This is a Category B project based on IFC’s 2012 Environmental and Social Sustainability Policy. The E&S risks and impacts of this proposed project are few, largely reversible and can be avoided or mitigated by adhering to Good International Industry Practices (GIIP). Key E&S risks and issues applicable for this investment are related to: (a) CMPG’s E&S policies, management systems, including screening systems for farmers and its distributors with respect to IFC PSs and capacity/competency of the EHS function; (b) assurance of fair, safe and healthy working conditions for employees and contractors with respect to IFC PS2 and legal requirements; (c) emissions, effluent and waste management; (d) road traffic safety and security management and (e) stakeholder engagement plan and community grievance mechanism.

E&S Policies. CMGP has adopted a Group-level sustainable development strategy which outlines its vision and objectives with respect to good governance, human resources, environmental performance and corporate social responsibility (CSR). At Company level, CMGP has adopted policies on Quality, Health, Safety and Environment (QHSE) for its different business lines and subsidiaries. These policies include CMPG’s commitment to environmental protection and pollution control and to guaranteeing safe working conditions in compliance with Morocco legal and regulatory requirements. The policies have been disclosed to the workforce and published on the Company website. Going forward, CMGP will upgrade its overarching E&S policies to commit the performance of all its manufacturing and distribution operations towards IFC Performance Standards (PSs) requirements (ESAP#1).

Identification of E&S Risks and Impacts. CMGP has implemented a QHSE risk assessment and internal audit procedure as part of its Integrated Management System (IMS) management systems and documented in a risk register. Major environmental and OHS risks identified in the risk register include storage, handling and transportation of equipment, disposal of hazardous waste (batteries, rags, paints pots, broken solar panels), road accidents involving distribution vehicle (contractor owned or CMGP’s own fleet). The register does not reflect community health risk.

A sector risk associated with this Project is linked to the commercialization of irrigation equipment. In December 2022 the Ministry of Agriculture acknowledged that exemptions of ‘water abstraction permits’ and ‘water drilling permits’ granted to applicants seeking government subsidies for irrigation projects under the Green Morocco Plan (2008-2018) resulted in uncontrolled water abstraction and further increased stress on limited water resources. It has thus decided to enforce back the compulsory permits, via the ‘water agency’, prior to applying for the government drip-irrigation subsidy for farming projects. However, there is a risk that, if not monitored properly, program beneficiary farmers or distributors may still operate unlicensed water wells or look to engage in drilling or abstracting water without the required permits. CMGP will (i) closely coordinate with BCP to ensure that farmer's applications involving new wells are submitted with the accompanying valid water abstraction permits delivered by the relevant water agency (Agence du Bassin Hydraulique - ‘ABH’); (ii) closely coordinate with BCP to ensure that distributors eligible under the program will only be those demonstrating partnership/compliance with the ABH through an MoU with CMGP (Code of Conduct) and independent verification ; (iii) update its risk register to reflect the community health risks associated with road safety, security management, and well drilling and water abstraction (ESAP#2).

E&S Management System and Programs. CMGP has implemented an Integrated Management System (‘IMS’) based on voluntary management standards for quality (ISO 9001), environment (ISO 14001) and occupational health and safety (ISO 45001). The IMS is structured around ISO certification requirements, with necessary components to implement a plan-do-check-act approach. It includes risk identification and analysis registers, management programs and detailed work instructions, key QHSE functions and personnel roles and competences, workforce training plan, emergency procedures and drills reports, monitoring records, audit and management review reports. To drive continuous improvement, CMGP defines annual objectives and key performance indicators (KPIs) and establishes “improvement cards” to document and track non-compliances and corrective actions for further reporting to management. As part of the system, CMGP has also identified QHSE aspects applicable to distributors, contractors and service providers, defining relevant mitigation measures and KPIs applicable to their various scopes of activities. The current KPIs however are mostly focused on quality management.

