Issues related to PS5: Land Acquisition and Involuntary Resettlement, PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected with this investment.  The land acquisition process for the new facilities in Morocco and Senegal will not require any physical resettlement or economic displacement.  The plots are on modified urban environments.

This is a Category B project according to IFC’s 2012 Environmental and Social Sustainability Policy. Based on information reviewed during appraisal, the project is designed, as described in the sections below, to avoid, minimize and manage E&S risks and impacts of the company’s operations in compliance with national legal and regulatory requirements, IFC Performance Standards, and its own corporate policies.

Key E&S issues associated with this investment relate mainly to (a) company’s E&S management systems and staffing to ensure development and operations of assets in line with IFC Performance Standards; (b) adequate E&S risk screening and assessments for proposed acquisitions and operations; (c) assurance of fair, safe and healthy working conditions for employees and contracted workers during construction and operation; (d) management of air emissions and wastewater from proposed operations; (e) workers and community grievance mechanism; (f) security and traffic management; and (g) energy efficiency of the operations.

 Environmental and Social (E&S) Policies and Management System: Ifria has a draft corporate level Environmental Health, Safety and Social (EHSS) guide.  The EHSS guide includes policies on construction phase mitigation measures, management of ammonia refrigerant gas, solid waste management, facility effluent management, carbon dioxide mitigation and ozone depletion mitigation, and environmental management systems.  Social policies include gender equality, labor security, employee compensation, and contractor qualification and management.  The policies will apply to all Ifria operations and includes third-party suppliers and contractors.  While these policies commit the organization not to undertake projects that unnecessarily harm the environment and have strong social attributes, Ifria will develop a corporate level Environmental and Social Management System (ESMS) aligned with IFC Performance Standard 1 and commensurate to the level of risks associated with the company’s business activities. Specifically, the ESMS will include: an overarching policy statement; objectives and targets; the definition of an organizational structure and relevant roles and responsibilities. Corporate E&S management procedures to be developed and implemented as part of the ESMS include: (i) Labor and Human Resources Manual; (ii) Environmental Health and Safety (EHS) procedure; (iii) Occupational Safety and Health procedure; (iv) Waste Management procedure; (v) Emergency Preparedness and Response procedure; (vi) Stakeholder Engagement procedure that includes an External Communication and a Grievance Mechanism); (vii) Security Management Procedure, (vii) E&S Risks and Impacts Screening and Assessment Procedure, and (ix) Contractor E&S Management Procedure. The corporate procedures will guide the development and implementation of the required E&S assessments and management plans at the project level, both for acquisitions and for new facilities during construction and operations (ESAP #1).

Identification of Risks and Impacts: Ifria will identify E&S risks and impacts through an E&S assessment process for construction and operation of the proposed greenfield facilities. Ifria will ensure that social aspects are included in the risk and impact identification and assessment to be carried out in compliance with PS1 and applicable national requirements in Morocco and Senegal. Disclosure and consultation will be carried out per local requirements and in line with the requirements of PS1 and will be reflected in the Stakeholder Engagement Plan for the project (see ESAP #1 for the corporate procedure). In addition, Ifria will conduct E&S due diligence against IFC PS to identify any potential legacy E&S issues from the existing facility in Morocco and any brownfield operations to be acquired. (ESAP #2).

There are no specific set of E&S risk management procedures documented by the company to screen for the E&S risks during project design and development and to guide E&S compliance by the company and its contractors. As such, the ESMS, under ESAP #1, will include E&S risk and impact assessment and management procedures to guide risk identification and management across the business, consistent with IFC’s Performance Standards.

Organizational Capacity and Competency: Ifria is a new company, although the four partners have many years of experience in TCL.  In the current set up, the Executive Managing Director Operations and the Project Manager are responsible for E&S during operations and maintenance (O&M). The company does not have a trained environmental, health and safety professional to effectively discharge this function and coordinate with other responsible officers in implementing the ESMS.  Given the planned operational expansion across various countries, Ifria understands the need for a more formal E&S management organization and will recruit an independent engineer with capacity on E&S during the contraction phase and assign a competent Ifria staff as a corporate level E&S Manager, 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.  Ifria will also ensure each facility has an EHS officer. (ESAP #3).

