SK Poland is located in an established industrial zone, surrounded by other production facilities. Thus, no E&S risks and impacts to nearby communities are expected. Performance Standards 5 through 8 are not considered relevant to this investment, since the Project will be constructed within the existing footprint where the land was acquired through willing-buyer-willing-seller transactions. As the Project is located in a well-developed industrial zone, which is a modified habitat, the Project will not have an impact on biodiversity or living natural resources. In addition, there are no indigenous people or cultural assets identified at the Project sites or in vicinity thereof.

This is a Category B project according to IFC's Policy on Environment 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”). 

Environmental and Social Assessment 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. In addition, SK’s corporate Sustainability and ESG management framework, E&S policies and management procedures are cascaded down to SK Poland. SK Poland has documented an EHS manual covering provisions on safety (e.g. risk classification, personal protective equipment (PPE), training, fire prevention, injuries reporting, etc.) and environment (e.g., waste disposal, treatment of wastewater, hazardous materials management) This manual is developed in accordance with the requirements of ISO 14001 and ISO 45001. The efficiency of the plant level E&S Management System is periodically audited by corporate ESG team in coordination with Environmental Management Committee through quarterly submitted reports and on-site visits. As part of the IFC investment, SK Poland will update and implement the existing EHS management system manual and related EHS standard operating procedures to address the expansion of the LiBS plant once it is operational (ESAP #1).

As per the requirements of local legislation, SK Poland has completed an EIA and safety and health protection plan for LiBS plant expansion and acquired the necessary environmental approvals from local authorities. In accordance with the EIA and BIOZ, the EPC contractor, SK Ecoplant, https://www.skecoplant.com/en/main, has prepared a construction Environmental, Social, Health and Safety Management Plan. The EPC has a well-established EHS policies and procedures.

Policy, Organizational Capacity and Competency, Monitoring and Review:

SK has a set of ESG policies  that guide all the activities and demonstrates its commitments for the sustainable development and responsible E&S management publicly available at: http://sustainability.skietechnology.com/static_page/Policies-and-Initiatives/?l=ENG. SK’s policies also cover human rights, gender and ethical standards, grievance handling, supply chain, biodiversity and no deforestation and climate change. ESG performance of all plants is tracked closely by the Corporate SK ESG team and published as part of annual Sustainability and ESG reports.

SK has an experienced EHS organizational structure at the corporate and facility levels ensuring that corporate EHS policies and management procedures are followed at all levels of its organization. Key ESG data of all SK plants are disclosed publicly through SK’s Annual Sustainability and ESG reports prepared in line with Global Reporting Initiative standards: i. http://sustainability.skietechnology.com/archived; and ii. http://eng.skinnovation.com/company/sr_01.asp Going forward, both reports will entail the ESG performance data of SK Poland’s operations.

Emergency Preparedness and Response:

SK has documented an emergency preparedness and response plan (EPRP) for existing LiBS plant operations. The plant has the necessary fire safety emergency detection and alarm systems, and response equipment, maintained and tested regularly. Additionally, the Company hired two in-house fire safety engineers who regularly carry out the fire protection system control and maintenance activities. As part of this investment, SK Poland will update the existing EPRP to reflect the expansion of the LiBS plant (ESAP#2).

Supply Chain management:

To manage E&S risks related to procurement and supply chain, SK has a documented process, including supplier prequalification and selection procedures in line with its Supplier Code of Conduct (http://sustainability.skietechnology.com/static_page/Supplier-ESG), which defines SK’s E&S commitments (including commitments relating to labor practices and human rights). SK incorporates these commitments into the contracts with its suppliers and regularly monitors E&S performances of key suppliers and conducts site visits if/when necessary. Furthermore, the relevant ESG information of the key suppliers is disclosed in the Annual Sustainability Reports.

SK Poland currently employs 457 direct workers 65% of which are male and 35 % female. In total, 50 third-party workers are employed in supporting activities including canteens and private security. 

At the peak of the construction phase, approximately 1,000 workers are expected to be on-site. The operations of expanded LiBS plant would require about 700 workers.

Human Resources Policies and Procedures, Working Conditions and Terms of Employment, Workers’ Organization:

SK’s corporate HR policy and procedures (http://eng.skinnovation.com/esg/csr_02.asp)  are cascaded down to its subsidiaries including SK Poland. Furthermore, SK requires all its subsidiaries to set up HR procedures following local labor laws. HR provides frameworks/guidelines which cover, working conditions, gender and equal opportunities, non-discrimination, any form of harassment, human rights, grievance mechanism, child labor, forced labor and freedom of association consistent with PS 2 and Polish labor law. SK Poland noted that each employee receives the relevant documents clearly indicating the terms and conditions of the employment, rights and the benefits, requirements for following SK’s EHS and ethical standards. Additionally, employees have access to the HR policy/procedures in their own languages. SK Poland is in the process of adopting the Corporate HR policies and procedures. Hence, as per ESAP#3, SK Poland will conduct a gap analysis against the Corporate HR policies and procedures and IFC PS 2 requirements to ensure its current HR policies and procedures are aligned with SK’s HR policies and procedures.

As articulated at Corporate Human Rights Policy, SK Poland respects the rights of employees to form and join an association without fear of retaliation, interference and harassment if the association complies with local laws which is also applicable to its subsidiaries. As reported in 2021 sustainability report, over 75% of its total employees are union members.

Non-discrimination and Equal Opportunity:

SK encourages diversity in its workforce and is committed to protecting its employees and stakeholders from all forms of discrimination and harassment based on their ideological views, race, color, religion, gender, sexual orientation, national origin, disability, age or any status regarded as a human right.

