This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on 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). 

Key E&S issues and risks associated with the Project include: (a) air emissions, noise and vibrations management in line with WBG EHS Guidelines; (b) management of potential transport impacts on communities health and safety; (c) strong oversight of the contracted workforce (construction and operations) in relation to labor practices and maintaining adequate occupational health and safety standards; and, (d) maintain continuous stakeholder engagement related to E&S aspects and implement an adequate grievance mechanism.                                                  

Policy and Management System. The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements.  VICAT Group Sustainability Framework, E&S policies and management procedures are cascaded down to SOCOCIM.  SOCOCIM adopted a QSE Policy and established an Integrated QSE Management System covering the plant and quarry activities The SOCOCIM plant is certified ISO 9001 (quality) since 2009 and ISO 14001 (Environment) since 2010. The efficiency of the QSE Management System is annually audited by external auditors. 

Identification of Risks and Impacts.  An Environmental and Social Impact Assessment (ESIA) was completed in March 2022 for the Project in line with the national legal requirements.  To complement the ESIA and meet IFC requirements, SOCOCIM will conduct complementary ambient air quality, noise , vibrations and traffic impact assessment studies for the Project to define adequate mitigation measures (see details under PS3). 

No quarry expansion is planned as part of the project, however investment in a new crusher at the Bargny quarry will be part of the Project.  The company will prepare additional ESIAs for the Bandia quarry before it starts operations (for the additional 250 ha authorized in 2019, not yet in operation), for the Pout quarry (410 ha authorized in 2009 versus 150 ha assessed in the 2004 ESIA) and for the Ngoudiane quarry (per article 4 of the Arrêté of July 11, 2019) in line with the national legal requirements and requirements of IFC PSs (ESAP # 1.1).

Management Programs.  The Project ESIA (2022) includes an Environmental and Social Management and Monitoring Plan (ESMMP) which covers both the construction and operations phases for the Project. The EPC contractor has prepared an Environmental, Health and Safety Plan for the construction phase. SOCOCIM will update and implement the ESMMP and other specific management and monitoring plans in line with the requirements of IFC PSs, as per ESAP #1.2 and 1.3.

Organizational Capacity and Competency.  SOCOCIM has a dedicated a Quality, Safety and Environment (QSE) Department.  A separate Quarry Department manages all 4 quarries and SOCOCIM agreed to strengthen its EHS organization capacity by hiring a health, safety and environment (HSE) officer (ESAP #1.4).  The EPC contractor will have an HSE Manager to supervise construction activities.  Clear roles and responsibilities of SOCOCIM HSE monitoring and supervision during the Project construction will be developed (ESAP #1.4).

Emergency Preparedness and Response. SOCOCIM has documented an emergency preparedness and response (EPR) plan for the cement plant.  The plant has the necessary fire safety emergency detection and alarm systems, and response equipment, tested periodically. The EPR will be updated to reflect the construction and operation of the new kiln 6 (ESAP #1.3).

Monitoring and Review.  As part of the plant QSE management system, the company monitors key performance indicators (KPIs) such as regulatory compliance. The QSE Management System Manual has a provision for regular EHS monitoring and review via internal audits and performance assessment.

SOCOCIM has 353 direct workers and 1936 contracted and hired through 4 labor hire agencies and employed through third-party contractors to support current operations.  The majority of contracted workers are from Rufisque and neighboring local communities in accordance with SOCOCIM contractor’s requirement to prioritize employment from local communities. The Project construction phase would require additional 1500-1600 workers. In the operational phase, it is anticipated that the plant workforce will increase approximately from 353 to 409 direct workers.

Human Resources Policies and Procedures.  SOCOCIM adopted and implemented the VICAT Group HR and Procurement policies and strategies as described in its Declaration of Non-Financial Performance (DPEF). Its Supplier Code of Conduct and Ethical Charter prohibit forced labor, child labor and discrimination and proactively seek to favor inclusion, employ local populations and proactively train teams on occupational health and safety.  SOCOCIM adopted and implemented site-specific specific HR procedures and regulations including: Quality, Health and Safety Manual (2018) and as required by national labor regulations, the Internal Regulation (Règlement Intérieur- 2020) which applies to all direct workers. SOCOCIM and VICAT HR policies and procedures align with national legal requirements.  In order to align with IFC PS2 requirements, SOCOCIM will update its labor grievance mechanism (see details below). 

