This is a Category B project according to IFC’s 2012 Policy on Environmental and Social Sustainability as the project is expected to have limited adverse environmental and social 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) procedures, guidelines, design criteria and pollution prevention/control equipment’ Best Available Technology (BAT) as described in the following sections and the attached E&S Action Plan (ESAP). This categorization is aligned with similar type of projects within the sector.

The key E&S risks associated with this project include: (a) IFC PSs compliant E&S Impact Assessment (ESIA) for proposed expansion in Nigeria and greenfield manufacturing facilities, including implementation of E&S management plans (ESMPs) as per Terms and Conditions of the Environmental License; (b) company’s ESMS aligned with IFC PSs requirements and World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines (General and for Pesticide Manufacturing, Formulation and Packaging) and implementation effectiveness; (c) company’s E&S staffing, capacity and competency to implement the corporate ESMS and plant-level ESMP, including assignment of annual EHS OPEX/CAPEX; (d) assurance of fair, safe and healthy working conditions for employees and contract workers, especially occupational, health and safety (OHS) procedures; (d) effluents, atmospheric / point source air emissions, waste and hazardous materials management as per national standards and WBG EHS Guidelines; (e) integrated pesticide management; (f) life and fire safety and emergency response; (g) road traffic and security management; and (h) stakeholder engagement and community grievance mechanism.

E&S Impact Assessment (ESIA) and Risk Assessment. An Environmental Impact Assessment (EIA) was conducted in 2016 prior to the commissioning of the Ibadan facility in Nigeria. The EIA was completed in line with the applicable legal requirements and included baseline environmental monitoring and stakeholder engagement. The EIA was approved by Federal Ministry of Environment (FMEnv) and environmental impact statement certificate was issued in 2017. The EIA identified that the suspended particulate matter (SPM) in the project area were exceeding the applicable limits specified by FMEnv (250 mg/m3).

Currently, the Group is in the process of evaluating applicable E&S requirements for the proposed expansion in Nigeria and the construction of the proposed greenfield facilities in other countries. Prior to the expansion of the existing facilities and/or to the construction of the greenfield facilities, the Group will commission an ESIA, meeting all applicable national legal and regulatory requirements, IFC PSs requirements and WBG EHS Guidelines (ESAP#1). These ESIAs will have to include a comprehensive environmental and socio-economic baseline, including provisions for environmental monitoring, social impact assessment and public engagement. Detailed Environmental and Social Management Plans (ESMPs) addressing all material risks and impacts identified during the ESIA Studies will be developed and implemented at each site. Considering that the original EIA for Ibadan site identified a degraded air shed – having SPM exceeding the limits, the ESIA for the Ibadan expansion in Nigeria will have to include a rigorous baseline air quality monitoring plan in the dry season. Based on the monitoring results, additional mitigation measures will have to be identified to ensure that there are no additional impacts on air quality. In addition, the Group will have to complete environmental and OHS risk assessments for the expansion and proposed greenfield facilities and share with IFC for review (ESAP#1). Based on the risk assessment and ESMPs, required preventive and mitigation measures, including required infrastructural measures and assignment of OPEX/CAPEX, will be implemented at all facilities within agreed timelines with IFC.

E&S Policy, Management Systems and Programs: As the only Group’s active manufacturing operations are in Nigeria, GACI Nigeria has adopted a policy on Health, Safety and Environment (HSE), which includes commitment to compliance to applicable legal requirements, safety assessment and management for new operations, contractor management and employee training. GACI has also a policy on Community Affairs, Safety, Health Environment, and Security (CASHES). Finally, GACI Nigeria has also documented Standard Operating Procedures (SOPs) on waste management, traffic management, drug and alcohol and operating procedures for fire emergency. The facilities conduct regular accident-incident investigations. The Group has yet to develop corporate EHS policies and management systems, which can be implemented at all proposed facilities. Going forward, the Group will engage a qualified consultant (that is acceptable to IFC) for supporting the development and implementation of corporate E&S policies and management systems as per Terms of Reference (ToR) agreed with IFC (ESAP#2). EHS performance-level requirements of these policies and management systems must meet national legal and regulatory requirements, IFC’s Performance Standards, WBG EHS Guidelines and FAO’s International Code of Conduct on the distribution and use of pesticides. The policies and management system will have to cover at least the following key elements: (a) chemical management plan (as described under PS3); (b) life & fire safety (LFS) management programs for all facilities; (c) emergency preparedness and response plans; (d) contractor management programs to supervise their compliance with legal requirements (labor/OHS) and IFC PSs; (e) pollution prevention processes including air emissions, wastewater management, solid and hazardous waste management plans (as described under PS3); (f) OHS management programs commensurate to the risk posed  by the activities (as described under PS2); (g) resource efficiency program, including corporate targets; (h) monitoring and reporting (internal and external) framework including the key E&S performance indicators for effectiveness and compliance status of all operations and regular environmental and OHS monitoring; (i) road traffic and security management plans; (j) stakeholder management including community grievance mechanism; (k) roles and responsibilities of all personnel involved; (l) training plans with roles and responsibilities and budgetary allocation for its staff (permanent and seasonal) and contractors; and (m) periodic management review by senior management/board.

