This is a Category B project according to IFC’s 2012 Environmental and Social Sustainability Policy. The proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible that can be avoided or mitigated by adhering to recognized Good International Industry Practices (GIIP).

Key E&S risks and issues applicable to this investment are: (a) implementation effectiveness of Kirene’s EHS, HR and Supply Chain management systems in its existing operations; (b) sustainability of the company’s water resources and availability of technical capacity/competency to manage them adequately; (c) adequacy of HR/Occupational Health and Safety (OHS) management systems for assurance of fair and safe working conditions for direct/seasonal workers and contractors, including Gender-Based Violence (GBV); (d) recycling/reuse of plastic waste generated during and after consumption of products; (e) wastewater management; (f) traceability and E&S risk screening of third-party suppliers in origins.

E&S Policies. Kirene adopted a set of policies documented in its ‘E&S Charter’. The policies commit the company to promote environmental protection, workers OHS protection, neighbouring community’s welfare, responsible supply chains, energy and resources efficiency, sound waste management, and fair recruitment and employee training. The food safety policy underscores Kirene’s engagement and strategy to control allergenic risks and cross-contamination in final products in order to reduce customer complaints related to foreign bodies in the product. The policies are operationalized through management plans and detailed procedures specifying roles and responsibilities at different functions to fulfil the company goals.

Identification of E&S Risks and Impacts. Kirene has implemented an E&S risk management procedure as part of its Integrated Management System. The company’s risk register includes information from the ‘Hazard Study’ and the E&S Impact Assessment (ESIA) submitted to local Authority as per regulatory requirements, from findings of internal/external inspections and audits, and from management or stakeholders’ reviews. Given that the new production lines are an expansion of existing processing capacity, the E&S risks are not expected to change significantly, except for the risk of water extraction.

The company’s assessment of groundwater availability and quality conducted in 2016 indicated that associated risks and impacts were high due to water vulnerability in the Diass region. A detailed water protection plan was developed with relevant recommendations to address the gaps; however, it has not been satisfactorily implemented to date, leaving critical recommendations unaddressed. Kirene will seek a suitably qualified consulting firm to conduct a specific risk assessment of impacts on groundwater resources due to water abstraction and wastewater discharge, as per agreed Terms of Reference (ESAP#1). The study shall include (i) detailed water balance (ii) audit of water consumption, (iii) evaluation of the ratio between water intake, net production and effluent discharge to assess Water Use Ratio (WUR), (iv) quantification of water consumption in the different processes of the plant, (v) evaluation and identification of opportunities and investments to optimize/reduce water use in an economic way and improve the WUR.

Kirene has further developed an E&S risk assessment procedure which is part of its IMS. Risks associated with operations and assets are assessed and tabulated in a risk register, and enhancements or mitigation measures are proposed accordingly. Kirene will ensure risks associated with the new project namely, the installation and operation of the solar panels and of the new production lines, are identified, assessed and documented in accordance with the existing risk management procedure (ESAP#2).

E&S Management Systems. As an existing IFC client, Kirene has rolled out an Integrated Management System (IMS) which includes an E&S Management System (ESMS) and a Food Safety Management System (FSMS) aligned with IFC PS1 requirements. The ESMS has been designed and continually upgraded in fulfilment of the previous projects’ E&S Action Plan (ESAP) as per investment agreements. It is operationalized through documented E&S policies, risks and impacts assessment and mitigation, organizational capacity and training, Environmental and Occupational Health and Safety (OHS) plans and procedures, emergency procedures, training programs, contractors’ requirements, E&S monitoring and reporting, and management review. The FSMS is designed and implemented with the support of external consultants and was certified in accordance with ISO22000 and HACCP (Hazard Analysis and Critical Control Points) requirements in December 2021. The FSMS includes documented policies, risk assessments, monitoring records and procedures for microbiological and physico-chemical controls to ensure the safety of foodstuffs throughout the supply chain. Kirene’s monitoring and reporting practices and engagement with different stakeholders is found at the company’s website https://kirene-groupe.com/impacts-et-engagements/politique-rse/. The IMS was found to be mature and compliant with IFC PS1 requirements.

E&S Management programs. Kirene has developed and implemented E&S management plans and standard operating procedures (SOPs), as part of its ESMS, as required under previous IFC’s investments. The plans are primarily related to the management of human resources, OHS, fire safety, food safety, waste, supply chain, air emissions, water and energy efficiency and emergency response. Staff are trained on procedures relevant to their areas of activities. Most of the plans were noted to be commensurate with the scale and E&S risks and impacts of the current operations. Going forward, Kirene will update its existing E&S management plans and implement additional SOPs, as may be deemed applicable, based on the findings of the additional risk assessment (ref. ESAP#1) to mitigate additional risks associated with the proposed investment (ESAP#3).

E&S Organizational Capacity. Kirene has an E&S team reporting to the Managing Director. Relevant E&S responsibilities are embedded at key positions with sufficient authority to implement the ESMS and FSMS. The plant manager is designated as the ultimate responsible for E&S compliance at the production site. His oversight extends to resource efficiency, water management, waste reduction, OHS, GHG emissions, wastewater management and sustainability reporting. The EHS Officer is tasked to operationalize E&S procedures and works in collaboration with the Audit and Certification Officer, both reporting to the Quality Health Safety and Environmental (QHSE) Manager. The corporate social responsibility (CSR) officer is in charge of stakeholders engagement and corporate social responsibility programs. The HR officer reporting to the plant manager oversees working conditions and labour compliance and training programs for employees and contractors. He coordinates staff E&S induction, OHS training, Food safety training as per ISO 22000 requirements and task-based training. The E&S team is adequately experienced to meet IFC PS requirements. Going forward, based on the findings of the additional water risk assessment (ref. ESAP#1) to ensure sustainable management of water resources, Kirene will hire and maintain a suitably qualified performance specialist for its overall operations who will also be responsible for the implementation of the water protection plan (ESAP#4).

