilities and the lubricant plant, security is provided by both private security guards and public security forces. The agreement between BOCOM and the public security forces dates to 2017. In this regard, BOCOM provides payment for the public security services and accommodation on site. As applicable, BOCOM will organize similar security arrangements for the new facilities.

Going forward BOCOM will develop and implement a Security Management Plan in compliance with IFC’s requirements to be applied at all facilities per ESAP#11.