This is Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012). Based on the information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible, and readily addressed through existing mitigation measures and good international industry practices (GIIP). The key E&S risks associated with this project include (i) CCBPL’s E&S management system and staffing to assess and manage E&S risks aligned with IFC PSs and World Bank Group (WBG) General and Sector specific Environmental, Health and Safety (EHS) Guidelines Food and Beverages Processing; Water and Sanitation; (ii) food safety management system; (iii) resource emissions, wastewater and water (plastic); (iv) workplace and ambient noise and labor and occupational health  and safety programs; (v) third party workers/supply chain child/forced laor and significant occupational health and safety risks; (vi) community safety risks from the transportation fleet and traffic management; (vii) community grievance mechanism.

 E&S Policy: CCI adopted in 2015 a corporate level EHS policy statement identifying three ESG priority areas, namely energy and water management, and sustainable packaging. CCI’s corporate EHS policy outlines the scope of application covering corporate and subsidiary’ employees, contractors, subcontractors, sales, and distribution agencies, and third parties involved in CCI operations. CCI applies IFC PSs requirement as EHS standards which are more stringent than applicable national legal and regulatory requirements. This is in line with CCI’s 12 golden safety rules on safety, emergency procedures, traffic safety, job safety, use of Personal Protective Equipment (PPE), risk assessment and contractor management and roles and responsibilities. The policy statement is available on the company’s website https://cci.com.tr/portals/3/CCI_Environment_Policy.pdf.

CCBPL implements a corporate EHS policy across all its operations in Pakistan. During this appraisal, CCBPL provided relevant NOCs (No Objection Certificates) confirming clearance of environmental impact assessments (EIAs) for each facility, including KPGF plant. CCBPL also received approvals issued by Khyber Pakhtukhua Environment Project Agency in line with “Pakistan Environment Protection Act (PEPA) 1997” covering all its operational plants, including the expansion of the KPGF plant. Under ESAP#37922, CCBPL streamlined its internal EHS monitoring and reporting system in compliance with regulatory requirements of KPK (Khyber Pakhtukhua) EPA (Environmental Protection Agency) for KPGF plant and submitted environmental monitoring reports (2021) including ambient air, emissions, wastewater and noise monitoring. CCBPL shall continue to submit its internal monitoring and reporting for all its operations in compliance with regulatory requirements of the respective Environmental Protection Agencies (EPAs), IFC PSs and applicable and relevant sections of the WBG EHS Guidelines (ESAP#1).

In 2010 CCI adopted the “Coca-Cola Operating Requirements System” (KORE), a management system designed by TCCC to integrate quality, environmental, food safety and OHS as key operational requirements. The KORE system supports the global quality function to perform risk determination, including quality, environmental, food safety and workplace safety audits across all its manufacturing facilities. As per ESAP#37922, CCBPL developed and implemented a time bound action plan to eliminate/minimize the risks related to the audit findings and risk assessments to all facilities in Pakistan. For KPGF facility, as part of ongoing EHS monitoring, CCBPL will develop and implement time-bound action plans to eliminate/minimize specific OHSE risks identified as a result of regular EHS risk analyses and compliance audits for all production facilities in Pakistan operations (ESAP#2).

Identification of E&S Risks & Impacts: CCI integrates E&S risk assessments for all new investments through the assignment of external EHS consultants. As per #37922, CCBPL was required to further integrate social risks in the E&S assessment process and broaden the scope of application to all Pakistan operations which also included KPGF. This agreed upon ESAP item has been satisfactorily implemented by CCBPL. E&S risks have been integrated in Construction NOC for Environment.  

Water management is a key focus area for the TCCC given its significance as a resource for production. All CCBPL bottling plants are required to conduct a local source vulnerability assessment (SVA) and develop a source water protection plan to mitigate water related risks. With this assessment, potential impacts of water usage and related wastewater discharge as well as vulnerabilities to community water sources are identified. As of 31 December 2014, all CCI plants had completed their SVA studies in all countries of operations. The assessment is conducted every five years, and an update of SVA studies was conducted during 2019. The KPGF bottling facility engaged a third-party firm to carry out SVA in 2014. The expert report confirmed no declining trend, however ground water depletion has been identified as potential vulnerability. For the KPGF facility, an updated SVA report will be completed by March 2023. Based on the audit findings, CCBPL will develop water conservation plan for the KPGF.

