The greenfield rice mill will be built on 8 acres industrial land within a 20 acres plot being developed by Meghna Group of Industries in Thengamara, Bogura. Currently the project land is owned by a Group entity – M/s Tasnim Condensed Milk Limited – from which the Company will take the land on lease agreement. Meghna Group has purchased these 20 acres on a willing seller – willing buyer basis between 2017 and 2020. The plot is secured with a boundary wall and is free from any encumbrances. There has been no physical and/or economic displacement of any previous land owner/users from the acquired lands. Consultations with local community confirms that the land transaction was voluntary in nature. No grievances or legal cases have been filed or pending against the land purchase. Meghna Group has acquired and started the land development since February 2017 after due regulatory approvals, including change in land use with regards to industrial development. Considering the voluntary nature of land transaction by Meghna Group and the project land will be leased by the company from one of the Meghna Group companies, it is assessed that there are no risks and impacts which must be managed in accordance with PS5: Land Acquisition and Involuntary Resettlement. As the company plans to source 50% of paddy requirement directly from farmers after 1-2 years of commissioning the project, the direct and indirect sourcing of rice from the farmers exposes the company operations to PS2/PS6 supply chain risks, such as Child Labor (CL), Forced Labor (FL), occupational safety issues due to pesticide use and risks of conversion of natural/critical habitats. Project must be managed in compliance to para 27-29 of PS 2 and para 30 of PS6 requirements. There are no identified impacts on Indigenous People (IPs), or cultural property in and around the project site and hence it is assessed that no risks and impacts are anticipated for the project which must be managed in accordance with: PS7: Indigenous Peoples and PS8: Cultural Heritage.

This is a Category B project as per IFC’s 2012 Policy on Environmental and Social sustainability. The key E&S risks and impacts of this proposed investment include: (i) Company’s capacity/competency to implement an integrated E&S management system at the greenfield rice mill, covering the construction and operational phase, in line with PS1 requirements and Bangladesh regulations; (ii) assurance of fair, safe, and healthy labor working conditions including that related to occupational health and safety (OHS) and life & fire safety risks in compliance to local regulations and PS2 requirements; (iii) resource efficiency, greenhouse gases, pollution prevention and cumulative impacts, hazardous materials and waste management in compliance with PS3 requirements and applicable WBG EHS Guidelines; (iv) community health and safety risks, including food safety management systems, emergency preparedness and response and risks due to transport fleet operations; (v) management of supply chain risks in line with PS2/PS6 supply chain requirements; (vi) stakeholder engagement and community grievance mechanism, especially in the paddy procurement process.

EHS Policies and Management Systems. Meghna Group of Industries (MGI) has formulated and implemented Group level and individual facility level E&S Management System (ESMS) that are certified to ISO 14001 and ISO 45001 standards. For the greenfield facility being developed under the project, the Company is in the process of formulating and instituting an ESMS. The ESMS for the proposed rice mill will be established as soon as the plant becomes operational in June 2023.

As part of IFC’s investment, the Company agrees to formulate, institute, and maintain an ESMS appropriate to the nature and scale of the project and commensurate with the level of its E&S risks and impacts (ESAP#1). The ESMS will incorporate the following elements: (i) policy; (ii) identification of risks and impacts; (iii) documented E&S operational manuals, procedures, practices, and plans; (iv) organizational capacity and competency; (v) emergency preparedness and response, including life & fire safety management plan; (vi) stakeholder engagement and community grievance mechanism; and (vii) monitoring and review.

At the Group level, MGI has promulgated an EHS Policy in January 2022 that defines its E&S commitments and principles guiding the Group companies to achieve sound E&S performance. Under this EHS policy, Meghna Group commits to conduct its operations in compliance with all applicable laws, regulations, licenses, codes of practice, industry standards and more importantly aligned to IFC Performance Standards. MGI further commits to minimize its environmental footprint, promote a safe and healthy work environment, seek continuous and sustainable improvement of its EHS performance, conduct safety and environmental capacity building, avoid adverse impacts on neighbourhood communities, actively involve and engage all stakeholders, and aim & achieve zero fatalities in its operations. Going forward, the Company will formulate project specific EHS policy based on Group EHS Policy (ESAP#1).