Working Conditions and Terms of Employment.  Working conditions and terms of employment are largely defined and aligned with the Senegalese labor law and the current collective bargaining agreements (CBA). All direct SOCOCIM workers have an open-ended contract (CDI, Contrat à Durée Indéterminée) except for seven employees who have fixed term contracts (CDD, Contract a Durée Déterminée).  The contracts for direct workers detail remuneration, employment period, responsibilities, probation period, available leave and medical requirements. Monthly wages are above the Senegalese minimum wage requirements and applied according to the worker’s grade. In addition to the basic monthly wage, workers are also entitled to leave, support in accessing housing finance, health insurance and free medical clinic and subsidized medicine on site for all workers (direct and contracted) and their family (family access temporarily suspended due to COVID 19 pandemic), retirement package, camp for children, and the potential for bonuses based on company and individual performance. Working hours are dictated by national labor legislation and industry standards, with workers not required to work more than 40-hours per week.

Workers’ Organization.  Approximately 80% of SOCOCIM employees are members of the CNT-FC (Confederation Nationale des Travailleurs du Senegal) union.  Union members are represented by 14 delegates and seven alternates that are elected for 3-year terms. A collective bargaining agreement (CBA) was finalized in December 2019 and additional points are agreed on an ongoing basis through the monthly meetings (briefly paused during the COVID 19 pandemic).

Non-discrimination and Equal Opportunity.  SOCOCIM is subject to VICAT Group policy on non-discrimination and inclusion including for gender and level of abilities. The group level policy is accompanied by a practical guide regarding good practices for an effective and inclusive recruitment. SOCOCIM has an HR Strategy of inclusion related to gender equality, diversity and disability with a goal of zero discrimination. The Internal Regulation outlines basic protection against bullying and sexual harassment.  SOCOCIM is seeking to increase the percentage of female employees over time and is monitoring gender diversity in recruitment.

Grievance Mechanism.  SOCOCIM Internal Regulation defines a process for workplace grievance and conflict resolution than can be treated at the team’s manager level or escalated to senior management.  For workplace grievances that do not reach the conflict resolution stage, employees report grievances either to their union representative or directly to human resources.  Furthermore, VICAT group’s Ethical Charter website is available for workers to report on non-compliance with the charter without retribution. However, SOCOCIM will update and implement a formal grievance mechanism (GM) for all workers to facilitate reporting and management of worker grievances, anonymous reporting and the procedures will also cover third-party workers.  Additionally, the GM will include a differentiated approach to address sexual harassment and gender-based violence.  The updated grievance mechanism will be disseminated to all direct and third-party workers (ESAP #2.2).

Occupational Health and Safety. Health and Safety (including Fire Safety) are supervised by the Vicat Group through regular communications and on site visits and training. SOCOCIM is following the VICAT Group’s objective of “Zero Accident” for its staff and staff from external companies and is implementing the “Essentials” rules, which form the fundamentals benchmarks at the site. Work-related accidents statistics for direct and contracted workers show a downward trend in the last several years. However, the number of work-related injuries is notably higher for contracted workers, which will require from SOCOCIM to strengthen its OHS monitoring and supervision for contracted workers (ESAP # 2.1).  Further, as part of the construction ESMPs, an OHS risk assessment and management plan has been prepared and implemented by the EPC contractor.

Workers Engaged by Third Parties.  SOCOCIM currently use four labor hire agencies and several primary third-party contractors for the provision of services for shipping-logistics and mechanical maintenance activities, as well as for green spaces, electrical maintenance, security and trucking. SOCOCIM contracts stipulate that labor agencies and contractors must respect their fiscal and social obligations to its workers including tax payments, retirement, social security and health insurance and maintains the right to audit worker contracts. In addition, workers hired through labor agencies are required to follow SOCOCIM’s Internal Regulations.

