Given the nature of the business activities under this proposed investment, no impacts are expected in the project which must be managed in a manner consistent with PS 5: Land Acquisition and Involuntary Resettlement; PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS 7: Indigenous Peoples and PS 8: Cultural Heritage.

 This is a Category B project, according to IFC’s 2012 Environmental and Social Sustainability Policy. Based on information reviewed during the appraisal, it is expected to have limited adverse environmental and social risks and impacts, short-term and site-specific, and can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections.

Environmental and Social Assessment and Management System

The company is still in the process of establishing EHS management procedures and systems. Prior to leasing warehouse or office space, the company undertakes a due diligence to confirm that the facilities are in compliance with the local licensing and permitting requirements.

As part of the site selection criteria, the company undertakes due diligence assessments of proposed new warehousing facilities to confirm that the sites have relevant government permits, appropriate firefighting equipment, shipping docks, sitting areas for workers and overall comply with Egyptian codes for EHS. However, there are no specific copies of documentation, certification or registers kept by the company.

The company will undertake a review of the E&S risks related to its operations as required under IFC PS 1. The risk assessment coverage will include third party operations including warehousing operations, delivery operations, franchise retail stores, and agent operations. The findings will also be used to develop and establish the company’s EHS policies, commitments, related Environmental and Social Management System (ESMS) and guide its activities for internal performance evaluations as well as oversight over its contractors. (ESAP 1).

The ESMS will include a corporate level procedure for screening and assessment of future office facilities and warehouse sites to enable application of appropriate local standards and codes, IFC PS requirements, and WBG EHS guidelines early in the site identification and selection process to cover pollution prevention, health and safety.

The company will also establish management programs to provide environmental and social risk mitigation as informed by the operational E&S risk assessments. Performance improvement actions and measures will be integrated into the management programs to enhance environmental and social management outcomes. Focus areas will include management of labour issues, health and safety including road safety, waste management and fire safety as envisaged in ESAP 1.

Organizational Capacity and Competency

At the time of the appraisal E&S issues in the company are generally managed by the relevant unit head. Additionally, the administration and security manager handles oversight on E&S issues for the warehouses and the outsourced last mile delivery fleet including permitting, licensing and government relations. The Head of Administration manages labour and workforce concerns for direct staff while the business development team, sales team and customer experience teams manage the relationship with agents from induction through to sales and related challenges or complaints.

Brimore shall appoint an E&S manager who will be charged with the development and implementation of the ESMS, conduct monitoring of E&S performance and report on E&S performance and challenges to the rest of the senior management team. The E&S Manager will be supported by the company’s senior management and external consultants as needed in the development, monitoring and evaluation of the PS compliant ESMS (ESAP#2).

As part of ESAP#2, Brimore shall also hire a qualified HR Manager who will be charged with development and implementation of the ESMS elements of relevance to management of labour risks for both direct workers, third party workers and supply chain related labour risks.

Emergency Preparedness and Response

Brimore will develop and implement an emergency preparedness and response plan (EPRP) for adoption at the various facilities covering possible emergency scenarios including fire and security issues in the workplace and relevant responses in line with IFC PS requirements (ESAP#3). The plans shall include actions to cover safety training program for staff at the offices and warehouse facilities. It shall also include mechanisms for coordination with the immediate neighbours at the warehouse facilities, first responders, and other relevant third parties.

Monitoring and Review

Brimore will develop procedures for internal monitoring, performance review, corrective action and related follow-up for management plans and programs as part of ESAP#1. The monitoring program will be overseen by the E&S manager who will also ensure that adequate records are kept for ESMS elements that are monitored by government or other third-party agencies and authorities. As part of the ESMS, a legal register will be established and maintained with relevant records regarding compliance with national laws and permits.

Brimore has 209 direct employees on employment basis or short contracts covering operations and logistics including IT support, business development, sales and marketing, customer experience, finance and administration. Third party workers consist of transportation contractor staff, warehouse operations staff and security contractor staff. Agents are currently classified as freelancer distributers and are mostly viewed as the primary customers in the business.

Human Resources Policies and Procedures

Brimore issues formal contracts to its direct employees which are based on local labour laws. Brimore staff are not members of any workers union and since inception, the company has not interacted with any union representatives nor dealt with labour related disputes.

The company will develop HR policies and procedures in compliance with PS 2 requirements to cover working terms and conditions including recruitment, induction, performance review training and capacity building, working hours, overtime, leave days (annual, sick, maternity, paternity and compassionate leave), salary payments, bonuses and benefits, health insurance, deductions, occupational health and safety, code of conduct and disciplinary measures (ESAP#4). The policies will include explicit statements and mechanisms covering non-discrimination and equal opportunity, freedom of association and prohibition of child and forced labour, prevention and management of gender-based violence and harassment (GBV&H) related risks - with the appropriate level of consideration for direct workers, agents and contractors.

Brimore will also establish mechanisms for staff sensitisation on these policies and procedures at induction and whenever material changes are made to policy and procedures. As part of ESAP# 1, Brimore will communicate its expectations and incorporate applicable PS2 requirements in contractual agreements with third party employers; and establish mechanisms for labour monitoring and audits of third party employers in relation to the requirements of PS2.