EHS Risk Assessment. As per Bangladesh's Environment Conservation Rules (1997), the proposed project will be categorized as “Orange B” requiring site clearance and environmental clearance (EC) from the Department of Environment (DOE). The EC will be issued by DOE based on an independent Initial Environment Examination (IEE) study to be commissioned by the Company before December 2022. The scope of the IEE study will be determined by DOE and the Company has applied in this regard. The Company will undertake an independent IEE of the Project aligned to the scope approved by DOE and expanded to integrate IFC PS requirements (ESAP#2). Upon the completion of the IFC-compliant IEE/Environment and social impact assessment (ESIA) study, the Company agrees to implement the risk mitigation and management plan arising out of such IEE study through the project life cycle. Capital expenditure (CAPEX) and operational expenditure (OPEX) will be confirmed to ensure timely implementation. This IEE study will include the potential for cumulative risks and impacts and focus on the following key E&S issues: (i) air emissions and ambient airshed quality; (ii) ambient noise levels; (iii) water resource availability and wastewater discharge; (iv) traffic and transportation; (v) greenhouse gas (GHG) emissions; (vi) waste disposal; (vii) child labor and biodiversity related supply chain risks in paddy crop cultivation; (viii) land acquisition impacts, if any on informal land users; (ix) increased labor workforce and impacts on local community due to migration of workforce including gender-specific impacts and analysis in the project's social impact assessment; (x) quantitative risk assessment (QRA) of hexane storage; and (xi) HAZOP study of boiler operations and other hazardous processes.

Supply Chain Risks and Impacts: As stated earlier, the direct and indirect sourcing of paddy from farmers and open market exposes the company operations to PS2/PS6 supply chain risks which are discussed under respective PS2 and PS6 sections below.

EHS Organizational Capacity/Competency. The E&S organisation has been instituted at two levels - at Meghna Group and at individual facilities level operated by Group’ companies. At the Group level, a Group Director has been assigned the responsibility to manage E&S aspects and report to the Management Board. This Director is assisted by an EHS team headed by a General Manager level staff. At facility level, the E&S organisation is instituted with appropriate technical resources. There are about 23 E&S staff in the multiple facilities of the Meghna Group. Going forward, the Company agrees to formulate and institute an appropriately sized E&S organisation at the project facility and for its raw paddy sourcing operations (ESAP#3). The Company will recruit and appoint a facility EHS head and a Fire Safety officer with adequate qualification and experience. The E&S organisation will be provided with budgetary and manpower resources as required. The roles and responsibilities of each staff of the facility level E&S organisation will be defined and documented. The company will institute an appropriately sized paddy sourcing team that will be periodically trained on sustainability and social issues (such as deforestation, stakeholder engagement, grievance redressal, child/forced labor risks) in paddy cultivation and capable of implementing ESAP#7 requirements through the project life cycle.

Emergency Preparedness and Response: The facility buildings and 400 bedded dormitory building (for housing operational phase workers) will be designed, constructed, and operated & maintained as per Bangladesh factory regulations, local fire codes and good international industry practices, including IFC’s Workers Accommodation Guidelines. Going forward, the Company will engage a suitably qualified professional to prepare a Life and Fire Safety (L&FS) Master Plan for the project and certify that the design meets the requirements of local fire codes & regulations and in accordance with an internationally accepted life and fire safety (L&FS) standard, such as US NFPA (ESAP#4). Before commissioning the project facility operations, the qualified professional will conduct a review of built life and fire safety systems & infrastructure and certify that construction of these systems has been carried out in accordance with the accepted design. The L&FS infrastructure and management systems through the project life cycle will be managed by a qualified and experienced Fire Safety Officer to be appointed by the Company before commissioning the project (ref. ESAP#3).

