The proposed expansion of the Nigeria warehouse will be on 3000 m2 of land adjacent to the current ABMN facility which was acquired through a 20-year lease from Oyo State. The land acquisition process did not involve any involuntary resettlement. The current warehouse and the factory are located in urban areas with no buffer zone between these operations and surrounding communities. The land is considered as modified habitats without significant biodiversity value, with no known historical and/or cultural heritage sites; and the project and its activities will not impact any indigenous people. Hence, no impacts for this project are expected against PS5: Land Acquisition and Involuntary Resettlement; PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7: Indigenous Peoples; and PS8: Cultural Heritage. If issues anticipated by these PSs arise, Bar Magen will promptly inform IFC. Screening and assessment of these issues against PSs requirements will be done through Bar Magen’s E&S Management System (ESMS).

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards

  This is a Category B project according to IFC’s 2012 Environmental and Social Sustainability Policy as the project is expected to have limited adverse E&S risks and impacts that are few in number, short-term and site-specific, and can be avoided or mitigated by adhering to recognized Good International Industry Practices (GIIPs) as described in the following sections and the attached E&S Action Plan (ESAP).

Key E&S risks associated with this proposed investment relate to EHS/HR management system, including organizational structure and internal capacity / competency for managing proposed operations in line with IFC PSs and Nigerian’s legal and regulatory requirements; implementation effectiveness of ABMN’s EHS, HR & food safety management systems; fair and safe working conditions for employees and contractors; energy efficiency; security management; and, community grievance mechanism.

 Environmental and Social Assessment and Management System. Bar Magen has a Food Safety Management System based on the Hazard Analysis and Critical Control Point (HCCP) system for its Israel operations which has yet to be replicated in ABMN. The company's products are approved by the Standards Institution of Israel in accordance with ISO 9001:2015 based on the HACCP system. For each risk identified across Bar Magen’s processing and warehousing operations, Standard Operating Procedures (SOPs) have been developed. The management of E&S risks is hinged primarily on implementing the existing SOPs. ABMN has an environmental management plan which guide the company on environmental risks assessment and management as required by national law. Going forward, the company will develop an Environmental and Social Management System (ESMS) in line with IFC PS1 requirements, World Bank Group’s (WBG) General EHS Guidelines, and national legal and regulatory requirements (ESAP#1), to systematically identify and manage E&S risks. The documented ESMS shall include: an overarching E&S policy statement, objectives & targets; organization capacity, including roles and responsibilities, management programs and plans, monitoring & review procedures and stakeholder engagement plan and community grievance mechanism.

Identification of E&S Risks and Impacts. Risk assessment for the factory and warehouse operations are conducted quarterly internally by staff and externally by a third-party consultant. For the last three years the main risks include OHS, waste management, and food safety while emergency response not being effective and incidents (loss-time working days and near misses) not being well documented. The findings include corrective action plans (CAPs) that are discussed by the management and implemented by a safety committee. Bar Magen’s risk and impacts identification is mostly guided by the equipment manufacturers’ specifications on air emissions, energy efficiency, etc. Statutory licensing laws provide for audits for ABMN operations from the Ministries of Agriculture, Labor, and regulatory agencies like National Environmental Standards and Regulations Enforcement Agency (NESREA), National Agency for Food & Drug Administration and Control (NAFDAC), Nigeria Institute of Animal Sciences, Veterinary Association of Nigeria, etc. There is no history of legal non-compliance in ABMN. Under the provisions of the Nigerian Environmental Impact Assessment Act No 86 of 1992 amended as EIA Act Cap E12 Law of the Federal Republic of Nigeria (LFN) 2004, it requires entities to conduct ESIA process for all greenfield projects. As part of this project, ABMN will commission an IFC PS-compliant ESIA for the construction of the new warehouse and implement the Environmental and Social Management Plan (ESMP) resulting from this assessment (ESAP#2). The ESIA report will be disclosed locally as per national and the Bar Magen’s Stakeholder Engagement Plan requirements.