SOCOCIM has engaged an EPC contractor for the kiln 6 Project construction and as per the EPC contract, specific labor provisions are included such as (i) workers be hired in accordance with the Senegalese law; (ii) respect of SOCOCIM health and safety policies and procedures; (iii) workers be informed of health and safety risks related to their work by the contractor; and, (iv) the requirement that workers wear appropriate PPE while on site.  In order to align with PS2 requirements, SOCOCIM will update its contractor management procedures to strengthen its monitoring and supervision of labor and OHS practices of its contracted workers for current operations and construction (ESAP #2.1).  

Supply Chain.  Key supplies currently include coal, pet coke and alternative fuels.  Alternative fuels will increase with the Project and include biomass, used tires, SRF, liquid waste.  Key potential risks include unfair labor practices, child and forced labor and potential OHS issues.  SOCOCIM included CSR clauses on labor, health and safety in the contracts with suppliers. As per ESAP # 2.3, the company will conduct supply chain mapping and E&S risk assessment for its suppliers for biomass and alternative fuels and develop a code of conduct for the suppliers to address the potential risks.

 Energy Consumption.  The main fuels for the kilns are coal and pet coke (up to 240kt/yr). Since 2009, alternative fuels for the kilns have been used as a replacement for fossil fuels. The current substitution rate is approx. 20%, consisting mainly of biomass, used tires, used oils and solid recovered fuel (SRF). The new kiln 6 aims at substituting up to 70% of fossil fuels. Thermal consumption of new kiln 6 will be within the range reflective of Best Available Techniques (BAT) defined by the 2013 EU BAT Reference Document for the sector, and within the benchmark set by the WBG EHS Guideline for Cement and Lime Manufacturing.

In addition, the electricity requirement for the new kiln 6 will be within the guidelines provided by the WBG EHS Guideline for Cement and Lime Manufacturing. 50% of the electricity will be provided through the national grid and the remaining by onsite supply including a 24 MW HFO fuelled plant, 3MW gas fuelled plant and 6.9 MW solar plant.

Water Supply.  The SOCOCIM plant uses about 400,000 m3/year of water, provided by the network (SEN Eau) and rainwater reutilization. The manufacturing process is essentially dry, and most of the water will be used primarily for cooling, grinding, high pressure cleaning, dust suppression, fire network, sanitary facilities. The plant water needs after Project installation will be significantly reduced due to Project design, leading to an economy of 150,000 m3/year as compared to current plant usage. 

Greenhouse Gas Emissions. The project gross emissions are estimated at 1,700k tCO2eq/year for kiln 5 and 6. For comparison, GHG emissions of the business-as-usual scenario (kiln 3 and kiln 4 in operation) would be over 2,000k tCO2eq/year. Hence, the Project would generate a reduction of more than 300k tCO2eq/year of greenhouse gas emissions.

Air Emissions and Ambient Air Quality.  The principal sources of air emissions at the SOCOCIM plant are the clinker production and grinding operations including limestone quarrying activities and transfer to site (via truck haulage), storage and handling of clinker, limestone, basalt and coal at the plant, transfer and bagging of cement, as well as transportation along the site access road. Measures are implemented to reduce dust levels such as filters, roads cleaning and watering. Also, the existing conveyors are enclosed, to reduce dust emissions.

Results of annual ambient air quality monitoring show elevated dust levels (PM10) within the site, at the site boundary and in the residential area, as well as SO2 at the site boundary. Monitoring of the kiln 5 and the on-site power plant stack air emissions currently shows exceedance of WBG EHS Guidelines. The Project is designed to significantly reduce dust emissions with: best available technology (including single bag filter design); replacement of existing coal mill; no more clinker imports and less clinker handling; increase of inside clinker storage capacity; and one single crusher for raw materials instead of two, equipped with a powerful bag filter. In addition, incoming and outgoing trucks will be routed through a new concrete road from national road to the crusher (as opposed to laterite track presently).  SOCOCIM will conduct monitoring of current and future emissions to identify and address any non-compliance with national and WBG EHS Guidelines, per ESAP # 3.1 and ESAP #3.3.