Monitoring and Review: The company would formulate and institute a monitoring and review mechanism as part of the ESMS under development (ESAP#1). Facility E&S organization would monitor and periodically report on the EHS plans covering construction and operational phase of the project, including key performance indicators (KPIs), resource efficiency, GHG emissions, incident and accident statistics, training delivery, ambient environmental quality and pollution monitoring, community grievances and regulatory compliance status allowing senior management to assess the project’s overall EHS compliance and performance. The monitoring mechanism would also have provisions for internal and external audits. As in practice with other Meghna Group companies, these EHS reports and audit findings would be reviewed by the MGI Board at regular intervals.

The project will generate about 45,000 mandays of work during its construction phase and will employ about 311 staff and workers during its operational phase. The company plans to employ all required staff and workers on permanent payrolls, except for paddy unloading operations during the paddy procurement season, wherein short-term temporary labour would be engaged.

Human Resource Policies and Procedures: At Group level, Meghna Group has instituted Human Resource Policy and Manual of Procedures that are in line with Bangladesh Labor Act 2006, Labour Rules 2015 and broadly aligned to IFC PS2 requirements, specifically on aspects such as: working conditions, employment terms & conditions, non-discrimination and equal opportunity, protection of workforce, workers representative committee, employee's code of conduct and discipline measurement, and a three-tiered workers grievances & resolution procedures. Meghna Group has formulated an anti-harassment policy covering sexual harassment as well. The company reports no past incidences of sexual harassment at the Group level. There has been no retrenchment of staff or workers at Meghna Group in the last 3 years through the COVID pandemic. The rice mill will provide worker’s accommodation facilities on-site for which a 6 storied structure has been proposed that can accommodate 400 operational phase workers.

As the greenfield project facility is in early construction phase now, the Company is in the process of formulating a project specific HR policies and Manual of Procedures based on the Meghna Group HR management framework. Going forward, the company agrees to formulate and share with IFC the draft HR policy and manual of procedures before finalising and adopting the same for implementation (ESAP#5) and commits to cover local labor regulatory and PS2 requirements in the project HR documents. Bangladesh labor regulations require business organization to cover aspects such as: worker welfare fund, bonus, participation committee, and service rules approval. IFC PS2 requirements includes working conditions and terms of employment; collective bargaining and freedom of association; non-discrimination and equal opportunity policies and recurrent workers awareness training on prevention of sexual harassment and gender-based violence (GBV) including setting up internal complaints committee as per Bangladesh Supreme Court Order 2009; retrenchment; grievance mechanism; protecting the workforce; workers engaged by 3rd parties and supply chain. Under equal opportunity policies, the company commits to train all recruitment personnel on how to implement the non-discrimination or equal opportunity policy during the recruitment process and conduct a gender smart safety audit. The employee grievance mechanism will cover third party workers and have provisions to receive confidential and anonymous complaints and handle them in a survivor centric way. The HR process will provide for specialized training to grievance focal points, investigators of sexual harassment allegations and line managers on how to respond to incidents of sexual harassment.

The company agrees to integrate IFC review inputs on the final version of HR policy and procedures to ensure compliance with IFC PS 2 requirements. The company commits to prepare the service manual and get it ratified/approved by the regulatory authorities before commissioning the plant. Further, the company commits to commission an independent third-party labor audit to verify effective implementation of the HR management systems within two years of commissioning the plant and implement the audit findings in a time bound manner.

Worker’s Organization: Meghna Group does not prohibit or discourage the formation of workers' organizations or collective bargaining of workers. However, none of the Group companies have yet any workers union. Instead, workers management committee are functional. The committee comprises of Factory Head/Chief Operating Officer and the representative management level staff members and does not include any representative from workers. Going forward, the company agrees to formulate specific policy and procedures with regards to workers organisation in compliance to labor law which requires setting up participation committee through direct involvement of the workers working in that establishment where no trade union exists and IFC PS2 requirements (ESAP#5).

Protecting the Workforce: In compliance to Bangladesh Labour Rules 2015, Meghna Group does not allow child (less than 18 years of age), forced or bonded labour practices in its operations and third-party contractors engaged at its facilities. The Group HR Manual of Procedures include verification of the workers' age using government documents.