CMGP has developed a QHSE master plan which is informed by recommendations resulting from internal risk analysis, internal/external compliance audits or management reviews. The plan outlines preventive and corrective actions with responsibilities, scope of activities, budgets, KPIs, deadlines and escalation procedures when required. The plan is articulated in work instructions and operational procedures. Some of the key procedures reviewed include the regulatory compliance monitoring procedure which inventories periodic checks and inspections; the workplace OHS management and monitoring procedure; the QHSE training and awareness plan, the accident reporting and investigation procedure and the waste management procedure. Most of the environmental and OHS plans are commensurate with the E&S risks and impacts of CMGP’s operations. The Company will review its existing E&S management plans and implement additional Standard Operating Procedures (SOPs) to further align its IMS towards a PS-compliant ESMS, based on the updated risk assessment, including with a Security Management Plan and a Road Safety Management Plan. CMGP will ensure the plans cover all its facilities (i.e CMGP, SICDA plants and distribution branches) (ESAP#3).

E&S Organizational Capacity. The E&S management function falls under the responsibility of the Group-level director in charge of organization, transformation and CSR. This director is responsible for the IMS implementation and internal ISO audits. Besides subsidiaries’ EHS staff, this director supervises five (5) staffs, namely Group-level QHSE Manager, SICDA plants QHSE Manager, CSR Manager and two QHSE officers. This Director reports to the CEO and participates in Board meetings to advise on IMS implementation progress, including implementation of the “improvement” cards. The QHSE officers are tasked with daily OHS and environmental management and monitoring at the SICDA factories. The CSR manager oversees stakeholders’ engagement and community outreach programs. CMPG’s senior management approves the Group-level E&S strategy and policies.

The Human Resources (HR) function at Group-level is led by a HR Director. She is responsible for HR policies development and implementation, labour regulatory compliance and performance review, including labour agencies and contractors’ performance such as E&S incidents reporting and corrective actions. She oversees a team of 4 supervisors in charge of HR and administrative operations in SICDA factories and distribution branches. Workshop, branch managers, and distribution teams equally have E&S responsibilities defined in their roles as part of the IMS. Independent consultants are hired for ISO certification audits and environmental/OHS monitoring (emissions, effluents, workplace nuisance etc.) as per regulatory requirements. CMPG provides QHSE training to its workforce and distributors. The E&S and HR teams are considered competent and experienced to implement PS requirements, including proposed ESAP items.

Emergency Preparedness and Response. CMGP has documented an emergency response procedure which identifies potential accidents. The procedure describes emergency scenarios and specifies responsibilities, measures and necessary resources. Scenarios anticipated include fire, falls, electric shock, road accidents, toxic releases etc. The procedure also provides for new staff briefing and employee annual refresher training. It is further substantiated at all facilities by emergency signage, contact numbers and instructions displayed conspicuously. The factories and warehouses are equipped with adequate emergency systems, including fire hydrants, extinguishers, automatic sprinklers, smoke and heat detectors and alarm systems with dedicated water storage and emergency exits. Each facility has a trained emergency response team and performs routine drills. Emergency training including on fire response, first aid gestures and hazardous material based on material safety data sheets (MSDS) is organized with the support of external experts. The local fire police conduct periodic controls which CMGP’s facilities have passed successfully. Drill reports evaluate team preparedness level, coordination and engagement and formulate recommendations accordingly.