The ESMS will be implemented for all facilities (including warehouses and sale depots) within agreed timelines as per the ESAP#2. Apart from the development of corporate E&S policies and management systems, the ToR of the consultant will also include conducting regular (e.g. bi-annual) reviews based on a pre-determined plan to review ESMS’s implementation progress and effectiveness at corporate and at all facilities, including needed immediate Corrective Actions Plans (CAPs).

E&S Organization Capacity: The Group does not currently have any corporate E&S function. GACI Nigeria facilities (Kano and Ibadan) have an in-house HSE specialist to ensure day-to-day implementation of HSE policies and procedures. The HSE specialist has undergone basic HSE training. The HSE specialist is supported by an external consultant on a part-time basis. Considering the proposed expansion into multiple countries, the Group will need to significantly strengthen its corporate and plant-level SHE functions. Going forward, the Group will appoint a qualified E&S Director with proven experience in the agrochemical sector in developing and implementing corporate E&S policies and management systems in accordance with Good International Industry Practices (ESAP#3). The person will also be responsible for the monitoring oversight of the ESMS and program effectiveness at facilities level, as indicated above. The corporate E&S Director shall be supported by the consultant hired to develop the E&S policy and management systems (ref. ESAP#2). Also, the Group will appoint a E&S specialist at each facility in Ghana, Tanzania, and Uganda where manufacturing operations are being established. The appointment of these specialists will take place before commissioning the ESIA study.

Emergency Preparedness and Response: The installed fire safety system at the GACI Nigeria facility (Ibadan) is mainly relying on fire extinguishers. The fire extinguishers are regularly serviced by a service provider. A fire hydrant system is under installation at this facility to be completed by June 2022. The facility has a fire safety certificate from the state fire service, which is located close to the facility. Based on the observations at the Ibadan facility, the number of fire extinguishers needs to be reviewed to ensure their adequacy. Also, a fire alarm system has not been provided at the facility. Going forward, an independent audit of the Life and Fire Safety System (LFS) by a competent professional will be carried out at the Ibadan facility to assess adequacy of the system (ESAP#4). Based on the audit, a Corrective Action Plan (CAP) on needed upgrade of the existing system will be developed and shared with IFC. The plan will be implemented within the agreed timelines and the assessment findings will also be used as the template/technical specification for fire safety system for all existing and proposed facilities.  

The company is using liquid Ammonia in Glyphosate production. Currently, the Ibadan facility does not have any specific leak detection and alarm systems or any kind of emergency response measures, in case of Ammonia leakage. Going forward, the Group will install an ammonia leak detection, alarm system and emergency response measures (ESAP#4).

The Ibadan facility has a standard operating procedure for fire emergencies. The evacuation exits, routes and assembly points were marked during the site visit. However, no emergency response plan has been documented for this facility to cover other potential emergencies, e.g. medical emergency, natural gas leaks, Ammonia leaks, chemical/fuel spills and security emergencies. The Group will develop emergency response plans for the existing and planned facilities covering all potential emergencies, including potential ammonia leakages which should describe detailed roles and responsibilities for relevant personnel (as well as their back-up), training needs and their frequencies (ESAP#4). All employees and contract/temporary workers will be trained on the emergency response plans through appropriate training and drills including specific training on first aid and fire-fighting. Coordination with neighboring facilities or communities that may be potentially impacted will also have to be described in the off-site emergency response plans. Emergency response plan template will be used for development of plans for all proposed facilities.