Organizational Capacity and Competency. The overall responsibility for EHS matters in Bar Magen lies with the Operations Manager in Israel and the Administration Manager for Nigeria operations, assisted by Facility Managers. Given the planned operational expansion, ABMN understands the need for a more formal E&S function and will recruit an E&S officer, to coordinate the implementation of the ESMS and effectively oversee E&S risk and impact assessment and management during project development and implementation and during routine operations and to carry out contractor E&S supervision (ESAP#3).

Emergency preparedness and response plan. EHS incidents that could result in emergencies have been identified at ABMN operations and include fire, serious workplace accident, kidnapping and traffic accident. ABMN has an emergency preparedness and response (EPR) procedure which only focus on life and fire safety. Going forward, the company will review and update the current EPR procedure and equipment, as needed, to include its inclusion during the construction or expansion and operation phases. The EPRP will incorporate the services of the local administration, internally assigned staff on emergency teams and their roles and responsibilities explicitly defined. All employees and contractors will be responsible for reporting any emergency incident to the HSE committee delegate for assessment and actioning. (ESAP#4).

COVID-19 Measures: ABMN has implemented several COVID-19 response measures for its operations including: social distancing, working in shifts, administrative staff working from home, provision of masks, cleaning and disinfecting in line with governmental public health requirements. All staff have been vaccinated. There has been no significant health impact so far due to the pandemic and no recorded cases of COVID-19 among its workforce.

EHS Training. The company conducts EHS training during induction session for all new staff.  In addition, there are periodic in-house training based on 16 modules focusing on the Factory Act, personnel hygiene, food safety, emergency preparedness, etc. All workers and third-party employees undertake these trainings based on their work specialization.

EHS Monitoring and Reporting. At the factory and warehouse, there is a reporting system to the senior management on key Occupational Health and Safety (OHS) performance indicators (KPIs), such as lost time accidents, recordable injury, first aid cases, etc. Going forward, the company will also report annually to relevant national authorities like Oyo State environmental agency, Ministry of labor, NAFDAC etc., and IFC, as part of the Annual Monitoring Report (AMR). OHS audits are carried out at on a quarterly basis by a consultant. ABMN does not have a documented monitoring and reporting procedure which allows for a review of EHS performance. EHS monitoring for Bar Magen operations is driven largely by Nigerian permit requirements and is undertaken for ambient air quality and noise levels. The monitoring parameters and their thresholds are governed by Nigeria environmental laws which are aligned with WBG EHS Guidelines. Based on information provided during appraisal, ABMN did not incur over the last three years any material regulatory penalties, fines or sanctions for contraventions or non-compliance with statutory obligations, as well as not reported any fatalities on sites at any of its operations. Going forward, ABMN will establish a documented monitoring procedure including KPIs aligned with international requirements like energy and water consumption and efficiency; noise levels and management, solid and hazardous waste management and disposal, compliance with national OHS requirements, including OHS leading and lagging indicators (lost-time accidents); customers and community complaints, supplier performance and community engagement activities in line with WBG’s General EHS Guidelines. (ESAP#5).

ABMN operations currently employ 70 direct employees, including nine (9) women. The Israel facilities have 50 employees, including ten (10) women. With the IFC investment, the number of direct workers is expected to increase to 100 in Nigeria.

Human Resources Policies and Procedures. ABMN has an Administrative and Personnel Policy Manual that set out the main policies and procedures that guide HR management. The policies apply to all direct and contract workers and relates to equal opportunities, workplace harassment, code of ethics, employees’ benefits, disciplinary policy, leave entitlements, health and safety, and workers grievance procedure. The policies are consistent with the requirements of this PS2 and national labor laws and managed by HR and Administration Manager.

Working Conditions and Terms of Employment. To operationalize its HR policy, ABMN has developed an Administrative and Personnel Policy Manual which outlines provisions for equal opportunity and non-discrimination, recruitment, remuneration, allowances and benefits, training, performance management, leave, grievance redress & disciplinary measures, occupational health and safety, harassment including sexual harassment, working hours & overtime and termination. The manual also provides information with clear language on selection, transfer, promotion, and performance review. Bar Magen HR policy prohibit hiring of persons under the age of 18. The manual is socialized to all employees during the worker’s induction session.