SOCOCIM is in the process of commissioning an air quality impact assessment to characterize air emissions and any impacts on ambient air quality resulting from the project. The study will i) assess baseline air quality, ii) undertake scenario based modelling per good international industry practice accounting for the likely air quality in the neighboring community areas based on expected operations and iii) propose mitigation measures to achieve compliance with the applicable national standards and WBG EHS Guidelines ahead of full operations per ESAP #3.2.

Ambient air quality monitoring during construction activities will be planned and implemented as per ESAP # 1.2.

Noise and vibration. Noise is generated by operation of plant equipment, quarrying activities including infrequent blasting, and operations-related traffic. Annual ambient noise monitoring results indicate noise level exceedance of WBG EHS Guidelines in the resident areas close to the plant boundaries.  

The main source of vibration is blasting activities at the limestone quarries. There is a maximum of 3 blasting per day in Bargny, carried out only during daytime and at a fixed time.  As described further in the stakeholder engagement section below, community concerns and complaints about noise and vibration caused by blasting practices at the quarry sites have been received. Monitoring of blasting vibrations is systematically conducted at the Bargny quarry. Monitoring for the past three years shows no exceedance of the defined threshold (French standard to avoid damage). SOCOCIM’s Noise & Vibration Management Plan will include regular monitoring for eventual structural defects at site buildings, as well as at any buildings in the neighboring communities (ESAP #1.3).

SOCOCIM is commissioning a noise and vibration impact assessment study to assess the impact of the Project on ambient noise and vibrations during the operations phase through quantitative noise modelling and identify mitigation measures, as required, to achieve compliance with the applicable national/local standards and WBG EHS Guidelines per ESAP #3.4.

Solid Waste Management. The main waste types generated in SOCOCIM operations include, food, paper and cardboard, scrap metal, used oils, oiled rags, plastics, wooden pallets, electronic waste. SOCOCIM established a Waste Management Procedure. Waste is segregated at the site and waste streams are mainly recycled (Objective: zero waste to the landfill). All waste with calorific value (paper and cardboard, used oil, oiled rags, solvents, plastic, wood etc.) is collected and used in the kilns as combustible material. Used tires from garages and parking lots and waste from health-care activities from the internal infirmary, are also collected and treated as alternative fuels. Scrap metal is sent out for recycling.  Raw material residues (as well as waste clinker and cement) are collected and recycled in the process at a rate of 90%, to be improved to full recycling with the acquisition of a new vacuum truck. Fuel and hydrocarbon storage areas are equipped with oil/water separators. In addition, the VICAT Group aims to increase the share of regional waste recovered in its production units (through the use of alternative fuels).

Wastewater Management.  There are few wastewater sources at the plant other than sanitary facilities. Sanitary wastewaters are collected for treatment in an offsite wastewater treatment plant. Liquid waste from workshops or spills are collected in drains for energy recovery. Stormwaters from the plant are collected in drains discharging in a basin within the SOCOCIM site, then overflowing without pre-treatment outside the site to an open canal (regularly scraped by SOCOCIM) (ESAP #3.5).

All Project installations will be equipped with a stormwater drainage system equipped with grates to minimize the quantity of suspended solids in the water, connected to the existing network. Stormwaters from the quarry are drained to lakes located within the quarry, to be reused within the process (for firewater and dust suppression mainly). As part of the Project, there is a plan to improve rainwater recuperation in the quarry and add treatment (filtration) for improved use in the plant.

Hazardous Materials Management. The main hazardous materials in production include energy sources (coal and pet coke, fuel), engine oils and lubricants, laboratory materials. Hazardous materials storage and the gas fuelling area are equipped with secondary containment. Emergency response equipment (absorbents) are available. During construction, hazardous materials will include: fuel, lubricants, hydraulic fluids, paints and solvents, concrete additives, forming oils, detergents. The construction ESMP will include a plan for the proper storage and handling of hazardous materials (ESAP #1.2).

Quarry Closure & Rehabilitation. Some (limited) sections of the quarries are rehabilitated as the exploitation works progresses. SOCOCIM established an action plan related to quarry management, which includes reforestation activities and partnership discussion with Water and Forest authorities (Eaux et Forêts). However, SOCOCIM will prepare a quarry closure and rehabilitation plan in line with WBG EHS guidelines and Good International Industry Practice (GIIP), to meet the objectives of physical, chemical and ecological habitat integrity and including estimated timelines and cost (ESAP #3.6).

