IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Identification of E&S Risks and Impacts Assessment: The company identifies and manages E&S risks and impacts associated with its operations in line with applicable national standards and regulatory requirements. According to the national legislation in Fiji, the company is not required to undertake an Environmental Impact Assessment (EIA) study for the Raiwai site. If an EIA is required for the Veisari site, the company will comply with government agency requirements and obtain approvals as per the national regulation. The company has granted required approvals for both project sites certifying architectural drawings, valid titles, other preliminary designs such as structural and fire safety.

E&S Policy: The Group has developed its corporate health and safety policy and code of ethics applicable to all the group’s operations. The policy includes commitments relating to management of its health and safety at workplace, legal compliance, risk identification and provision of trainings, communication and engagement with workers and stakeholders.

E&S Management System and Program: The company has procedures related to E&S management including corporate health and safety manual, risk assessment and identification, safety management procedures, waste management procedures and audit mechanisms applicable to all the company’s operations. ESMS is generally in line with IFC Performance Standards (PS) requirements. The corporate policies/procedures are available on the company’s internal information system and accessible to all the employees and relevant documents shared with contractors.

Organizational Capacity and Competency: The company has a corporate OHS manager and OHS and HR committees oversee various E&S aspects. A dedicated OHS officer has been appointed to each project site, who is in charge of monitoring and controlling E&S risks and overseeing contractors. HR department is also responsible for the implementation of corporate E&S management in corporation with OHS officer on site and relevant facility operation managers.

Emergency Preparedness and Response: The company has emergency response procedures (ERP) for each facility’s operations, including responsibilities and duties defined for staff as well as provision of relevant trainings. It consists of a standard operating procedure in case of fire, natural disaster and tsunami. However, there is no ERP available for warehouse and facility operations under the project. As part of ESAP 1, the company will prepare ERP for warehouse and facility operations under the project.

Monitoring and Review: The company monitors all the facility operations and projects under construction in accordance with key performance indicators (KPIs) such as OHS and energy consumption. OHS monitoring reports are submitted to the corporate OHS committee on quarterly basis. However, there is no formal E&S monitoring and reporting procedures available. As part of ESAP 2, the company will prepare E&S monitoring and reporting procedures for facilities operations under the project including the provision of training and/or capacity building activities for staff to conduct the monitoring and evaluation of E&S risks and actions.

PS2: Labor and Working Conditions

As of August 2023, the Group has about 1800 employees, where around 1500 are permanent and 300 are part-time staffs.

Human Resources Policies and Procedures: THL has a set of corporate HR policies and procedures. The company’s HR documents include, obligations of the workers, leave guideline, health and safety, performance award mechanisms, worker grievance process, workplace sexual harassment etc. As part of ESAP 3, the company will update/develop its HR policies and procedures in line with IFC PS2 to; (i) include workers' freedom of association; (ii) define and exclude forced, or child labor; and (iii) retrenchment policy.

Working Conditions and Terms of Employment: All employees are provided with a contract. These contracts include the conditions for employment, termination of contract, remuneration, hours and place of work, holiday and leave, retirement policy, disciplinary action, grievance etc. According to the company’s management, all employees exceed the minimum age of 18 years. The company does not provide accommodations for the employees.

Workers’ Organization and Retrenchment: THL does not restrict workers from freedom of association. The company currently does not have a labor union among the workers. There is no collective bargaining agreement and no major labor disputes to date. There is no retrenchment occurred in the past three years nor it is not anticipated. As described in ESAP 3, the company will update its HR policy and procedure to include clear commitment for freedom of organization and a retrenchment policy.

Non-discrimination and Equal Opportunity: Non-discrimination and equal opportunity are described in Fiji’s Employment Relations Act. These policies include principles to protect individual rights with a zero-tolerance stance towards child/forced labor, unlawful discrimination and sexual harassment. Although THL implements a sexual harassment policy as part of their corporate HR policies. There is no clear reference to a policy on anti-discrimination and child/forced labor. Going forward, as described in ESAP 3, the company will update its employment policies and procedures to include a zero-tolerance approach for anti-discrimination and child/forced labor.

Worker Grievance Mechanism: The Group has a formal grievance mechanism and whistle blowing policy defining the process for receiving, assessing and resolving grievances for employees through face-to-face meeting, or by talking to HR department. The grievance mechanism is not accessible to contractors and there is no anonymous mechanism available. As described in ESAP 3, the company will update its worker grievance mechanism procedure to be applicable for its contractual workers as well as define the process for anonymous reporting.