As per site visit observations, the facility is taking protective measures against COVID-19 (such as washing of hands, use of sanitizers and use of face masks). The company has also encouraged workers to be vaccinated to reduce the spread of the air-borne disease. Based on available data, about 80% of staff are partially/fully vaccinated.

E&S Monitoring and Review: Based on the observations and documents accessed during the field appraisal, GACI Nigeria Ibadan facility maintains accident-incidents records. Also, regular health checks are conducted for the workers. There is no other environmental and OHS monitoring which are conducted at the facility. The Group does not have any corporate E&S monitoring procedures. As part of the ESMS development (ref. ESAP#2), the Group will develop a comprehensive monitoring and reporting framework at both corporate and facilities levels aligned with national legal/regulatory framework, IFC PSs requirements, including applicable WBG EHS Guidelines (General and Sector-Specific – Pesticide manufacturing, formulation and packaging). The monitoring and reporting framework will describe: (a) key performance indicators (KPIs) on E&S compliance and performance for all operations (e.g., ambient air quality, point source air emissions, wastewater treatment and quality, OHS monitoring data, waste generation, segregation and disposal, spills, mock drills and training, accidents and incidents); (b) monitoring processes (e.g., inspections, internal/external audits); (c) reporting requirements in specific formats; and (d) process of regular management review for all operations by senior management. The framework will specify KPIs to be monitored at the facilities, monitoring frequencies, type of monitoring and the definition of thresholds that signal the need for corrective actions.

The Group employs over 2,400 people – about 70% of them for its operations in Nigeria. The visited facility in Ibadan has about 210 employees and 30 temporary workers (including 200 males and 38 female). The number of temporary staff increases during peak production period. The group is expected to employ total 4000 employees when the new facilities and expansion are operational – with 2400 employees in Nigeria, 150 employees in Tanzania and 580 employees each in Ghana and Uganda.

Human Resources (HR) policies, management procedures, working conditions and terms of employment: The GACI Nigeria (Ibadan) facility has an overarching HR policy which describes operational HR procedures for recruitment process, induction and training process, payroll and attendance process, taxes, leave, and employee transfer process. The facility also has an Employee Handbook that outlines all working conditions for staff, such as company and employee obligations, terms of employment, disciplinary actions, work schedules and conditions, grievance procedure, working hours, appraisal and promotions policy and benefits and compensation.

This HR policy is only valid for the Nigeria facility level and will need to be amended for a corporate HR framework and then extended to all proposed operations. After review, some of the PS2 requirements are not covered in this policy such as, non-discrimination, prohibition of child and forced labor. Therefore, as set forth in the ESAP #5, the Group will develop HR policies in compliance with the applicable national legal labour requirements of the specific countries of operation and in IFC PS2 requirements, especially on non-discrimination, prohibition of child and forced labor, freedom of association, contractor management. Similar to GACI Nigeria, Employee Handbooks will be prepared and distributed with the corporate/country-level revised HR policies for all countries of operation covered in the project.  

All employees are provided employment letters which included conditions of employments such as salary breakdown, working hours, leave provision and duration of probation. The regular working hours for office-based staff is between 8:00 am to 5:00 pm, while factory workers have a shift time of 12 hours (8 hours regular and 4 hours overtime) six days a week. The overtime policy is included in the Employee Handbook. Based on observations during the appraisal visit, wages and overtime payment were noted to be in compliance with the applicable legal labor requirements. All employees are provided with pension benefits, health insurance and transportation.

Additionally, the company has a cloak room at the facility for its workers (separate for males and females) for resting and having their meals. However, the condition of the cloak room needs improvement on additional chairs and lockers. As per the ESAP#6, the cloak room facilities should be improved at the Nigeria facility and similar facilities shall be provided at all proposed facilities in line with GIIPs and applicable legal labor requirements.

Non-discrimination: As mentioned above, the Group does not have a documented policy on non-discrimination. Such provision will be specifically included in the upgraded corporate and country-level HR policies, as set forth in the ESAP#5.

Prevention of child and forced labor: The Group does not engage forced labor or persons below 18 years of age. No instances of child and forced labor were noted during the field appraisal. However, there is no specific provision on such requirement has mentioned above. Such provision will be included in the HR policies as set forth in the ESAP#5.

Freedom of association: The Group does not restrict its employees to join unions. However, currently, the employees at the visited Ibadan facility do not belong to any unions. For Nigeria, the company has a signed memorandum of understanding (MoU) with the National Union of Chemical Footwear Rubber Leather and Non-Metallic Products employees (NUCFRLNM) even though none of its employees are member of this union.

