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
Environmental and Social Management System and Policy
The company has a documented E&S policy that has been approved by senior management in place. The policy covers the company commitment for compliance with environmental regulations and standards while prioritizing health and safety practices across operations.
EGMED has an environmental and social management system (ESMS) in alignment with guidance of the international management system standards of ISO 14001 (environment), 45001 (occupational health and safety – OHS), and the applicable national regulatory requirements. Currently for the operations in Egypt, local environmental regulations do not require EGMED to prepare environmental or social impact assessment (ESIA) studies for this type of project.
Identification of Risks and Impacts and Management Programs
The company undertakes an E&S risks assessment process related to its activities as required by national authorities for environmental and construction permitting purposes. Based on the management systems in place, the company has also developed a procedure for Key performance indicators (KPIs) development and periodical evaluation. These include environmental as well as health and safety targets such as leading and lagging indicators for OHS monitoring and decision making as required.
EGMED will review its existing ESMS, in line with IFC PS requirements and will develop an E&S Assessment and Management Procedure, aligned with IFC PS and local requirements to identify and manage E&S risks associated with acquisition of existing operations and brownfield assets (ESAP #1). In addition, since locations of future acquisitions are not known yet, an E&S Screening procedure will be developed for future expansion plans, covering all PSs (ESAP #1).
Organizational Capacity and Competency
EGMED has a quality, health and safety and environment (QHSE) unit and all operational sites are under the supervision of the QHSE manager. The QHSE unit is composed of designated officers responsible for Environment & Social (E&S) and Environment, Health, and Safety (EHS) matters within the company's operations. EGMED will assign a qualified person to the QHSE unit to coordinate the implementation of the ESMS and supervise E&S performance of all assets newly acquired and in operation. There will also be an EHS leader at each operational site reporting to the EGMED QHSE Manager (ESAP #2).
E&S trainings, including EGMED values, on the job skills and health and safety topics are provided to EGMED staff. Going forward, EGMED will develop a comprehensive E&S Training Plan for all the direct employees and contracted workers across all EGMED operations (ESAP #1).
Emergency Preparedness and Response
There are Emergency Preparedness and Response Plans (EPRP) in place for headquarters, operational sites and warehouses. EPRPs include large fires, electric incidents, occupational hazards, safety incidents, chemicals spills, serious environmental incidents, traffic incidents and on-site accidents, natural disasters, and security incidents. This is in addition to the fire detection and fighting systems installed and regularly monitored at all EGMED sites in Egypt. For each new acquisition, the EPRP is developed and implemented by the plant management. The EPRP for the planned acquisition will be handed over and reviewed by EGMED at time of each acquisition. After acquisition of brownfield assets, life and fire safety audits will be conducted (ESAP #1).
The company’s E&S management systems were noted to be commensurate with the scale and E&S risks and impacts of its operations; and the implementation at the project level to be robust.
PS2: Labor and Working Conditions
EGMED employs around 580 employees directly (86% males and 14% females). EGMED also engages approximately 180 third-party workers, providing services such as facilities cleaning, maintenance and security. With the planned acquisition in East Africa, there will be no redundancies, ensuring a seamless transition with all employees retained.
Human Resources Management, Policies and Procedures
EGMED organizational structure includes the QHSE manager who reports to the drugs and regulatory affairs director and an HR and administration director. Both roles jointly oversee EGMED's application of national labor laws and report directly to the EGMED chairman. Current organizational structure at corporate level includes an HR and admin director assisted by learning and communication manager, performance and talent manager and an admin manager. The HR team regularly visits branches, warehouses, and plants. At the sites, the quality assurance (QA) manager is assisted by a QA specialist responsible for QHSE as mentioned above and relay any human resources issues between the HR team visits.
EGMED's HR policies cover recruitment, termination, remuneration, benefits (medical insurance, loans), working hours, leave system, performance appraisal. HR policies and procedures are all documented and available on the internal HR platform available to all employees. These are also included in induction trainings, which are conducted for contractor workers and visitors. The employment contracts cover employment duration, wages, benefits & termination. The company will collect all relevant policies in an Employee Handbook to include commitment to non-discrimination, measures related to gender-based violence including the development of a GBV/SEAH policy to be included in the staff training plan, a code of conduct, freedom of association, and retrenchment in line with IFC PS2 and make it available to contractor workers in Arabic (ESAP #3).