Occupational health and safety: As per project design, the rice milling operation is fully automated with minimal manual interventions required. Appropriate fugitive dust pollution control devices (hoppers and bag filters) at all dust generating points in the production line will be installed to prevent dust generation and worker exposure. As part of ESAP#1 (ref. PS1 section above), the company agrees to formulate and institute an occupational health and safety management systems, including workplace environmental quality monitoring as part of the facility ESMS, and in compliance to IFC PS2 requirements.

IFC’s onsite appraisal assessment of ongoing construction work indicates average E&S performance by contractors despite contract agreement issued to the construction contractors with specific EHS provisions. Going forward, the company commits to strengthen the enforcement of EHS management and construction contractor oversight during the ongoing construction phase by: (i) strengthening the onsite project construction team's E&S capacity with company E&S staff or EHS consultant; (ii) enforcing compliance to Meghna Group's construction stage EHS plan requirements, local labor and safety regulations; (iii) instituting monthly internal or external auditing of ongoing construction works of different contractors and ensuring compliance to audit findings in a urgent manner; (iv) reporting on EHS accidents and incidents; (v) training and awareness building among migrant contractor workers on local community relations, GBV risks and avoiding conflicts (vi) maintaining construction workers accommodation, if any, as per IFC’s Workers Accommodation Guidelines and (vii) monthly senior management review and monitoring of construction contractors E&S performance. Senior management meetings will also decide on fines/penalties to be levied on the contractors for continued poor E&S performance based on sustained monitoring (ESAP#6).

Covid-19 Management: MGI had instituted a Covid-19 prevention and mitigation strategies in place across all its operations and factories. Some of the measures to address Covid-19 related challenges include flexibility to work from home, isolation centres for infected workers; financial and hospital support for infected staff; Covid task force and 24x7 helpdesk that provided information to workers. The company reports that about 400 employees were infected and 3 fatalities at Meghna Group level during COVID pandemic. There has been no reduction or cut in salaries or wages. Every staff and worker of the Group has been vaccinated.

Supply Chain: Project’s key supply chain operation is the periodical paddy procurement activity planned in the Northern regions of Bangladesh. As stated earlier, direct and indirect sourcing of rice paddy from the farmers, exposes company operations to high contextual risks such as CL, FL and safety issues due to pesticide use. To assess the project level risks, IFC appraised the labor risk using screening tools such as GMAP, US Department of Labor (DOL) reports and US Bureau of International Labor Affairs (ILAB) database. Rice is not a commodity listed by the US DOL as having been produced by forced labor in Bangladesh. But GMAP indicates high risk of harmful CL/FL, significant occupational safety risks and biodiversity loss due to the conversion of natural/critical habitats in paddy supply chain in Bangladesh. IFCs appraisal limited assessment based on direct stakeholder consultations held at Bogura in June 2022 with paddy farmers (small and marginal), community heads and non-government organization working with farmers in the region did not indicate CL/FL practices prevalent in paddy cultivation in the Northern Bangladesh region.

To mitigate the contextual risks, Company will review existing paddy procurement policy and institute supply chain management systems to address specific E&S risk aspects such as addressing child and forced labor, OHS, and biodiversity related supply chain risks as outlined in IFC PS2/PS6 (ESAP#7). The company will formulate and institute a specific paddy supplier code of conduct and will implement a paddy farmers education and training program that will be run through the project life cycle with appropriate budget allocation and manpower resources. Paddy supplier code of conduct will clearly lay down company’s policies, vision & mission statements, procurement procedures specifying compliance to labor and safety practices, and grievance mechanism. One of the key supplier policies will include prohibition of child labor and forced labor in the supply chain. Company will develop appropriate supplier management procedures and monitoring program to enforce its CL/FL policy implementation to all suppliers but particularly among the smallholder direct suppliers which represent the greatest risk. The design and development of farmers education and training program will focus on: (i) prevention of harmful child labor, forced and bonded labor practices in farming activities especially focused on school going children of less than 18 years of age; (ii) E&S risks and impacts due to indiscriminate use of pesticides including awareness about avoiding the prohibited WHO Class Ia/Ib pesticide products; (iii) training on appropriate use of pesticides, including provisions of Personal Protective Equipment’s (PPE); and (iv) E&S risks and impacts due to biodiversity loss due to the significant conversion of natural/critical habitats into rice fields. The procurement policy will be updated to integrate risk aspects in paddy supply chain such as: prevention of sexual harassment, gender-based violence and harassment (GBVH), farmer grievances and farmer consultations.

