Issues related to PS4 (Community Health, Safety and Security), PS5 (Land Acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Management of Living Natural Resources), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) do not apply to this investment for the following reasons: the new plant in Diamniadio which will host the two bottling lines to be funded by this project is in a designated industrial zone and far from any local community; the client makes limited use of security at its facilities, using its own staff (ostensibly manning a locked gate to prevent unauthorized access) and undertakes reasonable inquiries to ensure that if needed, 3rd party providers of security (such as those currently working at the construction site in Diamniadio to prevent unauthorized entry) are licensed as necessary and not implicated in past abuses; the land for the new production site was previously purchased through a market-based willing-buyer willing-seller transaction, and there was no economic or physical displacement as a result; the project site is located in in an industrial zone (modified habitat), and there will be no impacts on critical or natural habitat; similarly, no indigenous people or cultural heritage will be impacted by the project.

This is a Category B project based on IFC’s 2012 Policy on Environmental and Social Sustainability. The E&S risks and impacts associated with this project are limited, site-specific, and can be readily addressed through generally accepted mitigation measures described in this document. The key E&S issues related to this project – the addition of two bottling lines within a to-be-completed integrated bottling/production plant (already funded under a previous IFC investment) - include risks and hazards related to the use of glass, availability of water to allow for the increased production of beverages, and appropriate solid waste and wastewater management related to an increase in production output.

Environmental and Social Policies. At the time of appraisal for #40131 in November 2017, IBS had a policy that included only environmental matters. Since then, the client has upgraded the scope of issues to be covered by this policy, including performance-based requirements (ESAP#1, #40131). As of today, IBS has adopted an overarching new Quality, Hygiene, Security, Environment and Social policy. The document was reviewed and approved by IFC in August 2021. This policy defines the E&S objectives and principles that guide the client’s operations to meet E&S performance-based requirements as defined in PS1 and WBG EHS Guidelines.

Identification of Risks & Impacts. The company complied with Senegalese regulatory requirements to conduct an ESIA study (ref. #40131, ESAP#2). Validation of this study, including the Internal Operation Plan, has been done by the Ministry of the Environment, including the delivery of an Environmental License on October 25, 2019. In addition, IBS has institutionalized all HACCP pre-requisites, including sanitation and good management practices for its operations. The ESAP#3 of #40131 also required IBS to implement a robust food safety management system in line the Hazard Analysis Critical Control Points (HACCP). IBS has completed such improvement which is evidenced by having successfully obtained the Food Safety Management System (FSSC) 22000 Certification. This management system was developed and implemented with the support of The Coca-Cola Company. The valid FSSC certificate was provided to IFC during this appraisal.

For the design and technical specifications of its new plant in Diamniadio, IBS has used both TCCC  specifications and those from the European hygienic engineering & design group (a European-based NGO, https://www.ehedg.org/) that is ‘devoted to the advancement of hygienic design and food engineering. . IBS confirmed its commitment to conduct a comprehensive E&S risk assessment of the two additional bottling lines once they are operational. Based on risk findings, IBS will take appropriate mitigation measures, including the upgrade of its risk assessment and EHS procedures. Specifically, this will include an update of its documented assessment of occupational hazards risks at each working station. This document describes the hazards and associated risks, the evaluation of these risks according to probability and severity and the development of appropriate preventive measures to eliminate the risks or to reduce them to acceptable levels. This addition to the existing document, once complete, will be reported in the next AMR provided to IFC (ref. #40131).

EHS Management Programs. Following the successful institutionalization of all HACCP pre-requisites and the FSSC certification mentioned above, IBS uses such framework to drive continual improvement programs throughout its operations in accordance with the requirements of those recognized standards. There is for example a zoning of Access to certain areas / rooms / materials sensitive to food safety. In addition, and as was previously reported in prior appraisals, IBS is progressing on other initiatives, such as the Integrated Pest and Vector Management (IPM/IVM) programs, allergen control, use of customer complaints mechanism to drive improved quality performance along with a traceability and product recall program.