E&S Monitoring and Review. The IMS includes a protocol for QHSE and HR monitoring and reporting. The QHSE monitoring plan defines required parameters and monitoring frequencies for OHS/environmental inspections and mandatory regulatory controls related to different operations (e.g. factory, administration, stores, workshops). Monitoring parameters are defined based on KPIs approved in the annual objectives and tracked in the QHSE dashboard. KPIs include total number of accidents, lost-time injuries, water quality and consumption, energy use, solid waste, occupational noise, OHS training, number of controls performed and evaluation of service providers. Environmental and workplace OHS monitoring is performed by accredited organizations as per country regulations; emergency systems undergo periodic checks conducted by local fire police. Annual ISO certification audit of the IMS is carried out by external auditors. The QHSE team monitors corrective actions resulting from controls and documents non-conformities and opportunities for improvement in the “improvement cards” shared with senior management. A quarterly management review meeting is held to review the effectiveness of the IMS. The outcomes of this review are analyzed and prioritized for follow-up. CMGP publishes its E&S performance in its annual reports, available at https://cmgp-cas.com/nos-realisations/.

The Company has 704 direct workers of which 23% are women and 325 third party workers including outsourced casual laborers, and contractors’ staff providing security, transportation services, infrastructure installation and operational maintenance services to its customers. The Project will not result in an increase in the direct and contracted workforce.

HR Policies Procedures and Terms of Engagement. CMGP has documented HR policies and procedures based on local labour laws covering recruitment, working hours, wages and payment terms, performance review, leave and rest days, freedom of association, code of conduct, non-discrimination and equal opportunity, disciplinary measures, child and forced labour policies as well as occupational health and safety in the workplace. The policies and procedures broadly comply with PS 2 requirements, except for the issues raised below.

Direct staff are provided with contracts that outline the employment terms and per local law, as well as monthly payslips that outline the statutory deductions on pension and health insurance. As part of ESAP #1, the Company will develop HR record templates to facilitate standardized monitoring implementation and tracking labour related corrective actions and improvements in the ESMS.

Child and Forced Labour. The Company HR policies prohibit child and forced labour in its direct and contracted labour force. As part of ESAP #1, the Company will update its HR Procedures to integrate mechanisms for documenting, monitoring and reviewing non compliances with its policies for both direct and contracted workers.

Grievance Redress. The Company HR policies include an Ethics Code whose commitments include respect in the workplace and reporting of unacceptable workplace behavior while the whistle blower policy allows for reporting on unethical behavior in the workplace. The commission of workers delegates established under local law also presents workers complaints to management during periodic and ad-hoc meetings. For compliance with PS 2, the Company will develop a grievance policy and procedure to (i) allow workers, including contractors, to raise grievance with independent managers such as the HR office, (ii) provide mechanisms for raising and addressing anonymous complaints, (iii) provide templates for record keeping on hearings, investigations and resolution of complaints, (iv) update the incident investigation procedures and management responsibilities in the grievance redress procedures to facilitate survivor-centric mechanisms for dealing with general and sexual harassment as well as Gender Based Violence (GBV) related complaints and (v) provide sensitization and necessary training to staff and management on these adjustments to the grievance mechanism. The revisions in the grievance policies and procedures should not impede access to judicial or administrative remedies provided for in local law (ESAP#4).

Third-Party Workers and Supply Chain: The Company has mechanisms in place for monitoring wage payment by labour outsourcing companies. For compliance with PS 2, the Company will review and update the current HR recruitment procedures to incorporate objectives and KPIs for managing and monitoring contractors and labour outsourcing companies E&S performance in a manner that is consistent with PS 2 requirements especially on working terms and conditions, OHS and workers grievance redress mechanisms (ESAP#5).

Occupational Health and Safety. CMGP’s production halls were found to be adequately lit, ventilated, paved with clearly marked out movement lanes and signage. Factories have automated processes with well-maintained equipment and fire emergency systems and material properly stored off the ground. Agrochemicals in warehouses is strictly labelled and stored in separate cabinets with Material Safety Data Sheets (MSDS) available. The same OHS management practices are enforced at distributors sites. The QHSE team ensures that PPE including hearing protection, uniforms, masks or gloves are provided to workers according to their work stations and properly used. Refresher OHS training is regularly organized for the workforce, including for forklift operators and emergency personnel.