 Infrastructure and Equipment Design and Safety.  The Project ESIA includes a Hazard Study to assess technological risks associated with new kiln 6. The study assessed major accidents scenarios such as vehicle accidents and fires at combustible storage areas (tires, biomass etc.), coal mill, silos and conveyor belts and provided mitigation measures associated with the main risks identified.

Community Health and Safety.   The operation of the plant and quarries have the potential to cause air quality, noise and vibration impacts in the neighboring communities, as described in the PS3 section above. SOCOCIM will commission additional impact assessment studies to further evidence the impact of the Project on ambient air quality, noise and vibrations.  Mitigation measures will be implemented if required based on the results, to align with the requirements of the WBG EHS Guidelines (ESAP #3.2, #3.4).  SOCOCIM will disseminate the findings of these assessments on SOCOCIM’s website with the nearby communities and will continue to monitor air quality and noise levels and track any related grievances via the community grievance mechanism (ESAP #6.1).

Transport and traffic safety. The majority of Project related transport routes are going through already busy public roads of nearby Rufisque settlement. SOCOCIM owns some of vehicles used for bulk product transportation, and outsources haulage trucks for raw material transport from the quarries to the plant.  Transport of cement products in bags is the responsibility of the buyers.

SOCOCIM established a transport safety protocol, which identifies the site-specific loading/unloading risks within the plant and proposes associated mitigation measures. However, SOCOCIM will commission a traffic and transport impact assessment to quantify the Project impacts and assess alternative routes to access the site to potentially reduce interface with communities.  Based on this assessment, SOCOCIM will augment existing protocols by developing a traffic and transport management plan to address aspects of travel planning, vehicle conditions/management, driver certification, training/awareness, documentation of road incidents, selection and control of transportation suppliers to mitigate the potential community health and safety impacts (ESAP #4.1). 

Security Personnel.  The Company’s security is provided by two third-party contractors with approximately 335 unarmed security personnel distributed across two daily shifts. Private security is predominantly responsible for access control, asset protection and monitoring of strategic points around the plant, the quarries and other facilities. Security risks are mostly related to potential theft, trespassing and safety related issues at the plant and quarries.  SOCOCIM security procedures exist for receiving and managing customers’ trucks in the site and registering visitors.  Procedures will be expanded to cover the security management of the quarries and interfacing with communities (ESAP #1.3).

 Stakeholder Engagement.  The ESIA process undertaken in 2022 included consultations with local, regional and national authorities and communities adjacent to the project and communes of the town of Rufisque, Rufisque-East and Rufisque-South and Bargny. The stakeholders expressed general support for the Project and raised concerns about (i) insufficient communications by SOCOCIM; (ii) air pollution, respiratory illnesses, dust, noise and blasting at the quarries; (iii) degradation of roads due to SOCOCIM’s operations; (iv) traffic accidents; (v) job opportunities for youth; and, (vii) request to increase SOCOCIM’s social investments.

A few years ago, SOCOCIM has started working on the development of mitigation plans for noise disturbances (see PS3 above), ambient air quality (see PS3 above), transport and traffic safety (see PS4 above), and will look into additional mitigation actions if needed per ESAP #3.4, #3.2 and #4.1. Corrective action plans, as identified and required, resulting from these studies will be shared with IFC, and shall include agreed timelines. Specifically, SOCOCIM will share the findings of the noise, air, vibration and traffic assessments with the affected communities and stakeholders on its website and through proactive engagement (ESAP #6.1).

The person in charge of Compliance is responsible for managing external grievances mainly related to overall compliance with SOCOCIM’s policies and procedures and managing anonymous reporting. Stakeholder engagement and external grievance mechanism responsibilities will be clearly defined by SOCOCIM.  The General Secretary leads the occasional community engagement, but the process and responsibility will need to be formalized (ESAP #1.4). Additionally, a stakeholder engagement plan (SEP) and grievance mechanism will be developed and implemented to guide the engagement with stakeholders about project activities, environmental and social performance, impacts and mitigation measures (ESAP #6.1).