EHS Organizational Capacity and Competency. In 2021, IBS significantly strengthened the technical capacity to its QHSE function, bringing in a 19-year veteran of The Coca-Cola Company to lead its QHSE department. This professional oversees EHS management programs to support IBS’ strategic priorities. He is also in charge of managing his EHS team to achieve IBS’s E&S goals, including all E&S activities which will lead IBS in securing certification of a comprehensive E&S management system (ISO14001), while strengthening the internal technical capabilities of his team. In addition to the EHS head, two additional officers support the implementation of the EHS programs. One oversees system management in terms of documentation, good practices to be implemented, use of PPE, etc. The other’s duties center on a hands-on role verifying that agreed procedures and preventive actions are being implemented on site. This individual is also in charge of overseeing contractors’ work and providing work permits, when necessary. Going forward, IBS intends to hire 2 new officers who will be responsible for achieving implementation of ISO 14001 and ISO 45001 systems. The timeline for these hires and certifications is dependent upon the move to the new facility. In summary, IBS will move and install new production lines, including equipment, update its EHS risk assessment, and prepare all documentation for management and control of all processes in 2022 to be ready for third-party audit for ISO 14001 and 45001 implementation (incl. training, awareness, documentation, etc.) with certification targeted for 2023.

Each new worker, regardless of his/her department, continues to go through an induction program to be trained on IBS’s EHS policies. Specific training programs are developed to improve knowledge and strengthen the company’s E&S program. IBS intends to start in 2021 a new initiative (behavioral safety program) which consists of employee observations and feedback on all aspects of working conditions. Contractors are also included in this training program. Prior to each engagement with contractors, a risk assessment of the task in hand is conducted along with the contractor and awareness sessions are conducted on site during the time they are present on site. As part of its site visit in August 2021, IFC received a presentation outlining the E&S risks that could be encountered by visitors to the site and practices/procedures to be followed to ensure a safe visit. 

Emergency Preparedness and Response. To ensure a formal and documented emergency preparedness and response plan validated by local authorities (ESAP#4, #40131), IBS has developed and made operational an emergency preparedness and response plan in accordance with the local law/regulation and IFC PSs requirements. IBS conducts emergency drills and has put in place an incident management procedure which includes several emergency action plans depending on the nature of the incident listed. It has set up a fire control command center with optical smoke detectors, linear smoke detectors and associated thermal detectors as well as manual alarm triggers according to the risks present in the plants. IBS has also on-site fire-fighting equipment, such as portable/wheeled extinguishers and fire extinguishers. During this IFC appraisal, the following documents were provided (i) the Internal Operation Plan (IOP) – equivalent of an Emergency Preparedness Plan; (ii) notification of the validation of the IOP by the MESD; and, (iii) Incident management and crisis resolution procedure. In its current location in Dakar and its new production site of Diamniadio, IBS is located in an industrial area. There is no significant community living around its operations. IBS intends to transfer its emergency practices already implemented in its existing facility, notably an incident management and crisis resolution team in charge of handling incidents that might accidentally happen. The team is multi-disciplinary, led by the General Manager and composed of plant leaders. Road safety is a part of the planned response to emergencies and is incorporated into the existing ESMS. Several awareness sessions have been conducted for safe road behavior when using the IBS-owned light vehicles and trucks. IBS continuously communicates its goal of zero accidents at work, including commuting accidents. IBS makes its staff, including drivers, aware of road safety during its morning briefings. In addition, vehicles are effectively maintained and monitored for a safe operation.

COVID-19 Impact. IBS workforce have been impacted in a minor way (such as through limited absences or workers arriving late due to a lack of available public transport). The company reorganized work teams to ensure distance measures were respected while on site and (in the early days of the pandemic) to work around the limitations created by the curfews that were put in place by the authorities. Meetings were held virtually. There have been a limited number of workers contracting COVID since March 2020; they had to remain away from work and in quarantine as per public health regulations. The company also developed new work instructions to ensure workers were made aware of distancing, awareness of other barrier measures. Visual displays of such measures/requirements were also created. The company did experience some difficulty in sourcing raw materials (due to availability of shipping).

EHS Monitoring and Reporting. IBS continues to implement a structured EHS monitoring and reporting system for its operations as was observed back in 2017 and which was seen to be in place during the site visit of August 2021. This practice incorporates appropriate Key Performance Indicators (KPIs) related to E&S aspects associated with its activities, such as Lost Time Injury Frequency Rates (LTIFR), and Accident-Free Days, water and energy usage and efficiency against production volume and cleaning products consumption, and waste generated by type as are found in WBG EH&S Guidelines.