Distributors and contractors are bound per contract to train personnel on OHS risks and provide them with PPE. They also perform regular controls of the status of equipment used on the site for preventive maintenance, appoint suitably qualified personnel for key positions such as machine operators and electricians, and organize periodic occupational physician’s check-up for their personnel.

Workplace air quality and noise monitoring is conducted at production facilities in line with Moroccan legislation by accredited consultants. All values monitored were in compliance with local limits and WBG EHS Guidelines. Workers’ health is monitored annually by a labour physician. First aid boxes are available on work sites and their content is inspected monthly. There are also adequate change rooms and sanitary fittings. CMPG certifies its OHS management system as per ISO 45001 requirements and submits periodic OHS reports to the Ministry of Labor. This process includes an annual performance review. For year 2021, the Company reported 1 injury with an LTIFR of 4.37 for engineering and distribution activities, and 5 injuries with an LTIFR of 21.85 for manufacturing. This performance was significantly higher compared to the LTIFR for the synthetic rubber and plastics hoses and belting manufacturing industry of 1.2. CMPG will strengthen its OHS risk assessment and management plans (ref. ESAP#2). The review of accidents records demonstrates a good analysis of causes and adequate follow-up of corrective actions.

Resource use. CMGP uses water primarily for sanitation and for cooling systems in its manufacturing processes. Water is obtained from the municipal distribution system. Process water is recycled in a closed loop after cooling. Diesel is used for backup generators and transportation activities. Electricity is sourced from the grid. CMPG is implementing an electricity consumption reduction program with rolling-out of energy saving lights and computers (LED lamps and Energy Star-labelled computers). A 50 KWc PV solar system has been installed at its HQ, covering 50% of its overall electricity consumption. It is planning to implement the same at some of the branches.

CMGP monitors its monthly consumption of water, energy and fuel at each facility as part of its ISO 14000 system. However, it has not yet developed a documented resource efficiency strategy for its water usage. The Company will develop a resource efficiency strategy aligned with WBG EHS Guidelines, with measures to improve its water usage and efficiency (ESAP#6). As explained in the PS1 section above, CMGP will support the government’s effort to enforce back the compulsory ‘water abstraction permits’ and ‘water drilling permits’ for farmers beneficiaries of loans under the proposed project.

Pollution prevention

Liquid effluents and air emissions. CMGP’s wastewater effluents are minimal considering the nature of its manufacturing and distribution operations. Wastewater streams consist primarily of sanitary and cleaning water at each facility, including at SICDA plants. The effluent is discharged into municipal sewers with adequate capacity to meet local regulatory requirements. Quarterly effluent monitoring was performed by an accredited laboratory.

The main sources of air emissions are fugitive dust from raw material storage or blending, particulate matter (PM10, PM2.5). To mitigate the risk associated with such exposure, raw material is stored in tight silos. Machinery preventive maintenance is routinely performed to optimize efficiency and reduce airborne emissions and production halls are equipped with adequate aspiration systems. Ambient air quality monitoring was conducted by licensed consultants around the plants as part of the ISO 14001 audit process.  CMGP will update its environmental monitoring plan and ensure liquid effluents and ambient air emissions monitoring is regularly conducted as required by local regulation, and that monitored values are aligned with WBG EHS General Guidelines (ESAP#7).  

GHG emissions. CMGP’s annual GHG emissions amount to approximately 1,906 tons CO2e which is below the reporting threshold of 25,000 tons CO2e. Vehicle fuel consumption is the main contributor. By promoting drip irrigation and PV solar systems, the project will contribute to lower farmers emissions by replacing the subsidized butane gas used as a main source of energy.

Noise. CMGP does not conduct ambient noise monitoring for factories surrounding areas. Considering the location of SICDA I and II in industrial area, the Company considers that monitoring is not warranted. However, SICDA III factory is located close from human settlements. CMPG will develop and implement an ambient noise monitoring plan for SICDA III and take necessary steps to ensure monitored values are aligned with the WBG EHS General Guidelines (ESAP#8).