Emergency preparedness and response plan: Ifria has an emergency management policy that requires the company to have (i) an evacuation plan, (ii) fully stocked first aid kits that are easily accessible for all offices, and warehouses, (iii) designated workers to perform leadership roles, and (iv) designated assembly points. Ifria will further operationalize this policy by developing an emergency preparedness and response plan at each facility as part of ESAP #1. The plan for the warehouses will include (i) the designation of an emergency committee responsible for first aid and fire prevention, (ii) identify areas where accidents and emergency situations may occur, the response procedures (for fire, earthquake, flood and hurricanes, civil unrest and theft), (iii) provision of periodic emergency preparedness training (annual) and fire drill (semester) to personnel and contractors, including the participation of the Local Fire Department, and (iv) ensuring existence of clear marking of evacuation routes and assembly points as part of the evacuation plan.

Monitoring and Reporting: As part of the draft EHSS guide, Ifria intends to develop environmental and social monitoring indicators to be calculated and audited on a yearly basis. As part of ESAP #1, as part of the ESMS, Ifria will develop an internal monitoring system which will include the monitoring of key KPIs such as air emissions (point source and ambient), energy utilization and refrigeration gases, compliance with national OHS requirements, including accident rates (lost-time accidents), primary suppliers risk assessment and management, and contractors EHS performance.

 Human Resource Policy & Procedure: During operations, Ifria is envisioning a workforce of about 260 direct workers (50% male and 50% female). Ifria has prepared a social and human resources guide.  The guide has policies on employee rights, code of conduct to be signed by every employee, disciplinary procedures, grievance management and a monitoring process of social indicators.  The HR policy commitments include, fair, safe, and hygienic working conditions, fair living wages, working hours and benefits, non-discrimination, or harassment (including sexual harassment), prohibition of child and/or forced labor, etc. While the policies are consistent with the requirements of PS2 and national labor laws, the company will develop an HR Manual and relevant Procedures guided by its policies and IFC PS2, also including respect for collective bargaining and freedom of association, workers’ access to grievance mechanism, equal opportunity, and measures to prevent and address gender-based violence (ESAP #4).

Workers’ Organizations and Grievance Mechanism: Ifria’s social and human resources guide commits the organisation to comply with national legislation and to provide workers with freedom of association. The company will not discourage workers from electing representatives, forming, or joining employee organizations of their choice, nor will it discriminate or retaliate against workers who participate or seek to participate in such organizations and collective bargaining agreements. Various staff communication channels for grievances are listed in the guide.  However, Ifria will develop and implement a worker grievance procedure compliant with PS2 as part of ESAP #4. The procedure will apply to all operations, and accessible to contracted workers, and will include (i) alternative platforms for submitting a grievance, (ii) provision for both anonymous and gender specific complaints and (iii) provision for third party mediation and arbitration should it not be possible to resolve the grievance internally.

Occupational Health and Safety: Occupational health and safety (OHS) risks associated with TCL and distribution are largely limited to forklifts accidents, working in cold temperatures, slips/ falls and road safety. Ifria has made a strong commitment to ensure safe working conditions of all its workers and contractors in warehouses in its EHSS guide.  To operationalize its policy, the company will develop a corporate Occupational Health and Safety (OHS) procedure aimed at (i) achieving a safe and accident-free workplace in all offices, warehouses, and during transportation of goods, (ii) incorporating OHS principles in project planning and work activities, (iii) ensuring identification and management of OHS risks in the workplace, including incident reporting and tracking, (iv) monitoring and reviewing implementation of OHS management measures and corrective action plans and (v) worker OHS training programs. The scope of the procedure will include both employees and contracted workers. (ESAP #5).  The warehouse managers will be trained and tasked with enforcing OHS requirements and ensuring employees and contracted workers’ health and safety.

Fire prevention, protection, suppression, and control measures will be included in the design of the warehouses, which will be designed, constructed, and operated by competent professionals in accordance with design standards and GIIP, taking into consideration safety risks. Ifria will commission a local L&FS expert to conduct annual L&FS audits and ensure the warehouse managers implement any corrective action plans from the L&FS inspection. (ESAP #6).

The company will commission contractors for the construction of the new warehouses in Morocco and Senegal. Ifria will develop and monitor the implementation of EHS management plans by the contractors, in line with national’s OHS laws and IFC PS2 as part of ESAP #5. The plans, among other measures, will include procedures for managing and monitoring OHS performance of the construction contractors by Ifria team and will ensure that such requirements are contractually biding for the contractors. Ifria will also ensure that contractors do not hire child or forced labor.

To manage the impact of COVID-19 on the business and employees, Ifria will ensure compliance with the guidelines provide by the World Health Organization and the Ministry of Health at respective countries, develop appropriate mitigation and management measures and ensure continuous updates are provided to employees and contractors.