Also, the facility was noted to have a workers’ representative who serves as a liaison between the workers and management in terms of grievance mechanism, welfare and compliance. Based on the interview with workers, it would appear they are satisfied with this arrangement. To strengthen the freedom of association and Collective Bargaining provision, the Group shall include a documented policy on freedom of association in its HR policies (ref. ESAP#5).

Grievance mechanism: A grievance mechanism was noted to be documented in the Employee Handbook. The procedure requires the employees to raise the grievances with the immediate line manager and in case not being resolved, to escalate to the Managing Director. The procedure is explained to the employees during Worker’s Induction session. As per available information, no significant grievances have been received from the employees. As per ESAP#5, the company will expand the grievance procedures to describe process of resolution, include provisions to submit anonymous grievances, prevent any retribution for raising any grievances and extend the grievance process to third party workers. Also, the grievance process shall have a separate grievance redressal process for any sexual harassment related grievances/complaints. The grievance procedure will be included in the revised HR policies described above and communicated at all proposed facilities.

Occupational, health and safety (OHS): Based on the observations during the site visit at the Ibadan facility, there are display of safety signages, aisle markings, emergency routes and exit markings.

The equipment and operations are semi-automatic, which reduce the risk associated with hygiene and worker safety. The packaging of the finished product is done through automated filling machines which are enclosed, thus removing the potential for physical contact between workers and the finished product. The workers were provided with appropriate personal protective equipment (PPE) and use is strictly enforced within the facility. Training on operation of equipment was documented to be part of the Worker’s Induction session. Material Safety Data Sheets (MSDSs) for all chemicals used at the facility are available.

The facility has a ventilation system in all areas, except in the formulation section which leads to high temperature. The ventilation system in this section is under installation and expected to be completed soon. The Group shall ensure completion of ventilation system for all section of the facilities (ref. ESAP#1) as part of the environmental and OHS risk assessment in all workstations as described in PS1. Risk Assessment section above. The ventilation system has not been connected to any extraction / scrubbing system and thus emissions from the work area are exhausted directly. Work area air quality monitoring has not been completed for assessing level of exposure to various chemicals used and produced in the facility. As per ESAP#7, the Group will conduct work area air quality and process emissions monitoring for assessing level of exposure to various chemicals and noise through a qualified service provider. Based on the results, required mitigation measures need to be identified and documented as a CAP with strict implementation timelines. Based on level of work area air quality and process emissions, ventilation system shall be connected to scrubbers. Implementation of the scrubbers needs to be included in the CAP.  

The facility conducts monthly health checks for the workers in high-risk workplace. However, the tests conducted are mainly physical examination, vision, lung function tests and routine blood count. As the manufacturing process includes usage and production of toxic chemicals, as per ESAP#7, the Group will identify additional parameters to ensure no negative effects of worker’s exposure to these chemicals. Health checks will be completed at the Nigeria facility to establish a baseline of workers’ health conditions and appropriate corrective and preventive action plans shall be prepared to mitigate any OHS impacts due to their work.

The Ibadan facility has an on-site clinic with basic medication and health care facilities along with a registered nurse and first aid boxes (at the clinic and in production section farthest from the clinic). Facility supervisors are trained to handle basic first aid. Incidents are reported in detail in the incident and occurrence logbook, while there is a hospital logbook at the clinic for incidents requiring medical attention. No major incidents/accidents have been recorded as per available records. However, no investigation is carried out for the incidents. 

The Group does not have any documented OHS management system and processes. Therefore, as mentioned under PS1. Risk Assessment section above and as per ESAP#2, an OHS management system and programs meeting IFC PS2 requirements will be developed and implemented at corporate level which would then be adapted for each proposed facility, including specific safety procedures required for the operations commensurate to the risk posed by various activities; training plans with roles and responsibilities for its employees, temporary and contract workers; and monitoring and reporting framework, which will include required OHS monitoring for chemical exposure. The implementation will be supported by regular training and communication covering all employees and temporary workers.  

Third-party workers: The company employs temporary workers in warehouses and production facilities to manage peak and off-peak seasons dependent on the farming season and demand of crop protection products. The visited facility in Ibadan employed 27 temporary workers during the visit. This head count can go up to 600. Monthly projections are made on the number of temporary workers required and these projections are made available to an external labor agency which provides these third-party workers.