Solid and Hazardous Waste Management. The Company has documented a IMS’s waste management procedure. Solid and hazardous waste is segregated at source, then stored in dedicated areas for recycling or further disposal by licensed third parties, following Moroccan regulations. Process waste (piping material in PVC or High-Density Polyethylene (HDPE) is fully recycled in the process. The workforce is trained on sorting/disposal protocols. QHSE officers and area supervisors monitor compliance. Distributors and contractors are committed by terms of contracts to compliance with this procedure. Based on the management practices, CMPG is found to be aligned with WBG EHS requirements.

Hazardous Materials Management. There are limited hazardous materials required in the manufacturing process of irrigation equipment. Key hazardous products include lab reactants and lubricants. Operators exposed to chemicals are provided with suitable PPE and attend regular training on the safe handling of these chemicals, including emergency drills. Facilities are fitted with eye showers.

Road traffic safety. Most of CMGP’s facilities are located in industrial zones, except SICDA III factory and some warehouses. Distribution logistics equally require frequent vehicle movement which is ensured with a fleet of approximatively 50 vehicles. In addition, as noted under PS2 section, CMGP has appointed a transport contractor for head office workers. The Company has identified and assessed risks associated with the handling and transportation of equipment and products through its risk analysis process and developed an equipment handling procedure which does not address prevention of road accidents. The Company will develop and roll out a Road Safety Management Plan applicable to its own transport fleet and its transport contractors, addressing driver fitness, competence and training; journey management; speed limits; emergency response for road accidents; vehicle maintenance and safety standards (ESAP#9).

Security personnel. CMGP’s security at head office and at part of its facilities is handled by its own employees. At other locations, the Company has outsourced security services. None of the security agents is armed. Going forward, the Company will develop and implement a Security Management Plan consisting of a security risk assessment and a security training plan for security personnel as per IFC PS4 requirements (ESAP#10).

CMGP has developed an ISO 26000 compliant CSR system, achieving the ‘Engagé RSE label’ (CSR committed label) in 2020 as validated by the French Standards Organization (AFNOR). Its sustainability strategy commits the Company to maintain a strong relationship with the community. The CSR effort does not provide for a channel to disclose and disseminate Company information, community consultation and participation and a grievance mechanism as required under IFC PS1. Going forward, CMPG will develop and implement a Stakeholder Engagement Policy and Procedure following PS1 requirements and based on a stakeholder analysis and mapping exercise to ensure engagement and participation of the impacted communities. The Stakeholder Engagement Policy and Procedure will entail i) a description of key social and environmental risks and impacts of each facility; ii) identification and prioritization of stakeholders within the scope of the operations; iii) methods to provide information to and consult with each stakeholder group; iv) action plans to be updated annually describing specific stakeholder engagement activities to be conducted; v) timetable, resources, and responsibilities. The Stakeholder Engagement Policy and Procedure will also include a comprehensive grievance redress mechanism to: i) receive and register external communications and grievances from the public; ii) screen and assess the issues raised and determine how to address them; iii) provide, track, and document responses; iv) provide feedback to stakeholders on grievance mechanism results, and iv) monitoring implementation and effectiveness through KPIs; v) the mechanisms will provide measures for handling complaints around GBVH in a survivor centric manner and allow for anonymous complaints and ensure confidentiality when requested by the person who raised the concern. CMGP will ensure that staff responsible for the grievance redress mechanism are adequately trained on implementing the survivor centered approach to handling GBVH complaints. A stakeholder engagement plan and grievance management plan will be developed for each of the facilities and appropriately communicated to affected communities (ESAP#11)

-          Contact Person: Younes Al Abadan

-          Address: Parc Industriel Sapino 102 - 105 Nouaceur, 20 240, Casablanca

-          Email: y.alabadan@cmgp-cas.com

-          Phone: +212.5.22.49.56.10