CCBPL  has planned the implementation of nine  water saving projects at KPGF, such as: (i) Activated Carbon Filter( ACF) and Ultrafiltration (UF) backwash water saving, (ii) Pump seal water recycling at dissolver & victoria, (iii) Reuse of reverse osmosis (RO) rejects with 50% recovery, (iv) Clean-in-place CIP pre-rinse water utilization after treatment & Cooling towers, (v) Utility cooling tower evaporation water recovery project, (vi) Rainwater Harvesting for cleaning activities, (vii) Water softener unit backwash water recovery and (viii) Production lines cleaning/coefficient of performance (COP_ water recovery. To further ensure sustainable water consumption and minimize risks associated with groundwater depletion, CCBPL will develop a water management plan for the KPGF based on the KPGF source vulnerability assessment (SVA) report findings including: (i) water consumption and availability plan and water accounting forecasts and (ii) quarterly progress report summarizing the results of assessment, way forward and recommendations. (ESAP#3).

Management Systems & Programs: CCI’s policy commits to quality, environmental, occupational health and safety, and food safety management systems with internationally recognized standards. All CCBPL Pakistan operations are certified against ISO 9001:2008, Food Safety System Certification (FSSC) 22000, OHSAS 18001:2007, ISO 14001:2004, ISO 50001: 2011, ISO 9001: 2015, HAZOP, KORE and FACC 22000. In addition, ISO 19001:2007 is also being implemented at Rahim Yar Khan Plant Site while ISO 45001:2018 and OHSAS 18001:2007 are implemented at Lahore Plant. The Faisalabad, Gujranwala, Karachi, Lahore and Rahim Yar Khan Plants were audited in 2015 and 2016 for recertification for most of the standards. According to the audit results, no material non-conformities at these plants were encountered. KPGF plant have cleared Stage-I audit for ISO 45001 and 14001. Stage-II audits against these standards have been completed in February 2023.

Organizational Capacity and Competency: CCBPL has established a competent EHS function at corporate and plant-level. At the KPGF plant, the E&S matters are handled by a qualified officer acting as the Quality Executive and a HSE Engineer. However, coordination, communication and reporting lines between CCBPL’s corporate and KPGF HSE function is limited and would benefit to be formalized to ensure alignment with corporate E&S policy. CCBPL will strengthen its E&S capacity by (i) developing training module in line with “WBG EHS Guidelines  for Food and Beverage Processing” and include these trainings as a regular element of training calendar, (ii) developing and implementing internal reporting  procedures for coordination of HQ and production facilities based team on IFC’s PS and reporting requirements; and (iii) assigning of dedicated, qualified and experienced EHS professionals for each of plant. (ESAP#4).

Emergency preparedness and response: CCBPL implements an emergency preparedness and response plan including a fire safety plan, in line with IFC PS1 requirements. Drills are planned for each plant annually, including simulations for confined space entry, boiler, ammonia leakage, first aid, fire and earthquake, chemical spill, emergency response for fall from height, flammable liquid, gas cylinder leakage and fire, respiratory and security. Like other CCBPL plants, KPGF facility is located adjacent to Hattar Industrial Estate Road and is subject to the Industrial Zone Emergency Plan.

EHS Monitoring and Review: CCBPL is monitoring all its Pakistan operations in accordance with a EHS dashboard. Air emissions and wastewater monitoring results at operational locations remained compliant with WBG guideline values and local regulatory requirements in 2021 CCBPL will include the KPGF facility under the existing CCBPL EHS monitoring and review program (ref. ESAP#2).

Supply Chain risk assessment and management. CCBPL raw material supply is classified into two broad categories i.e. the primary raw and secondary raw material. The primary raw material includes following: concentrate, sugar (mainly sourced from Punjab and Sindh Province of Pakistan), CO2 and pre-form of (plastic bottles). Secondary raw material includes: label, shrink and stretch (these two are plastic package), interlayer sheet secondary packaging (paper material). Raw material is procured centrally by head office (TCC company, approved suppliers after audit qualifies for supplies). Major service providers include distributors, transporters, sales agents, security and catering agencies.