The company will also develop a written grievance procedure formalizing grievance management practices already in place including, a clear articulation of how complaints are filed and received, timelines for responses, routes for escalation, options for anonymous complaints, and commitments to non-retribution. The grievance procedure will be communicated to workers (including third party workers and agents) and supported by grievance logging or recording mechanisms. This mechanism will not impede access to other judicial or administrative remedies that might be available under the law (ESAP#5).

Occupational Health and Safety

Brimore has a mechanism for reporting incidents and accidents arising from office and warehouse related OHS risks. Shift meetings incorporate discussions and information on OHS management.

Brimore will develop a formal OHS program (ESAP#6) to cover direct staff and third party workers per the requirements of PS2. The program will include: mechanisms for identification OHS risks covering office and warehouse facilities; mechanisms for preventive and protective actions commensurate to identified hazards; use of personal protective equipment where applicable, staff training mechanisms; incident reporting and investigation; applicable permits to work; emergency prevention preparedness and response; performance measurement and monitoring; organisation, roles and responsibilities; and internal and external reporting mechanisms.

Brimore will integrate specific fire safety management measures commensurate to warehousing and office facilities in its OHS program and EPRP as discussed in the previous sections. These measures will include: (i) periodic conducting of fire evacuation drills; (iii) provision, testing and inspection of firefighting equipment, fire warning and evacuation systems; and (iv) provision of adequate fire safety training to employees. Brimore will also secure applicable local building and fire permits for the warehousing facilities.

For COVID-19 management, Brimore instituted mechanisms and provided equipment for staff to work from home to facilitate flexible work hours. Whenever a case was reported in the office, the impacted team was quarantined for 14 days while infected staff were provided contactless delivery of food and medical supplies. The health insurance for staff was also upgraded to include coverage for COVID-19 treatment. So far there has been no need for lay-offs of staff as a result of the pandemic.

Ongoing communication to staff and drivers on company expectations and policy on OHS management (including COVID-19 response) is undertaken through short talks and internal meetings.

Management of Freelance Sales Agent Relationship

Brimore Agents are engaged on as freelance sales agents working on an online based platform. New agents are recruited by existing agents with peak recruitment depending on the month and season. As earlier indicated, the sales and customer experience teams are responsible for onboarding and training of new agents using pre-developed materials including induction videos available on the online platform.

The company provides materials to guide to its staff to promote respectful engagement with agents.

The legal environment for freelancers is continuously evolving. Brimore will seek legal advice to determine the legal status of agents and check compliance with local labour laws. The company will continuously monitor the situation through its in-house counsel with support from external counsel as appropriate to ensure that the company is up to date with any changes on the legal status of agents (ESAP#7).

As part of ESAP #4, Brimore shall develop and document policies and procedures specific to induction of agents, engagement with supervisors and managers, grievance redress (including grievances related to gender based violence/sexual harassment) and termination of engagement with agents. The policies and procedures shall indicate Brimore’s commitments on non-discrimination to guide these processes and provide explicit statements on freedom of expression and collective bargaining appropriate to the agent’s freelancer status.

Workers Engaged by Third Parties

As indicated earlier, the main contractors are the outsourced warehouse operations, transportation contractor for the last mile delivery and a security company that provides unarmed personnel at the warehouse facilities. Due diligence on contractors is undertaken through review of testimonials and their reputation in the market in general and on word of mouth by the company’s partners. The procurement team also undertakes a general assessment of the contractors’ performance as provided for in the service agreements.

As part of ESAP#1, Brimore will review and update its contracts with contractors, suppliers and service providers to ensure that compliance with IFC PSs is incorporated as a contractual requirement to cover risks in child labour, forced labour and OHS contextualized to third party worker risks especially in the warehouse related activities, road safety (for delivery contractors) and reputational risks from community complaints. The company will also implement contractor E&S compliance audits according to a relevant procedure of the ESMS .

The company operates from leased offices. Power and water consumption is minimal as it caters for routine office administration and sanitation purposes. Waste management and sanitation for the office facilities is generally integrated into the service agreements as the landlord’s responsibility. The company has an agreement with a recycling company which collects packaging wastes from the warehouse.

Brimore will communicate its policy expectations with the cleaning teams on handling and management of hazardous chemicals including disinfectants and other cleaning agents while they operate at the warehouses, as part of ESAP #6.

Food and Consumer Safety

Brimore has mechanisms in place to check for expiry of goods prior to issuance to the agents for sale. The company does not keep products close to or past their expiry date among their stock.  Suppliers are usually required to issue goods that are still within 80% of their shelf life, and where this is not possible, Brimore retains the right to reject goods offered to them. Agents can use the online platform to provide feedback on the quality of goods sold. Records on product quality related complaints are recorded under the agent’s profile and are analyzed by the customer experience team for escalation to the management or manufacturers as appropriate.

Security Personnel

Brimore security at the warehouses is provided through a contracted firm that provides unarmed security guards. As part of the E&S risk review under ESAP#1, the company shall make reasonable inquiries to ensure that contracted security firms are not implicated in past human rights abuses. Brimore shall also review its security contracts to include explicit statements to ensure that the contractor provides training of security personnel on human rights issues, proper use of force, and appropriate conduct towards workers and other stakeholders, and auditing procedures for the security service providers (ESAP#8).