Workers Engaged by Third Parties: The company employs third party agencies to perform activities including planned construction works of new facilities in Veisari. The company includes the required corporate OHS policies and requirements in the agreements with contractors. THL separately monitors all activities of the contractors during the construction period and also provides relevant trainings.

Occupational Health and Safety: The company has developed OHS policy and manual and implemented corporate OHS risk identification and management procedure. Company’s OHS manual includes risk identification and management, monitoring and reporting, workplace safety, provision of trainings and the safety audit. There is a standardized procedure in place for incident reporting. Regular OHS trainings provided to all the employees and additional fire safety trainings are conducted to each property and warehouse workers. Personal protective equipment (PPE) is confirmed to be provided to all warehouse staff at Raiwai site. All new employees are required to receive an induction training. There are no fatalities nor major incidents have been reported during the company’s operation over the past three years including contractors.

Supply Chain: The company currently does not have a formal E&S screening process or a documented supplier Code of Conduct. As part of ESAP 5 the company will establish a supplier Code of Conduct articulating its commitment to prohibit forced, or child labor and significant occupational health and safety risks; and a procedure to assess supply chain E&S risks for its primary suppliers. The company will monitor its primary supply chain on an ongoing basis in order to identify any significant changes in its supply chain and if new risks or incidents of child and/or forced labor are identified. If such risks are identified, the company will develop processes to prevent and remedy such practices including termination of contracts if risks are not adequately addressed in a reasonable period of time.

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency: Some of the resource efficiency initiatives implemented include installation of static wave generator and an onsite rainwater harvesting system. The roof of the warehouse in Raiwai is designed to install solar panel systems. Based on data from the company’s energy consumption from existing operations, total gross greenhouse gas (GHG) emissions from the project is estimated to be significantly less than 25.000 tons of carbon dioxide equivalent per annum.

Energy Supply and Air Emissions: Electricity is sourced from the national public grid for all operations under the project including warehouse and building facilities. No major air pollutant emission is expected from the project’s operations, except painting processes which will be implemented in an enclosed workstation operations with installation of air filtration and fire controlling system in line with local regulations. Small amount of diesel oil would be used by the backup generators but due to annual consumption, it is not expected to generate significant quantities of air emissions.

Water and Wastewater: For all the facilities operations under the project, water is supplied via public reticulation system. The water usage is estimated to be abound 1,500 to 2,500 m3 per year. There is no major process wastewater generated from the project operations, other than for cleaning purposes or auto service/maintenance process. Domestic wastewater from office and warehouse operations are discharged to the septic tanks installed at both project sites. Sludge from septic tank is collected by third party company and transported to the wastewater treatment plant. In addition, grease traps will be installed in the wastewater network to prevent the discharge of oil into the environment.

Waste and Hazardous Material Management: The company has waste management procedures to dispose waste including a system of appropriate handling, storage and disposal, which is consistent with the applicable national standards. All the waste is collected for disposal by an authorized third party agency specialized in each type of waste. Hazardous materials for facility operations under the project are limited to cleaning and painting chemicals, used oil and steel parts which are stored, segregated and disposed in line with the legal requirement by third party authorized companies. The material safety data sheet (MSDS) has prepared for the chemicals and oils used.

PS4: Community Health, Safety and Security

Life and Fire Safety Management: The company has approvals for the facilities under the project, certifying architectural drawings, including fire safety and water supply system. The company installs fire alarming system for the warehouse in Raiwai site connected to the National Fire Authority (NFA) including smoke/heat detectors, fire hose reel system with pumps and fire extinguishers, emergency exits etc. The warehouse is equipped with firewalls, as well as fire-proof roller shutters. NFA carries out monthly inspections to ensure the alarm system is functional.

Training for fire safety management has been implemented for its warehouse and headquarter office operations with support from the local fire authorities. There was a fire incident reported for the company’s operation in the past three years, where there was no fatalities or injuries at the case and the company implemented the mitigation measures, as recommended and confirmed by NFA.

Community safety management: The company does not own a transportation fleet and contracted to third-party transportation fleet operators. The company has a vehicle policy including safety driving and reporting procedure in case of accident. There have been no major traffic incidents reported in the past three years. A construction management plan developed for the Veisari project with consideration of traffic impact including material transportation to be limited to offpeak hours and public access to be restricted using separation boundaries. CCTV monitoring and supervision system through video cameras has installed in Raiwai project site observing the key areas.

Security Personnel: Some company facilities including the warehouse premises are protected using contracted unarmed security. There are no current plans to use armed security guards. The company regularly undertakes internal briefings and provides training for the security personnel.