CCBPL is committed to continue auditing its supply chain periodically based on risks. CCI established Supplier Guiding Principles (SGP) with Green Status across all its country of operations. The SGP sets out minimum CCI requirements for third-party raw material suppliers, including compliance with applicable national laws and regulations, child labor, forced labor, abuse of labor, freedom of association and collective bargaining, discrimination, wages and benefits, work hours and overtime, health and safety, environment and demonstration of compliance. Suppliers are also reviewed and evaluated annually, including on hygiene and safety.

All suppliers are certified to recognized standards (FSSC22000 – SGFA – BRC) and are pre-approved according to CCI’s supply chain requirements. No serious issues have been recorded under IFC previous investment (#37922), based on review of compliance audit of primary suppliers / contractors /distributors. CCBPL is committed to continue auditing its supply chain periodically based on risks The SGP have been included in supplier agreements since 2002 for TCCC and the direct suppliers to bottlers, including CCI. Suppliers are audited by TCCC and CCI regularly and TCCC routinely utilizes independent parties to assess supplier performance according to SGP. The audit results are reported to TCCC’s global audit team and tracked by CCI. CCBPL will provide supply chain compliance audit report (by itself or engaging 3rd party) of primary suppliers / contractors /distributors to verify status of compliance with the Borrower’s SGP, terms and conditions of their agreements with CCBPL and local laws and regulations (starting from a sugar industry) on labour and working conditions including occupational health and safety and environmental protection; frequency of the audits will be based on performance of every supplier/contractor/distributor and can range from one to every three years (ESAP#7).Suppliers are expected to implement corrective actions to comply with the SGP requirements and to avoid agreement termination. The audits results are also publicly reported with the Sustainability Report. In case of any non-compliance, CCBPL is committed to take necessary corrective actions and/or change suppliers.

 CCBPL employs 2,377 direct employees out of which 143 are female direct employees and 223 were contractor employees. Total workforce at the KPGF facility is 120 permanent management and non-management employees, including 8 are females. An additional 20 management and non-management staff is expected to be hired for the new PET production line.

Human Resources (HR) Policies and Procedures: CCI adopted the Workplace Rights (WPR) as its internal HR policy globally. The WPR is based on UN Universal Declaration of Human Rights, International Labour Organization’s (ILO) principles, and the UN Global Compact. CCBPL HR policy is overseen by CCI Executive Committee and includes provisions covering freedom of association and collective bargaining; prohibition of forced labour and child labour; discrimination; working hours and wages; safe and healthy workplace; grievance mechanism, community and stakeholder engagement, The company’s HR policies are in compliance with national laws and regulations and IFC PS2 objectives. CCBPL will develop formal workers grievance mechanism procedures in line with the requirements of IFC’s PS2 in English and local language. This will also include a complaint box to be placed in the KPGF plant premises (ESAP#5).  

Working Conditions and Terms of Employment: CCBPL implements PIR (Pay in Range) market surveys conducted by a third-party service provider to assess wages/salaries for corporate sector which is used by CCI as a salary scale benchmark for CCBPL employees. Employees work 5 days a week in offices and 6 days at plants in two, 8-hour shifts and are given a break for lunch. During peak season, a third 8-hour shift is added. Overtime is voluntary. Each facility includes clean drinking water, toilets separate for men and women a cafeteria with food, and sufficient indoor seating (with ceiling fans/ACs) and first aid system with company own ambulances.

Workers’ Organization: All workers are unionized. Union membership includes permanent/full time workers employed in production plants and sales centres across Pakistan (non-management level, excluding third-party contractors). Elections are held every two years, including renewal of Collective Bargaining Agreement (CBA). No union strikes and conflicts were reported since 2016. CCBPL also carries out monthly employees and union representatives’ meetings. The minutes are documented.

Grievance Mechanism: CCBPL adopts an open-door policy and grievances are managed through union representatives. The formal procedure includes an ethics helpline, email service, and an online anonymous e-mail (ER)/Information Reporting (IR) portal to report grievances. The HR department is responsible for handling workers (non-management staff) and with management level employees’ grievances.