The Ibadan facility has a documented service agreement with this agency. The wages, benefits and insurance were noted to be in line with applicable labor requirements. However, this is not verified by the Group/facility. As per ESAP#5, and as part of the improvement to the HR policies and management system, the Group will put in place policies and procedures on contractor management to continuously supervise and review compliance with applicable legal and IFC PS2 requirements. The same will be implemented at all project facilities.

Also, as the construction contractors will be hired for construction of all proposed facilities, as per ESAP#8, the Group shall develop a documented EHS/labor manual for construction activities, to be responded by contractors during bidding process, as well as a monitoring procedure and checklist which will include: (i) clear EHS/labor and working conditions requirements (in line with IFC PSs and legal requirements) to be implemented at the site; (ii) clear roles and responsibilities of the Group and contractors’ personnel for implementation and regular monitoring on-site;  (iii) incentives and consequences of non-compliance for the contractors and their method of implementation;  (iv) requirements on labor law compliance including prevention of child labor; (v) labor camp guidelines in line with the IFC guidance note on workers’ accommodation; and (vi) specific processes on dust control and waste management.

The clauses related to the EHS/labor manual shall be included in the contracts signed with the contractors and the implementation shall be reviewed through regular documented site inspections and audits.

Energy use and air emissions: The main power source at the visited Ibadan facility is natural gas generators and national grid.  In addition, back-up diesel generator (DG) sets are provided in case of power cuts. Considering the current power scenario in the countries where project facilities are going to be established, DG sets are expected to be the main source of power at the proposed facilities as gas may not be available at all places. For example, the Kano facility uses DG sets only as the main source of power since no gas is available in the area.

Currently, the Ibadan facility is not conducting any ambient and point source air quality monitoring even though the EIA identified that the suspended particulate matter (SPM) in the project area were exceeding the applicable limits specified by FMEnv (250 mg/m3). As per ESAP#1. Ref. PS1 monitoring and review section above, regular air quality and stack emissions monitoring shall be conducted at the project facilities to ensure their compliance with applicable national and local standards and WBG EHS Guidelines. Summary of these reports will be shared as part of the Annual Monitoring Report submitted to IFC.

Specifically, for the Nigeria facility, the Group shall conduct ambient air quality monitoring to assess level of air quality currently and additional mitigation measures will need to be implemented for the existing facility and proposed expansion (ESAP#9). The road in the immediate vicinity of the Nigeria facility has significant dust levels (based on visual observations). Suitable dust suppression measures should be included in the mitigation measures.

Water supply and wastewater treatment: Water supply at the visited Ibadan facility is mainly from groundwater abstracted through on-site bore wells. The proposed facilities are also expected to mainly use groundwater. Water is suitably treated and stored for use in production process. The water consumption ranges from 80 m3 to 150 m3/day based on level of production. Water usage in Ghana will be in same range as it will be a formulation facility whereas the Uganda and Tanzania facilities will be packaging facilities and thus water consumption is expected to be significantly less.

The wastewater generated from the visited facility is collected in a tank and disposed of through a service provider. Given the wastewater is expected to be hazardous, an on-site wastewater treatment will need to be installed. The Group is in the process of obtaining proposals from external contractors for the design and installation of the wastewater treatment (WWT) plant at the Ibadan facility. Going forward, the Group will design a wastewater treatment plant to meet the national standards and WBG EHS Guidelines and share the design and technical specifications with IFC (ESAP#9). The plant will be installed within agreed timelines. Meanwhile, the company will ensure that all the wastewater generated is stored in the underground storage tank and not discharged/disposed. Once treatment starts, the quality of wastewater will be tested on a monthly basis as per the monitoring and reporting framework defined in the above PS1 section. Similar wastewater treatment plants will need to be designed and installed at all proposed facilities.

Hazardous materials management: The manufacturing operations of pesticides involves use of a number of hazardous chemicals, including active compounds (e.g. Glyphosate, Paraquat), liquid ammonia and ammonium bicarbonate. Also, diesel is stored on-site for the DG sets. There are no documented procedures which have been developed for the management of chemicals. As per ESAP#2 and as part of ESMS development as described in PS1 section above, the Group will need to develop specific procedures and work instructions for hazardous materials management including on storage, handling and use of the chemicals and response to any spills. Training on these procedures will be provided to all employees at all facilities and warehouses during worker’s induction session and on monthly basis thereafter.  