Resource Efficiency: The rice mill will consume resources, such as electricity, water and steam to process raw paddy. The company is setting up a 55 tons per hour (TPH) co-generation steam boiler to generate steam that would drive a 6 MW steam turbine to generate electricity and meet process steam demand. This captive electricity generation would fully meet the production process's electrical energy requirement of around 3.5 MWH. The lighting and maintenance electrical load would be sourced from the public utility grid which will also be used as a back-up power source. The project steam demand will be met through the 55TPH co-generation boiler which will be 100% rice husk fired using the waste material generated from rice mill operations. The excess spent steam from the boiler and excess electricity generated from the turbine would be provided to Meghna Feeds Limited - a sister company adjoining facility in the complex. The project design provides for installation of 26% more energy efficient rice mill process machineries when compared with conventional machineries and is designed to run under programmable logical controller (PLC) system that would improve electric energy conservation.

Water Consumption: Water demand for rice processing and steam generation is estimated at 300 KLD and will be sourced through permitted boreholes. A borehole structure to a depth of 120 feet will be installed with a pumping capacity of 120 m³/hr. The groundwater will be treated in a 2-stage water treatment plant comprising of demineralisation and reverse osmosis (RO) unit (only for boiler feed water). As indicated above, the company will carry out a detailed hydrological assessment of the area to assess the risks and impacts on groundwater resources as part of the IEE study (ref. ESAP#2) and formulate & implement water resource management plan for the rice mill. A 420 KLD capacity effluent treatment plant (ETP) with a treatment scheme that enables 75% reuse of treated water in the production process has been proposed. Balance treated wastewater will be discharged in the surface water pond located within the complex owned by Meghna Group after taking due permits for the discharge. Wastewater generation is expected from parboiling process as spent liquid, acid oil from the rice bran oil process and domestic wastewater from 400 bedded worker dormitory building. All the wastewater streams will be treated together in the ETP. As part of ESAP#1 indicated above, the company agrees to integrate a comprehensive water and wastewater quality management and monitoring programs, as part of the facility ESMS, that would comply with the permit terms and conditions, Bangladesh Department of Environment Standards for inland surface water discharges, and WBG General EHS guidelines.

GHG Emissions: The project's direct and indirect GHG emissions are expected from rice husk fired boiler, fossil fuel use in transport fleets, electricity use from grid and other sources (fire extinguishers, refrigerants, ETP operations, fossil fuel, cooking gas etc). Total GHG emissions (Scope 1 and Scope 2) is estimated to cross the threshold level of 25,000 tCO2e/year specified in Para 8 of IFC PS 3 Standards during the operational phase of the project. As part of ESAP#1, the company agrees to integrate as part of the facility ESMS: i) GHG emission monitoring and reporting systems in accordance with internationally recognized methodologies and good practice; and ii) institute a resource conservation program (RCP) that includes formulation of resource conservation related key performance indicators (KPIs) or targets that are general and site-specific covering energy, water and raw material inputs. Wherever appropriate global, national benchmarking data are available, the company will make a comparison to establish the relative levels of efficiency.

Pollution prevention: Main air emission sources are boiler operations, transport fleet and fugitive dust in process areas. Boiler stack is designed with electrostatic precipitator and the process areas will have bag filters with hoppers & extraction systems at all dust generating points (such as receiving hopper, cleaning, de-husking, polishing process areas). All material handling and process equipment will be enclosed to reduce noise levels at source. Based on the workplace’ environmental quality monitoring program data and as part of OHS management systems discussed under PS2, the company will design and implement an appropriate personal protection equipment (PPE) regime covering the entire project operations.  The company agrees to integrate a comprehensive ambient and workplace environmental quality monitoring program as part of the facility ESMS (ref. ESAP#1) that would comply with the permit Terms and Conditions, local regulations and WBG EHS guidelines.