Occupational Health and Safety: In line with its HSE Policy, CCBPL is committed to ensuring safe working conditions to all employees and contractors at its facilities. CCBPL developed a Safety and Evacuation plan for each facility (offices, plants, sales centres, warehouses), and Standard Operating Procedures (SOPs) for (i) emergency response, (ii) managing incidents/accidents, (iii) employees and visitors, (iv) third parties (contractors, sub- contractors, sales and distribution agencies), (v) risk assessment. OHS is monitored by EHS staff and the company uses monthly HSE statistics to identify the effectiveness of systems implementation and controls exercised to ensure compliance. No fatalities and severe injuries have been reported at operational sites. Three lost time accidents (LTAs) have been reported in 2019. Corrective Action Plan (CAP) have been developed and implemented to address investigation’s recommendations. Plant safety at operational sites ensured the (i) integrity of the safety equipment, regular operations risk assessment, testing of vehicle safety, seat belts operations and use. . PPEs (e.g.  coverall, shoe caps, hygiene caps, gloves) are being provided to workers while behaviour-based safety, defensive driving training, firefighting, emergency evacuation and other EHS trainings are part of the annual EHS training calendar. Concrete steps taken by KPGF for improvement of OHS systems at site includes: (i) installation of automatic trapping system, (ii) addition of inspection process, (iii) x-ray inspection method replaced with camera to check bottle filling and capping and (iv) reduced manual lifting and handling operations through increased automation and palletiser and shrink wrap. However, improvements of OHS and environment related signs/symbols in English and local language are being recommended particularly at the waste storage area. Going forward, CCBPL will further enhance its OHS risk assessment and management practices at KPGF facility in line with IFC PS2 requirements and WBG EHS Guidelines (ESAP#6). 

All employees and contractors go through a standard orientation module at the time of joining. Shift start trainings are also provided across different facilities. Job specific EHS training plans are developed and organized yearly for all employees. CCBPL has implemented specific improvement measures under the ESAP#37922 to fleet management i.e. drivers safety by ensuring that a) safety belts are functional in all vehicles used in business operations and b) fire extinguishers are installed in all trucks owned by the company or distributers third-parties transportation. Going forward, CCBPL will ensure such fleet safety measures are in place, including at KPGF, and will continue to monitor its effective implementation.

Workers Engaged by Third Parties: CCBPL procures third-party service providers for non-core functions through an open competition and formal contractual agreements. Standard contract clauses for service providers and contractors include labor laws, working conditions, including provision of PPEs, and EHS requirements. CCBPL conducts annual performance evaluation to review compliance with the terms and conditions of contracts. It provides technical assistance to third-party service providers, including equipment, process improvements, human resource development and EHS to improve operations efficiency. External supplier’s vehicles are also monitored for use of functional seat belts. Third-party contractors are issued with safety card after training/EHS induction.

 All of CCBPL’s existing facilities are located in industrial urban, peri-urban or agricultural areas where basic infrastructure and utilities (electricity, sewerage systems, and solid waste collection) are supplied by relevant municipalities. Risk assessments are implemented by the Company, including mitigation and improvements measures addressing management of WWTP and emissions from the bottling operations.

Resource Efficiency: In Pakistani operations, power is sourced primarily from the grid, in addition to small standby diesel generators in all facilities to ensure consistent power supply, and reduce machine down time. CCI aims to reduce the amount of energy consumed per refrigerator and switch to HFC-free cooling equipment that contain refrigerants with low global warming potential within the scope of 2020 energy management and climate protection targets. In CCBPL operations, R134A, R407 and ammonia are used at manufacturing plants as refrigerant agents. These refrigerants are acceptable under the Montreal Protocol. There are no governmental restrictions for the refrigerant amount used in Pakistan. Maintenance and operations of coolers are implemented by the sales point owner but gas and procurement of the spare parts are done by CCBPL.