In accordance with its partners' requirements, IBS monitors its wastewater internally after treatment at its wastewater treatment (WWT) plant. It monitors parameters such as pH, dissolved oxygen, sludge, BOD5, COD, free chlorine, suspended solids, ammonia, phosphorus, aluminum, iron, Total Dissolved Solids, sulphate and nitrates. It conducts external analysis of some of these parameters. These parameters are also monitored by The Coca Cola Company. Results show compliance with WBG EHS Guidelines.

IBS has established a waste management procedure with identification of each type of waste generated by the facility and the required treatment process. Hazardous waste, such as used oil, battery, ink cartridges, electrical and electronic equipment wastes, gas cylinders, are put in bins and stored in dedicated areas before being taken to the specific treatment facility. Waste is eliminated as per the local requirements. IBS monitors annually an indicator named rate of waste (by type) recycled, with a target of 45%. EHS monitoring frequencies and methodology are considered commensurate to IBS’s operational risks and impacts. The monitoring data is still compiled in a centralized database for development of summary reports, and regularly presented to senior management. Corrective measures are defined, and implementation is agreed upon following management review. For example, the QHSE watch and regulatory compliance document shared with IFC details that the General Manager requested the certificate of analysis and the certificate of compliance as proof of control of the presence of heavy metals and on compliance with other parameters. IBS also reports its E&S performance data to TCCC on a monthly basis. This reporting includes production volume, water and energy consumption, CO2 consumption, fuel utilization, accidents with lost workdays, and medical cases. In addition, on a quarterly basis, analysis of IBS wastewater effluent monitoring is shared with TCCC. The local regulatory agency (Direction de l'Environnement et des Etablissements Classes - DEEC, a department of the Ministry of the Environment and Sustainable Development), also requires IBS to share data on its wastewater quality once a year. Internally, these data are reviewed monthly by the plant’ leadership committee. Through the continuous implementation of the above mentioned ESMS, IBS is judged to be in compliance with IFC PS requirements and WBG EHS Guidelines.

Stakeholder Engagement Plan and Community Grievance Mechanism.  IBS is not located in an area where its activity impacts local communities. IBS current location as well as in Diamniadio, is within an industrial site. However, in case a grievance is reported, the quality assurance (QA) manager is in charge of registering the grievance and driving appropriate corrective action as per the grievance mechanism procedure with support of the leadership team.   

Human Resources Policies and Procedures. IBS has currently 131 permanent employees and 32 contractors. Among its permanent staff, there are 7 women in the administrative department, 2 in the Quality Control department, 12 in the cleaning department and 4 in the commercial department. Among its permanent staff, 19 have fixed-term contracts and 112 have open-ended contracts.

The HR Policy (‘’Règlement intérieur’’) did not cover all types of workers in 2017, while it lacked provisions related to non-discrimination and equal opportunity, harassment, and prohibition of forced and child labor (ref. ESAP#5, #40131). Therefore, IBS has upgraded its HR policy to include such issues. IFC reviewed and approved this new HR Policies in Dec. 2020, including inclusion of these requirements in the training curriculum of its Worker’s Induction session. 

Working Conditions and Terms of Employment. The current MR policy on employment/labor and working conditions is in compliance with the Senegalese labor laws and regulations and those of PS2 objectives. The « Convention collective fédérale des industries alimentaires » includes sections on trade union rights, employment contract, salary, working conditions, health and safety, staff representatives, interpretation and mediation committee, retirement and special provisions. The document (https://votresalaire.org/senegal/droit-du-travail/conventions-collectives-base-de-donnees/convention-collective-federale-des-industries-alimentaires-1958) was prepared by the “ Syndicats d’employeurs de la branche professionnelle « Industries alimentaires», affiliés à l’« Union Intersyndicale d’Entreprises et d’industries de l’Afrique Occidentale française » (UNISYNDI). It entered into force in 1958. IBS also complies with the Senegal Constitution, Article 7, Paragraph 4 (ref. All human beings are equal before the law; and that men and the women are equal in right), the requirements of the collective agreement of the food-processing industries (article 20, 21 of CCIAA), on the need for equal treatment in matters of employment, non-violence and zero tolerance of harassment of any kind at work. In compliance with article 4 of the Senegalese Labor Code and article 17 of the CCIAA, all forms of work are accepted except by forced or compulsory labor, child labor, etc.