Solid and Hazardous Wastes: The main non-hazardous waste streams is fly ash and bottom ash from the boiler operations; spent cleaning agent from rice bran oil process; packaging material and by-products (such as rice husk, broken rice, oil cakes). The fly ash and bottom ash will be completely reused at Group companies, such as Unique Cement Industries Limited and Sonargaon Green Concrete Auto Bricks and Blocks Limited respectively. Rice husk generated will be used as feedstock in biomass-boiler operations. The rice bran will be processed in rice bran oil plant. The bleaching earth used for refining the rice bran would be disposed of inside the premises in low lying areas for earth filling. Broken rice and oil cakes would be consumed at Meghna Feeds Limited and excess will be sold to poultry farms. Hazardous waste streams, such as used oil will be limited and will be disposed through a licensed service provider at permit conditions. Considering the contextual risk of plastic pollution caused by packaging materials, jute bag will be used as packing materials for 50 Kg product bags which is expected around 70% of total product. For the smaller sized product bags, Polypropylene (PP) woven bag will be used as packing material which is recycled in Bangladesh. The company agrees to integrate a comprehensive waste management plan and monitoring program, as part of the facility ESMS, that would comply the permit conditions, local regulations and WBG EHS guidelines (ref. ESAP#1).

Hazardous materials management: There are no major hazardous material handling in the project operations, except for storage and handling of diesel, natural gas cylinders and hexane. As hexane has a low flashpoint, its storage and handling will be subjected to quantitative risk assessment (QRA) studies (ref. ESAP#2). As part of ESAP#1, the company agrees to integrate a comprehensive hazardous materials management plan, as part of the facility ESMS, that would comply the permit conditions, local regulations and WBG General EHS guidelines.

Pesticide Use and Management: The company has no plans to get directly or indirectly involved into paddy cultivation. The Company will institute a paddy farmers education and training program in which the critical focus will be on educating and training the farmers on E&S risks and impacts due to indiscriminate use of pesticides and sustained training of farmers on appropriate use of pesticides including awareness about avoiding the prohibited WHO Class Ia/Ib pesticide products (ref. ESAP#7). Within the facility, the company agrees to integrate a pest control management plan, as part of the facility ESMS, that would comply the local regulations and PS3 requirements.

Infrastructure and hazardous materials management: The nearest neighbourhood community at Karanpur having a population of around 500 people is located at about 300m distance south of the proposed rice mill. No risks or impacts are envisaged to this neighbourhood community due to any unforeseen catastrophic incident or accident (e.g. fire, inflammable material storage tank explosion, hazardous chemical leaks). The company will undertake QRA, HAZON/HAZOP studies to determine the risks before commissioning the plant (ref. ESAP#2). The company will also conduct periodic ambient environmental quality monitoring by independent third party as per local regulation requirements. The company agrees to integrate an infrastructure and equipment safety related testing program, as part of the facility ESMS, that would comply with the local factory regulations and WBG General EHS Guidelines (ref. ESAP#1).

Traffic and transport network: The project site is located on the N515 branching national highway (locally known as Dhanghara Road) connecting to N5 National highway at about 2km distance. The N5 is the key arterial national highway connecting Dhaka and the town of Banglabandha on the Bangladesh-India border. The company transport fleet is estimated to have around 80 vehicles to bring in rice paddy and distribute finished product. The rice mill plant is designed with a 120 truck parking facility to avoid traffic congestion. The company agrees to integrate a transport fleet management and monitoring plan, as part of the facility ESMS, that would comply the local transport regulations and WBG General EHS Guidelines (ref. ESAP#1). Transport management plan will focus on road safety, periodic verification of vehicle roadworthiness, driver training, emergency management, and GBVH aspects.

Community health and safety: The company will assess as part of IEE (ref ESAP#2) the risks of gender-based violence in nearby communities and supply chains; assess the risks of gender-based violence perpetrated by workers and/or contractors who will be living or staying in local communities and truck drivers. As part of HR documentation under development (ref. ESAP#5), the company commits to formulate and implement a Code of Conduct for employees and contractors that prohibits gender-based violence with a recurrent training program to all employees and contractors on gender-based violence code of conduct.