Energy management and climate protection are priority areas in CCI’s sustainability strategy. CCI sets targets and implements mitigation measures for energy use reduction, GHG emissions, and low-carbon technology alternatives. KPGF recently equipped with 1 MW solar power and plans the installation of an additional 1 MW solar by 2023. CCBPL also implemented a number of energy and water conservation interventions as part of the agreed upon ESAP#37922, including the use of ultrasonic detectors for repairing steam/compressed air leaks, use of thermal camera for regular surveys to identify all hot & cold pipe insulation leaks, switching to high-efficiency lights. The annual energy consumption in MJ/liters of 0.25 for 2020 indicated a decrease in energy consumption when compared with the baseline value of 0.52 MJ/liter and the targeted energy consumption of 0.46 MJ/liter for 2020. Other water conservation programs across various facilities in Pakistan include backwash water saving, Pump seal water recycling Project,  Reuse of RO rejects (50% recovery, CIP pre-rinse water utilization after treatment & Cooling towers,  Utility Cooling tower evaporation water recovery project, and Production lines cleaning/COP water recovery.

Air emissions. Point source air emission from boilers stacks complied with WBG guideline values and local standards for NOx, SO2 and Particulate Matter (PM) at all CCBPL operations. Stack emissions from diesel generators in Lahore plant have been measured and analyzed by a laboratory, as required by National Environmental Quality Standards (NEQS). Stack emissions at CCBPL are compliant with all local regulatory laws. To meet WBG EHS Guidelines, the KPGF will provide the necessary documents (ESAP#8). In case of deviations, time-bound corrective actions will be agreed upon.

GHG emissions for all CCBPL’s Pakistan operations have been tracked since 2014, whereas the company reported Total CO2-eq Emission of 66,000- and 56,600-tons CO2/year in 2020 and 2019 respectively. In 2021, CCBPL’s Scope 1 emissions were 27,095 CO2e due to electricity consumption whereas emissions due to stationary combustion emissions, fleet emissions and fugitive emissions from cooling systems (Scope 2) were 35,554 CO2e. CCBPL recently equipped KPGF bottling facility with 1 MW solar power and plans the installation of an additional 1 MW solar by 2023.

Water and Wastewater Management: Process water for all CCBPL plants is sourced from 2 groundwater wells having water extraction capacity of about 145 m3/hour. To achieve efficient and sustainable water consumption use targets, KPGF also monitors its Water Use Ratio (WUR) (i.e., liters of water used/liters of products produced). The current WUR is reported as 1.59 liter/liter of the product. As water is a material risk, the preparation of a water balance assessment is a key element of CCI’s water management strategy, as reflected in CCI 2020 Integrated Annual Report. Source Vulnerability Assessment (SVA) study and Source Water Protection (SWP) plan are carried out for each plant in Pakistan every five years by an independent consultant. Irrigation Department issued a Non-Objection Certificate (NOC) in August 2021 specifying provisions for wastewater discharge and the development of a water monitoring plan, including (i) groundwater quality and quantity in the locality; (ii) volumetric monitoring of water abstracted by CCBPL; (iii) effluent quality discharged into Haru River; (iv) monitoring frequency, data accuracy and reporting. To ensure sustainable water consumption and minimize risks associated with groundwater use, CCBPL will develop a water protection plan for the KPGF facility based on the KPGF water Source Vulnerability Assessment (SVA) report findings, including: (i) water consumption and availability plan and water accounting forecasts and (ii) quarterly progress report summarizing the results of assessment, way forward and recommendations (ref. ESAP#3).

During peak season the maximum wastewater discharge is about 200 m3/day, which is treated through wastewater treatment plant installed with secondary chemical treatment, aeration coagulant and flocculant. Tertiary type wastewater treatment plant (extended aeration) also commissioned in December 2022 which became operational in January, 2023. Wastewater treatment at other operational facilities of CCBPL is also maintained in line with National Environmental Quality Standards (NEQS) and WBG EHS guidelines for effluent’s guideline values. Across all facilities the levels for pH, BOD5, COD, Total nitrogen, Total phosphorus, Oil and Grease, Total Suspended Solids, Total Suspended Solids and Fecal Coliform Bacteria have been in compliance with WBG effluent’s guideline values and local standards, as confirmed by independent laboratories.