Furthermore, SK conducts annual human rights due diligence including SK Poland employees through online surveys which includes self-diagnosis checklist and interviews with groups vulnerable to human rights risks. Accordingly, a corrective action is planned and disclosed on their website and Sustainability Reports.

Grievance Mechanism:

SK has formal and well-established workers grievance mechanisms which also allow for anonymous submissions and same principle applied at all subsidiaries. All direct employees and contractors can report grievances through hotline, e-mail or online forms or suggestion boxes available in common areas. Additionally, employees can report their grievances to union representatives who follow an escalation procedure for addressing workplace issues. Issues raised through grievance mechanisms are followed up by relevant departments.

Occupational Health and Safety:

SK Poland has an established OHS risk management system that comprises programs and procedures to develop and maintain high levels of health and safety performance which aligns with corporate level OHS management principles and goals. High standards of workplace health and safety are maintained through periodic safety trainings, good safety signage all over the facilities, external and internal audits, oversight from senior management, systematically tracking the accident/incident records and analysing the data and taking necessary actions, enforcing the use of PPE and so on. All incident data are collected and complied through internal reporting systems for investigation, root cause analysis and to establish corrective and preventive measures. SK has competent health and safety experts assigned to plants and reporting to a senior health and safety manager appointed at corporate level. At the facility level, internal safety checks are conducted by the OHS specialist daily and by the EHS committee on a regular basis. All new employees receive safety training during induction, which is then followed by regular refresher training over the course of time and specific to the workplace risks and hazards.

Workers Engaged by Third Parties:

All third-party workers, including those assigned to construction sites are to follow the labour and OHS standards as those followed by the direct employees. Any accidents or incidents associated with third party employees are also recorded and monitored.

The EPC contract has specific labor provisions including: workers be hired in accordance with the Polish law; respect SK health and safety policies and procedures; workers be informed of health and safety risks related to their work by the contractor. SK Poland regularly monitors labor and OHS practices of the EPC Contractor.

SK is committed on environmental protection with clearly defined KPIs. SK has set a zero waste of air, liquid and solid target by 2030 and reduce greenhouse-gas emissions by 2035. SK Poland plants utilize the electricity from the national grid which is supplied from renewable sources and obtained RE 100 plant certification.

Estimated GHG emissions for expanded plant will be 26,223 tCO2e per year

Water and Wastewater:

The water use of expanded LiBS plant is estimated to be about 2,500 m3/day, provided by the network. The manufacturing process is essentially dry, and most of the water will be used primarily for cooling, cleaning of machines, fire network and sanitary facilities. The wastewater containing dichloromethane (MC), is collected in a tank and recovered. The remaining water with a small amount of MC is treated in the aeration tank and residue is sent for offsite treatment/disposal by qualified waste management companies.

The contaminated rainwater on exposed hard surface is collected and treated at filter system before discharged. The monitoring data for the discharged rainwater meet all local regulatory requirements.

Air emissions and Ambient Air Quality:

SK monitors and manages the air emissions from its facilities in accordance with the local environmental permit conditions. The main source of emissions is the natural gas fired boilers and MC emissions from the production process. Air pollution control measures are in place and the measurement results are in compliance with the local regulatory limits and the WBG EHS Guidelines. The plant is surrounded by other manufacturing plants and located in a region characterized with heavy industrial practices (past and present). Therefore, SK Poland will commission an air quality impact assessment, including baseline air quality assessment, to characterize air emissions and any impacts on ambient air quality resulting from the LiBS plant expansion and define mitigation measures to achieve compliance with the applicable national standards and WBG EHS Guidelines ahead of full operations per ESAP #4.

Solid Waste Management:

The existing LiBS plant has a waste management and monitoring plan which clearly identifies and classifies all waste streams generated at its plants, quantifies the amounts and describes storage and handling by accredited waste management companies. The majority of the waste produced at plant is recycled. This includes mainly plastics, batteries, packaging waste. Raw material residues are also collected and recycled.

Hazardous Materials and Waste Management:

Hazardous materials are handled through strict procedures where needed. SK Poland has adequate procedures for the proper handling of hazardous materials including Material Safety Data Sheets in local languages, labeling, personal protective equipment, spill containment, and fire prevention equipment.

The above ground tank farms for MC and oil meet good international industrial practices with secondary containment which is well maintained. All hazardous wastes generated at the plants are classified and temporarily stored at the plants until they are handled to accredited companies.

SK Poland plant is in established industrial area located away from the residential area. Moreover, the plant complies with applicable environmental and OHS related permit requirements which facilitates adequate community health, safety and security. Regular emergency response drills are conducted to test the preparedness of the company's emergency response teams, as required, such drills are conducted in collaboration with neighboring industrial units or the industrial zone authorities.

Unarmed security service is provided by third-party contractors with 8 employees, predominantly responsible for access control, asset protection.

Stakeholder Engagement:

SK systematically analyzes its stakeholder structure and views the good relationship with key stakeholders as a benchmark of corporate success. Employees, shareholders, labor unions, non-governmental organizations (NGOs); and suppliers are among the key stakeholders. SK has stakeholder engagement plans to reach out to all its respective stakeholders including all subsidiaries. Communication and stakeholder engagement are managed by the corporate team.

All stakeholders may report an incident/concern via email or telephone number provided on http://eng.skinnovation.com/esg/sc.asp. SK discloses its environmental and social performance through annual sustainability reports aligned with GRI-G4 standards.

Contact Person: Taejun (Ted) Sim

Company Name: SK hi-tech battery materials Poland

Address:  Innowacyjna 2, 42-520 Dabrowa Górnicza, Poland 

Email: tjshim@sk.com

Phone:   +48-539-011-701