Workers Organizations. The Trade Union (Amendment) Act of 2004 governs the activities of trade unions in Nigeria and provides for labor unions. ABMN workers are not unionized and do not have a Collective Bargaining Agreement (CBA). This is the same in Israel. Though there is no history of recent labor strikes among Bar Magen’s facilities, and management has indicated that there are no restrictions for workers to join trade unions/organizations at will, this is not documented in the HR Manual. The Company will therefore update the HR Manual to explicitly articulate that there are no restrictions on freedom of association and for workers to join trade unions/organizations. This provision will be explicitly communicated through a communication plan and outline during worker’s induction session (ESAP#6).

Grievance Mechanism. ABMN has established a workers’ grievance procedure commensurate to its operations. This procedure is part of the HR manual, issued to every employee. The procedure provides for documented grievance reporting, alternative handling methods, regular meeting and feedback to claimants and appeal options. This procedure is also accessible to contract workers. This mechanism is commensurate with the nature of ABMN’s operations and is consistent with PS2 requirements. While the company has provided suggestion boxes as an anonymous grievance mechanism, there have been no recorded anonymous grievances.

Life and fire safety. ABMN mixers and its warehouse operations are associated with fire risk.  The company has fire prevention policy, procedures and fire suppression equipment, mainly portable fire extinguishers. The company conducts internal Life and Fire Safety (LF&S) audits and has contracts with specialized service providers to ensure inspection and refilling of portal fire extinguishers are conducted on an annual basis. In addition, the Federal Fire Services of Nigeria conducts annual audit and provides certification. Going forward, the company will select and train Fire Marshals, who will supervise fire drills which will be conducted once per year in coordination with the local fire brigades (ESAP#7).

Workers Engaged by Third Parties. ABMN engage consultants, contractual and casual staff for the completion of specific tasks. They are not considered as employees and hence are not entitled to employee benefits. While the company conducts due diligence of some contractors, there is lack of details on the contracting process, how potential third-party service providers are vetted or monitored. Furthermore, it does not detail how ABMN’s E&S/HR policies and procedures are applicable to third party service providers. Going forward, ABMN will develop and implement a third-party / contractor selection and management process that will include the vetting and ongoing monitoring of contractors’ safety, compliance with labor law, and compliance with ABMN’s EHS/HR policies. In addition, the contractor management process will ensure that all contractors have access to the existing ABMN employee grievance mechanism should they not have a suitable internal procedure available (ESAP#8).

Occupational Health and Safety. The company does not have a stand-alone OHS policy. Standard operating procedures (SOP) for its processing and warehousing operations have some OHS elements which include (i) exposure to dust and biological agents, (ii) emergency response and (iii) noise prevention and control measures. Both Israel and Nigeria facilities ensure the risk management requirements are appropriately implemented by undertaking both internal and external assurance activities. For example, in Israel, an OHS consultant conducts inspection quarterly. Training on OHS is more pronounced and better planned in Israel. Going forward, the company will replicate the training plan in Nigeria to ensure a dedicated OHS training programs while visitors being allowed at site only after an introductory safety instruction. Incidents and/or accidents are reported and investigated as per internal procedures. OHS statistics (fatalities, incidents records) are maintained in both facilities. In the past three years, ABMN have not recorded any fatalities, non-fatal injuries, lost workdays, or vehicle collisions. The company’s lost time frequency rate (LTIFR) of 0 for the last three years.