IBS was audited in 2018 against The TCCC Guiding Principles for Suppliers, including compliance with applicable national laws and regulations, child labor, forced labor and human trafficking, abuse of labor, freedom of association and collective bargaining, discrimination, wages and benefits, work hours and overtime, health and safety. The audit’s findings did not document any deficiencies on these requirements. In addition to evidence of the above having been addressed, a policy against sexual harassment is also integrated into the internal HR regulations. Requirements related to child labor, minimum wage, overtime, training on Safety, Health and Protection, wearing personal protective equipment (PPE), use of hazardous substances are integrated in the contractual agreements with contractors.

Workers’ Organizations. As required by the Senegalese Constitution (Article 8) and by the seven chapters of title II of the Senegalese Labor Code, all employees have the freedom to join a professional union. At IBS, employees are affiliated to the national union of food industry workers of Senegal and freely exercise their right in accordance with the laws and regulations.

Non-discrimination and Equal Opportunity. All forms of discrimination as they relate to race, color, age, gender, belonging to a union, brotherhood, religion or sect, ethnicity, pregnancy, social origin, handicap, etc., are addressed by the HR policy, are prohibited and occurrence sanctioned within the company. IBS stated that it strongly believes in equal opportunity employers. This is further stipulated by the collective agreement of the food-processing industries in its article 19. 1.

Grievance Mechanism. The company has a register for internal complaints as part of its PS-2 compliant grievance mechanism. The company reports on the use of the GM in the AMR submitted to IFC.

Protecting the Workforce. The company does not employ child labor or forced labor in its operations. As noted above, this is independently assessed as part of the TCCC audit of its suppliers.

Life and Fire safety. IBS improved its fire prevention system by installing this year (2021) automatic fire detection in the warehouse, syrup and utility rooms of its existing facility. For the new Diamniadio site, IBS is working with CEFI, a certified company with expertise in fire safety. The safety standards being complied with in the technical design (and ultimately operation) for this new plant are a combination of national norms (Senegalese and French) and those required by TCCC.

Workers engaged by Third Parties. Each contractual agreement with contractors and sub-contractors includes clauses to manage their operations with respect to relevant E&S risks and impacts. For example, sub-contractors must remove waste generated during their work on a daily basis before leaving the premises. They are required to take appropriate measures to prevent the ingress of rainwater or other external contamination, provide spill prevention devices and train their personnel to ensure the effective use of these devices. They are required to avoid the use of pollutants that have a negative impact on the environment and are required to wear PPE. As part of induction, they are instructed regarding what areas they can access, what risks may be found in those work areas, etc. For each job that requires use of a contractor, IBS has developed a work authorization permit which allows for a thorough risk assessment before the work begins. As part of this routine assessment, contractor’s employee is checked for identification and minimum age for work. 

For third-party suppliers of raw materials, IBS has its own requirements and those of its partners (e.g., TCCC). IBS was audited by SGS as part of TCCC Supplier Guiding Principle (SGP) audit program. SGP audit focuses on the following areas: laws & regulations, child, forces and abuse labor, collective bargaining, wages and benefits, working hours & overtime, business integrity, work environment, discrimination, employee health and safety, and management of risk related to the environment. Audit outcome was green (satisfactory) as IBS was found to comply with the requirements. When possible (e.g., in case of on-site delivery or collection), IBS instructs its personnel to observe that no child labor is used and that its OHS protocols are respected. Based on the implementation of the above measures, the company is judged to be in compliance with PS2 related supply chain requirement.

Occupational Health and Safety. The company’s operations are mostly fully automated using modern machines with adequate safety features and limited moving parts. Likewise, limited but potential risks come from lifting, repetitive work, posture injuries, falls on slippery surfaces, and burns from hazardous materials used in cleaning (e.g. caustic acid).  The company continues to conduct job hazard analyses, hazard avoidance or minimization, and provides necessary PPE for those jobs with residual occupational hazards (e.g. hearing protection, uniforms, masks, footwear and gloves). IBS periodically measures the noise at each workstation and, depending on the noise levels, it pro-actively provides its employees with earplugs or earmuffs. As evidence of the functioning of the OHS management system in place, latest OHS statistic provided to IFC (as part of the 2020 AMR) shows a Lost Time Incident Frequency Rate (LTIFR) of 6.77, which is below the 2012 US reference for beverage manufacturing (9.5). There were no accidents reported among the contractor’s workers.