Solid and hazardous waste management: The main waste streams generated from the GACI Nigeria facility operations are plastic waste (sprayers and bottles), other plastic waste, paper waste, pallets, other domestic waste. Also, used oils is generated from the gas generators and DG sets. The facility has a waste management plan that provides the procedures for handling and disposal of hazardous and non-hazardous wastes. Wastes are segregated and collected by government-approved waste vendors. Waste plastics are recycled on-site in the crushing room where the plastic is crushed and reused as a raw material for plastic production. However, the waste plan does not specify storage and disposal practices for all waste streams. Also, it does not provide information on how the waste are finally disposed by the contractors. As per ESAP#2 and as part of ESMS development, the waste management plan shall be improved to identify all waste streams, identify storage, handling and disposal processes for all expected waste streams from the proposed facilities.  

Integrated pesticide management: The Group imports active ingredients from suppliers. In accordance with the Food and Agriculture Organization’s International Code of Conduct on the Distribution and Use of Pesticides, its products are well packaged and labelled in polyethylene terephthalate (PET) resin and high-density polyethylene (HDPE) bottles. Filling and packaging operations are automated and enclosed. Each product contains information and instructions about the product clearly written in English to reduce risks to users and minimize adverse effects on the environment. The Group also has technical and agronomy staff that undertake site visits, farm demonstrations, trainings and other extension services to aid in raising awareness of proper product utilization. However, it is not clear if the safety issues associated with the products are covered in these activities.

The Group has reviewed its 130 product portfolio to assess compliance with IFC PSs requirements of not purchasing, storing, using, manufacturing, or trading in products that fall in WHO Recommended Classification of Pesticides by Hazard Class Ia (extremely hazardous) or Ib (highly hazardous). Based on these reviews, some products classified under Ib were identified. The Group has already phased out these in their manufacturing/trading and sales.

The product portfolio has a number of products classified under Class II and III and thus as per ESAP#10, the Group shall prepare a comprehensive integrated pest management (IPM) plan, including specific awareness materials on safe storage, handling and usage of its products which can be part of the extension services activities and training for its employees and workers.

Greenhouse Gas (GHG) emissions: Once the project plans are fully finalized, the Group will estimate the GHG footprint of the project.

As mentioned above, the visited Ibadan facility is located in an industrial area. All proposed facilities within this proposed investment will also be located on designated industrial land. However, there can be communities next to the facilities or warehouses. For example, both the Ibadan facility and proposed site for Ghana facility have communities within few hundred meters. At the same time, taken into account that the operations are formulation and packaging operations, significant adverse impacts are not expected on the neighbouring communities, except in case of an emergencies (e.g. ammonia release or untreated wastewater discharge) or through traffic and security. The plan for handling such emergencies will need to be included in the emergency response plans as described under PS1 (ref. ESAP#6).

Traffic management: Trucks are used for transportation of finished products from the facilities to storage depots, distributors and warehouses. The facility in Nigeria has developed a traffic management plan which describes various safety measures. Each trip is monitored by the logistics and field officer who is responsible for checking the condition of drivers and trucks before every trip. Drug and alcohol tests are conducted for drivers quarterly and before every trip and a breath alcohol test is conducted for the drivers. All trucks are fitted with a tracking device, NAVLEB – a GPS tracking system which is tracked by a Group company. The traffic management plan does not include instructions on managing spills. As per ESAP#2, the same should be added in the plan. Also, required provisions for spill control shall be provided in the trucks.

Security management: Security at the Ibadan facility is provided by third-party security companies with both unarmed and armed security personnel provided by separate agencies. Armed security personnel are provided by SKYNET (who provide 5 policemen) and the Nigerian Army (3 soldiers). All security personnel are supervised by a facility’s Chief Security Officer directly employed by GACI Nigeria. The police escort the workers in case of late evening closure. Currently, there is no documented security policies, procedures and management plan or specific documented agreement on use of force. As per ESAP#11, the Group will develop Security Policies, Procedures, and Management Plan that assesses and addresses the risks posed by the security arrangements and includes a clear procedure in the due diligence, hiring and training process of security forces for all existing and proposed facilities. Also, contracts/agreements will be with third-party security companies in all countries of operation that provide armed security on hiring, rules of conduct, training, equipping, and monitoring and use of force.