Supply Chain. Main commodities are purchased either from local suppliers (maize, soya, limestone and packaging materials) or from international markets (mainly veterinary medicines, vitamins, and minerals), the latter being reputable multinational companies with subsidiaries in Israel, such as Nuetrico, Elanco, etc. As part of this project, ABMN will develop a Supplier Code of Conduct which will provide guidance on procurement requirements and guaranteeing that commodities are sourced in a responsible and ethical manner. The requirements will be drawn from PS2 and International Labor Organization (ILO) conventions, including (i) requiring provision of good working conditions (e.g., contracts, health and safety, equal opportunities), opposing all forms of child labor, forced labor and all other forms of abuse and exploitation, (ii) adopting a Supplier Code based on the compliance of all suppliers with human and business rights, and health and safety, environment, and business integrity requirements. ABMN will conduct a due diligence for all third-party suppliers and will be required to commit to the policy by signing the Supplier Code. ABMN’s legal department will ensure continuous compliance. In case of material non-conformity, ABMN may terminate an agreement with a supplier (ESAP#9).

 Energy use and greenhouse gas emissions. ABMN facilities use energy from the national grid. Emergency back-up generators are also used in case of power outage. Energy consumption (electricity, fuel) is closely monitored at all sites. Energy efficiency measures are embedded at the design stage and in technical specification of the equipment selected. In Israel, a photovoltaic (PV) rooftop solar has been installed with a capacity of 270 KVA which is approximately 25% of its total energy consumption.

Greenhouse Gases. Current GHG emissions from the existing factory and warehouses operations (based on electricity and fuels) have been estimated to approximately 69 tons CO2-equivalent per year (Scope 1 and 2) for ABMN. Additional GHG emissions due to the proposed expansion are not expected to be significant and will be well below 25,000 tons of CO2-equivalent per year.

Air emissions monitoring. Main sources of air emissions are the gensets that burn diesel to produce electricity during electricity outages. The generators undergo periodic maintenance audits in accordance with manufactures requirements to optimize efficiency. Given their size (below 3 MWh) and frequency of usage, stack air emissions from its generators are considered minimal and not measured.

Water use and efficiency. The primary operations of Bar Magen do not use water (dry process). The company provide workers with bottled drinking water, while water for other uses like sanitation is sourced from a licensed borehole within the facility. Total water consumption is well monitored through installment of water meters. The company educates its employees on the importance of water conservation.

Management of solid and hazardous wastes. Wastes from ABMN warehouse and factory are characterized by organic waste, mainly hulls, solid waste (cardboard, nylon, packaging, metal, plastic, etc.), and hazardous waste (light bulbs, used oil and clothes, diesel tanks, chemical containers, batteries, reagents from the laboratory, etc.). All the waste is stored in a designated area, collected periodically, and disposed by authorized service providers. Plastic bags and pallets are sold, and the proceeds is sent to the welfare committee.

Effluent Management. ABMN operations only carry out dry processing (e.g., removal of moisture) and hence produces minimum effluent waste. Sanitary effluents are channeled into a septic tank system. When full, a licensed third-party contractor will collect disposed into a state wastewater treatment plant.

Pest management and control: Fumigation is carried out in the factories and warehouses, using phosphine or hydrogen phosphate (PH3). Licensed service providers are recruited to conduct rodent control in all operations and include inspection and maintenance.

  Community Health and Safety: In Nigeria, the facilities are surrounded by various stakeholders, including churches, residential houses and amenities. ABMN is committed to harmonious relationship with surrounding communities. There are potentially limited impacts on surrounding communities, aside from induced traffic and noise during the construction of the warehouse. On average, the company utilizes 20-50 trucks per week for dispatching its products which are from third party contractors. The company has internal regulations applying to drivers and include scanning of drivers’ license, inspection of trucks on defects and drivers on appropriate PPE. During the construction of ABMN’s warehouse, it will inspect the implementation of the ESMP by the contractor to ensure community health and safety procedures are adhered to. As part of corporate social responsibility, ABMN provides water to the neighboring communities

Security Personnel: ABMN facilities are manned by unarmed security personnel from a licensed service provider supplemented by armed Nigeria police. While ABMN appraise potential security service providers for past cases of human rights violations, the company will assess risks posed by its security arrangements to those within and outside the project site and develop a Security Management Plan (SMP), including a training module for management and security personnel. This SMP shall be aligned with the Voluntary Principles on Security and Human Rights and with the requirements of PS4. (ESAP#10).