Food Safety Management System: The company is committed to establish a Hazard Analysis Critical Control Point (HACCP) based Food Safety Management Systems as per ISO 22000 Standards and receive HACCP /ISO certifications well ahead of commissioning the plant. In addition, the company would address risk mitigation measures to control indiscriminate use of pesticides in paddy cultivation as part of Food Safety Management System. Food safety management systems will be designed to control the procurement process and be based on preventive principles and concepts. Going forward, the company will institute Food Safety Management Systems as per ISO 22000 Standards along with EHS management systems discussed under PS1 (ESAP#8).

Security Forces. The company will deploy a security team comprising fully of on-roll security staff. Meghna Group operations have not reported any security-worker-community conflict in the past. As part of ESAP#1, the company agrees to integrate a security management plan as part of the facility ESMS that would comply the local security related regulations and Voluntary Principles on Security and Human Rights.

Supply Chain Risks: A review of deforestation rates within the rice growing areas within Bangladesh that would supply rice to the mill did not identify any risks. Information shown from the mapping tool of Global Forest Watch indicates that the proposed paddy sourcing districts of Dinajpur, Naogaon, Natore, Rangpur, Bagura, Rajshahi and Shirajgong are located in north-western Bangladesh north of the confluence of the Brahmaputra and the Ganges/Padma River. All of the districts are in the floodplains of these rivers with no forest loss identified between 2001 and 2019. As such, the risk of conversion of natural and critical habitats in this landscape is very low. However, in order to ensure that ongoing supply of rice complies with PS6, the Company will be required to prepare a policy and systems to track and verify the supply chain [ESAP#7]. Going forward, the Company will prepare a policy to commit to the requirements of PS6 to manage risks to natural and critical habitats within their supply chain to the satisfaction of the IFC. The policy is to require that all suppliers and brokers of materials are to adopt the policies of the Company. A system of tracking and verification of the supply chain is also to be established.  The tracking and verification system is also to be adopted by suppliers and brokers. Verification of the supply chain is to be undertaken on an annual basis and reported within the supply chain to the Company and to the IFC. The company will explore the feasibility of joining international sustainable certification programs such as Sustainable Rice Platform (https://www.sustainablerice.org/).

As per prevailing regulatory requirement, the Company and Bangladesh Department of Environment (DOE) will disclose the IFC-compliant IEE study report on their respective websites (ref. ESAP#2). The IEE study process includes stakeholder consultation process to be conducted by the IEE consultant and is a key process document to be submitted to DOE as part of IEE Report before seeking environmental clearance. Meghna Group's operational facilities have developed stakeholder engagement plan (SEP) and community grievance mechanism (CGM) to address neighbourhood community grievances, complaints, concerns against the facility operations. Going forward, the company commits to integrate a SEP and CGM, as part of the facility ESMS (ref. ESAP#1). The SEP under development for the project will review and update MGIs existing corporate stakeholder engagement framework, consistent with the requirements of PS1 to identify project affected communities and establish an engagement process throughout the life of the project from construction through operations. The updated framework will outline: (i) the criteria and mechanisms of stakeholder identification (mapping) and analysis, (ii) methods of consultation and engagement with communities, and (iii) methods and frequency of reporting on the risks and impacts derived from project construction and operations. The company will include community and local groups that advocate for the rights of women, children, and adolescents as part of the community engagement strategy. The project will then use the framework to develop and implement a SEP.

The company will update MGI external grievance mechanism and implement it through the updated stakeholder engagement framework, tailoring to the type of affected communities. The community grievance mechanism will (i) specify and allow additional channels of grievance communication (e.g., suggestion boxes, company contact person details, regular meetings), (ii) disseminate communication channels to communities, (iii) receive, register, and handle all inquiries and grievances in timely manner, (vi) provide a resolution and feedback to communities, and (v) analyze its trends and take corrective actions, including key performance indicators (KPIs) to measure its effectiveness.