Solid and Hazardous Waste. CCBPL records the volumes of hazardous material used at each facility including caustic soda, diesel and acid. Waste categories and disposal methods are recorded at each plant. Wastes are recycled through government approved 3rd party vendors. CCBPL has a dedicated KPI (grams of waste produced/Liter Product) to monitor and control waste generation. The indicators underlying Solid and Hazardous Waste management systems at KPGF have improved compared to the baseline. Concerning plastic waste, KPGF facility is launching a project to recycle plastic waste and convert it into plastic pallets to be utilized for storage of finished goods. Going forward, CCBPL will continue to undertake necessary corrective actions to ensure compliance and eliminate any deviations in line with WBG EHS Guidelines in all facilities in Pakistan including: (i) wastewater management practices, (ii) energy conservation measures, and (iii) solid and hazardous waste management with a focus on plastic waste management plans (ESAP#8).

 Transportation Safety Management: CCBPL does not own a fleet of trucks as  the distribution is undertaken by distributors. CCBPL has an accident recording system and undertakes traffic safety management through several measures, including defensive driving training; (i) by third parties to their drivers; (ii) by CCBPL; and (iii) by National Highway Authority. Other traffic safety management measures include license checking, fitness for work, annual drug testing, parking protocols, and route hazard assessment. The KPGF facility implements the CCBPL transportation safety management system. As KPGF facility is located near a school, and to avoid accident risks and ensure community safety, CCBPL will implement the following measures in respect to traffic safety at the KPGF facility: (i) develop and implement a traffic safety management plan to ensure safety of school students across transport routes network outside the plant, (ii) continuously enhance  signs, signals and markings of the KPGf’s transport routes (English and Urdu) and (iii) implement training on defensive driving for drivers, as well as road safety sessions for school children by CCBPL HS team (for example road crossing ethics training for school going children) (ESAP#9).

Food Safety: CCBPL activities comply with Hazard Analysis Critical Control Points (HACCP) principles for which all plants have received FSSC/ISO 22000. To reduce hygiene and food safety risks and to mitigate potential impacts on the community, the design of each processing line follows HACCP requirements to avoid contamination and remove potential contact between workers and the finished product. Procedures are also in place to ensure daily cleaning of equipment and solid waste management. Staff receive training on food safety and PPE (clothes, gloves and hair coverage) commensurate with the extent of contact with the finished product.

Security Personnel: Each site is equipped with a Closed-Circuit Television (CCTV). Security guards are employed through a licensed third-party service contractor (OHSAS18001 and ISO9002 certified) and work across two shifts (12-hours each). The security company developed a HR policy and SOPs which outline the requirements for security guards (i.e. criminal background checks, formal training for use of licensed weapons. health and safety, periodical trainings). A security assessment is carried out for each new facility and a mechanism for recording, investigating and reporting incidents is in place. CCBPL hires security personnel equipped with arms to secure their premises. The security staff keep close contact with local police and are updated about security situation. These same practices are replicated in KPGF facility.

Stakeholder Engagement. BBCPL developed a Stakeholder Engagement Plan (SEP) in 2018 (ref. ESAP#37922). The SEP includes requirements on information disclosure and external communication, stakeholder identification, corporate community investment projects, and external grievance mechanism. However, there is no formal documented external grievance mechanism for KPGF facility. Going forward, CCBPL will: (i) further enhance the existing stakeholder engagement plan (SEP) by defining more proactive strategy for stakeholder engagement and communication with the communities and other stakeholders in Haripur area, (ii) continue with efforts of communication related to the communities’ grievance mechanism including; separate and dedicated grievance logging, evaluation and resolution mechanism (English and local languages), (iii) maintain data with the record of grievances, indicators, analysis of trends, response times including community grievances relevant to the school (ESAP#10).

  Stakeholder Engagement. BBCPL developed a Stakeholder Engagement Plan (SEP) in 2018 (ref. ESAP#37922). The SEP includes requirements on information disclosure and external communication, stakeholder identification, corporate community investment projects, and external grievance mechanism. However, there is no formal documented external grievance mechanism for KPGF facility. Going forward, CCBPL will: (i) further enhance the existing stakeholder engagement plan (SEP) by defining more proactive strategy for stakeholder engagement and communication with the communities and other stakeholders in Haripur area, (ii) continue with efforts of communication related to the communities’ grievance mechanism including; separate and dedicated grievance logging, evaluation and resolution mechanism (English and local languages), (iii) maintain data with the record of grievances, indicators, analysis of trends, response times including community grievances relevant to the school (ESAP#10).