Workers Engaged by Third Parties: The company has developed a contractor management guide that provides for documentation of contractor information, however, does not provide any detail on how potential third-party service providers are vetted or monitored. Furthermore, it does not detail how Ifria’s E&S policies and procedures are applicable to third party service providers. As part of the project, Ifria will develop and implement a contractor selection and management process that will include the vetting and ongoing monitoring of contractors’ safety, compliance with labor law, and compliance with Ifria policies. In addition, Ifria will ensure that all contracted workers have access to the Ifria worker grievance mechanism should the contractors not have a suitable internal procedure available. (ESAP #7)

 Resources Efficiency and Greenhouse Gas (GHG) Emissions: As the Ifria’s warehouse facilities under the proposed investment will be located in industrial zones, electricity will be provided by the national distribution grid. There will be back-up generators in case of power outage. Energy consumption will be monitored closely, and data on electricity and diesel/gas consumption will be reported annually. The company aim at implementing energy efficiency measures to reduce its operational cost and, as part of ESAP #1, will develop a Resource Efficiency and Refrigerant Gas Management Plan which will include measures to reduce energy, water and material consumption (including refrigerants).

The annual total greenhouse gas (GHG) emissions of the proposed acquisitions and greenfield based on electricity use (scope 2) are estimated at 2,283 tons of CO2-equivalent. GHG emissions are attributable mainly to the use of refrigeration units; and secondarily to the use of fuel for vehicles (as many of them are equipped with natural gas engines). Both Morocco and Senegal are signatories to the Montreal Protocol and are committed to phase-out of HCFCs by 2030. The new warehouse refrigeration systems will be based on the use of R407, R410, R404 and R134 refrigerants. The company will install new equipment which will use ammonia gas, which is more energy efficient.

As part of the Ifria’s management of ammonia refrigerant gas guide, the company has indicated to undertake two inspections per day and regularly checks of the refrigeration equipment. An automatic monitoring system will be installed, and a dashboard will display any anomaly. The staff responsible for refrigerator maintenance will undergo relevant training, including safety instructions. Ifria will ensure that the regular service of refrigerating equipment will be outsourced to a licensed company. All the relevant procedures, including monitoring and control of leakages and safety procedures, will be included in the Resource Efficiency and Refrigerant Gas Management Plan.

Pollution Prevention: Wastes from the Ifria warehouses are and will be characterized as organic waste, mainly food wastes, solid waste (cardboard, nylon, packaging materials, metal, plastic, etc.), and hazardous waste (light bulbs, used oil and clothes, diesel tanks, chemical containers, batteries refrigerant waste etc.). Ifria has developed a standard solid waste management guide to provide on how solid waste is stored in designated areas, collected periodically, and disposed by authorized service providers. During construction, the EHS management plan for the construction phase will include the relevant waste management measures. Under ESAP #1, the company will develop a corporate Waste Management Procedure and relevant plans at the facility level.

The facilities will be located in zoned industrial area with established sewer lines and a water treatment facility.  Sanitary effluents at the warehouses will be connected to the sewer lines.

 As indicated under PS1, Ifria’s warehouse facilities will be located in industrial zones. As an integrated cold chain company, Ifria will provide warehousing and storage solutions for the cold chain and will support transportation and distribution logistics. As such, risks and potential adverse impacts to surrounding communities are expected to be limited, and mainly related to an induced increase in road transport between the warehouses and point of sale. Ifria will ensure drivers of its transport contractors will undergo defensive driver training and will ensure that a road safety plan is implemented, including vehicle maintenance and inspection program (ESAP #8).

Security Personnel:  Ifria facilities will be within industrial zones which will have their own security, including security forces provided by the Government. Ifria will employ unarmed security personnel for access control and guarding of property. As part of this project, and guided by safety and security management guidelines, the company will assess risks posed by the proposed security arrangements and develop and implement a Security Management Plan (SMP). The SMP will include a training module for company’s management and security personnel and be aligned with PS 4 (ESAP #9).

 Community Grievance Mechanism: As part of ESAP #1, the company will develop and implement a documented grievance mechanism for local community to receive and address any concerns or complaints from interested or affected stakeholders. Ifria will ensure the mechanism is able to receive anonymous complaints and provide confidentiality to any community member who registers grievances, and in particular, respond in a survivor centered way on any complaints of Gender Based Violence (GBV).

 Contact Person: Mr. Mathew Meredith, Executive Managing Director

Company Name: Ifria Cold Chain Development Company LLC

Wilmington, Delaware, USA

Email: mmeredtih@ifriacold.com / contact@ifriacold.com

Phone: +1 202 550 5627