Resource Efficiency. As part of its new production site in Diamniadio, IBS is installing a solar panel system on the roof to supply a portion of its electrical power needs. The company will report on the operation of this system in the AMR once it is up and running.                                                   

Greenhouse Gases. The amount of GHG was estimated in 2017 at around 2,000 tons CO2-e. Production rates (and therefore inputs of electricity and use of fuel in transport) have remained similar since then but have the potential to double following the move to the new facility. Even so, that will keep GHG levels below 5,000 tons p.a. The company will use the AMR to report its GHG emissions to IFC.

Water Consumption. The current raw water used by IBS comes from the national agency that supplies water to the city of Dakar. IBS’ current water needs will double after its move to the new production site in Diamniadio; the source of raw water for this plant will remain the same national agency. The Agence d’Aménagement et de Promotion des Sites Industriels (APROSI) is currently installing piping from the municipal water system to the new facility. As part of its project design process, IBS communicated its production water consumption needs to APROSI, and through them to the water authority; there have been no issues with regards to regulation or restriction regarding raw water supply from the relevant governmental agencies. In addition, as part of the planning and design of the new plant, IBS worked closely with local authorities to validate its water needs for its potential firefighting needs and emergency plans, etc.

Pollution Prevention.

Liquid effluents. Wastewater produced at the existing beverage processing plant was discharged into the Dakar municipal treatment system without treatment in 2017. As per ESAP#7 in #40131, including TCCC requirements, IBS installed a wastewater treatment plant (WWTP) for its existing Dakar operation. As such, IBS now treats its effluents before discharging into the municipal system so if the Dakar municipal WWT plant fails, or is incapable of treating its effluent, the effluent from IBS would still be of a sufficient quality and remain compliant to local and WBG EHS Guideline values (Table 1). The company will relocate its effluent treatment equipment to the new plant and supplement it, as needed considering its increased production capacity, in order to continue to treat water to the same standards. The company is currently in discussion with the management company that runs Diamniadio’ Industrial site to assess if its treated water can be used for irrigation within the industrial site instead of its discharge into the municipal sewer system.  

The boiler in use at the existing production site in Dakar is too small (less than 3 MWth) to require compliance with WBG EHS Guidelines limits. In accordance with the recommendations described in the Senegalese standard NS 05-062, IBS carries out quarterly monitoring of CO, NOx, SO2 and dust in the smoke from its boiler. Regarding fume emission, boiler is properly maintained every year by the original equipment manufacturer. IBS is installing oil removing units at different locations on the site to prevent oil leakage, and accidental soil contamination. For the new facility, IBS is acquiring similar sized new high performing clean burning boilers working with diesel. They will also be able to run on gas. Regardless, it will continue to perform its point source air monitoring program, as recommended by local regulation.

Solid and Hazardous Waste. IBS has established a waste management procedure with identification of each type of waste generated by its plant and the required treatment process. Waste is eliminated as per the local requirement and surroundings are not affected by IBS’s activities. IBS has recently acquired an aluminum can compactor to crush empty cans and sell them to companies (e.g., foundries) that can used them as raw material. IBS monitors its waste generation rates by type and has a current target to recycle 45% of that generated. Latest results regarding recycling rates are as follows: small wooden pallets (100%), mandrel (51%), empty can pallets (62%), cans - bidons (100%), cans (51%), drums (100%), WEEE – PSI (100%), ink cartridges (100%) and used oils (100%).

Hazardous Materials. Limited hazardous materials are used within the facility. Once used, hazardous waste such as used oil, battery, ink cartridges, electrical and electronic equipment wastes, gas cylinders, are put in dedicated bins and stored in dedicated areas before being taken for recycling or to a licensed treatment / disposal facility. Based on the measures undertaken above, the company is judged to be in compliance with PS3 requirements. They will continue to provide information and data to IFC on operational performance in the AMR.