Employee Grievance Mechanism
Employees are encouraged to reach out to the HR team, their direct manager, or the manager above them to discuss and resolve issues. Additionally, the HR team regularly visits branches, warehouses, and plants to ensure open communication channels are maintained and the voices of employees are heard. The system is managed at company level and grievances are dealt with by the HR department. The company will document and update the Workers' Grievance Mechanism, in line with IFC PS2, to include a mechanism for anonymous grievances, a separate route for gender-based violence and harassment (GBVH) and will assign and train personnel on its use (ESAP #4).
Occupational Health and Safety (OHS)
The company has an OHS Policy as well as various procedures and an OHS Training Plan.
EGMED has a procedure for monitoring and reporting work-related incidents including conducting investigations and analyses of their root causes. No major health and safety accidents reported for EGMED over the past 3 years. Based on observations harvested through the auditing system in place, corrective measures are continuously implemented to eliminate occurrence of OHS incidents. In addition to the staff protection measures implemented, the company will develop heat stress management protocols, which will be implemented to protect the well-being of workers, including cooling systems and/or sufficient ventilation (ESAP #1).
Internal audits are conducted on regular basis for environmental, health and safety aspects across EGMED operations. EGMED is also subject to external audits such as visits by ISO certification institutes, every three years.
Workers Engaged by Third Parties and Supply Chain
There is no distinction in the HR procedures and training of staff, third party, or temporary employees.
EGMED E&S requirements are communicated to contractors through the contractor and visitors' management procedure which requires contractors to comply with and respect labor legislation and EGMED's internal management systems while performing work for the company. Monitoring contractor HR management, labor conditions and worker safety are included in the Contractor Management Procedure currently implemented at the EGMED facilities in Egypt.
EGMED's E&S policy is applicable to its contractors and stakeholders including suppliers. EGMED selects its suppliers and contractors based on their expertise, certification, and fulfilment of contractual requirements. EGMED has a Health and Safety procedure for contractors. EGMED will update its contractor selection through the integration of E&S requirements into its tender documents and, through its updated E&S Monitoring Protocol, it will monitor that these requirements are fulfilled for its existing operations and / or for new projects under acquisition (ESAP #1).
The company has an agreement in place that is signed with all its suppliers. This agreement covers the standards for materials used in assembly and manufacturing. This agreement allows EGMED to audit its suppliers once every three years. It will be updated to include E&S clauses, including (but not limited to) provisions for use of forced and child labor, in alignment with IFC PSs and will be shared with suppliers (ESAP #1).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gas (GHG) Emissions
EGMED’ annual GHG emissions in 2023 were estimated to be 3,838 tonnes of CO2-eq., including both directly through on-site fossil fuel combustion for back-up generators and electricity consumption for air conditioning, lighting, etc. at the warehouses and indirectly such as emissions from fleet fuel consumption. The estimated scope 1 emissions are 3,034 tCO2e/year and scope 2 are 804 tCO2e/year. Upon project completion, it is estimated that GHG emissions will remain less than 25.000 tpa as well.
Pollution Prevention
EGMED is monitoring its E&S performance per the local regulatory requirements. The company will update and implement an environmental monitoring procedure including resource efficiency (water, fuel, energy) monitoring and noise, air pollution from its fleet, wastewater quality will be tracked against the WBG's General EHS guideline guidance values, across all its operations (ESAP #1).
Water and Wastewater Management
Water provided by the industrial zone are treated through a filtration system before use in the manufacturing process. EGMED uses water for the process where Heparin is included in the product. Water provided by the industrial zone are passed through a filtration system before use. In terms of resource consumption, there is minimal use of water inside the warehouses and minimal wastewater is generated. Drinking water for employees on site is provided through purchased mineral water.
Hazardous Materials and Waste Management
Based on the solid waste management plan, all waste is segregated at source. A licensed waste disposal contractor is responsible for final disposal and recycling of the waste generated from the plants and warehouse facilities. The company does not currently produce any hazardous waste and does not expect any construction work related to its expansion plan. However, the waste management plan it currently follows in Egypt will be extended to its new acquisitions as part of the hand-over as mentioned under ESAP item 1.
PS4: Community Health, Safety and Security
The company owns and operates a fleet of 30 trucks for its operations. The company has in place adequate transportation safety management systems which includes its approaches to journey, fleet, and driver management for vehicle and community safety. EGMED has in place a safety monitoring program, developed per local laws requirements and in line with the Traffic Safety section of the WBG's General EHS Guidelines. Drivers are trained, licensed and vehicles undergo regular maintenance which is recorded and reviewed regularly and reported by the vehicles department.
Security Risk Management
The company contracts a private security provider to protect its facilities. The guards are not armed and are externally trained on access control, emergency evacuation and responsibility during emergency situations such as theft or property damage by the security service provider.