Emergency Preparedness and Response. Kirene has documented an Emergency Preparedness and Response Plan (EPRP) as part of the Internal Operations Plan. The plan describes potential emergency scenarios at the plant and specifies responsibilities, measures and resources necessary. Scenarios anticipated include fire, explosion, accidental environmental release or spills, severe accidental injuries. Routine emergency drills are performed at the facility for effectiveness. The plan was validated by local authorities and was found to be in line with national law requirements. The production site emergency system was upgraded as part of the life & fire safety (L&FS) recommendations to comply with WBG EHS Guidelines. The system includes fire hydrants, automatic sprinklers, pumps, smoke and heat detection, fire extinguishers and fire alarm systems with dedicated water storage and emergency exits. Separate alarm systems have been installed for ammonia leak detection in the refrigeration system. The systems were noted to be adequately maintained and are audited annually by external experts.

E&S Monitoring and Review. As part of its ESMS, Kirene has adopted a structured EHS monitoring and reporting system on environmental, HR, OHS and social impacts of its operations. Monitoring parameters, frequencies and methodology are defined by the ESMS, and data is stored in a centralized database for periodic reporting. Key performance indicators (KPIs) are defined for workplace safety (including lost-time injuries frequency rates), water quality and consumption, energy efficiency, solid and hazardous waste, noise levels, OHS training, evaluation of service providers and implementation of corrective actions with respect to internal and external audits. An Annual E&S Monitoring Report (AMR) is submitted to IFC, benchmarking Kirene’s E&S performance to local requirements and applicable WBG EHS Guidelines (General and Sector specific for food and beverage processing). Data reviewed during this appraisal indicate that Kirene needs to improve its tracking of water use ratio (ref. ESAP #1). The EHS officer schedules E&S compliance inspections jointly with relevant section responsible, or with the plant manager. External inspectors from the Regional Division of the Environment and Classified Establishments of Thies (DREEC/THIES) conduct periodic external audits of the facility. The municipality fire department conducts fire safety technical inspections. FSMS audits are undertaken by external specialists per ISO 22000/HACCP certification requirements. Going forward, based on the findings of the additional risk assessments referred to under ESAP#1 and #2, the company will augment the E&S objectives and KPIs and incorporate them to the current E&S monitoring and reporting (ESAP#5).

Supply Chain risk assessment.  Kirene’s E&S risk assessments highlighted the screening of labour practices in the supply chain as a key risk. The company subsequently developed and signed a ‘Supplier's Code of Conduct’ with raw milk and mangoes suppliers, explicitly prohibiting child and forced labor in their operations, consistent with PS2 requirements and mainstreamed it in purchase agreements. These agreements were initially signed with 8 commercial farms and 2 cooperatives in 2019-2020 but only pursued with 5 of the farms as of 2022.

A biodiversity screening was performed on the regions in which the cooperatives are located given that the company did no longer retain individual farmers locations. The screening found that cooperatives are in regions with high range rarity but there is no evidence of recent significant conversion. All the farms are located within modified habitats away from areas likely to support Key Biodiversity Areas (KBAs) values (wetlands, lakes, shorelines). However, one farm appears to be close but outside a Protected Area (PA) and another one overlaps a Key Biodiversity Area (KBA). Kirene shall (i) require the concerned farmer to confirm avoidance of overlap with Senegalese authorities; and (ii) integrate good practice requirements into their supply chain and supplier code of conduct that requires the screening and avoidance of farms that required conversion of natural habitat and/or overlap PAs or internationally recognized areas (ESAP#6). These suppliers were further trained by IFC Advisory team on Good Agricultural Practices (GAPs) under the IFC-Kirene Dairy Advisory program implemented in 2019-2020 and were sensitized on control procedures for raw milk hygiene, quality safety and the screening of labour practices. Enforcement of the Code is monitored by Kirene’s quality assurance technicians based at collection centers. Kirene’s UHT milk is based on a blend of powdered (70-80%) and raw milk (20-30%). Powdered milk is purchased from suppliers approved by Candia, an ISO 9000 and FSSC 22000 certified company, promoting environmental sustainability. For the larger portion of fruit juice produced based on concentrates, nectar and fruit concentrates are sourced from Dohler, a German based global producer, which maintains Fair Trade certification and promotes decent working conditions as per ILO Conventions. Mango pulp is supplied from Comafruit in Mali, which sources raw mangoes from traders and farmers committed to maintain Global Gap certification. Sugar is sourced from Cosumar, a Morocco based firm, that retains food safety certification (FSSC 22000) as well as environmental and safety systems certifications (ISO 14001 and ISO 45001). Packaging materials are purchased from company approved suppliers.

Kirene will enhance its supply chain management system by (i) requiring a legal representation of each major raw materials supplier by signing off on the Supplier Code of Conduct, (ii) developing contractual provisions and enforcing them by its supply chain team, through periodic audits (ESAP#7). For the solar project, Kirene will source solar panels via an energy supply contract with a French-based supplier (CVE). At the time of appraisal however, this arrangement was not yet finalized. To mitigate the global concern around forced labor in the solar equipment supply chain, Kirene will ensure that the solar PV supplier selected is signatory to the Solar Energy Industries Association’s Forced Labor Prevention Pledge and include specific contract language in the procurement of the solar equipment (ESAP#8).                                             

Human Resources (HR) Policies and Procedures. Kirene has documented HR policies and an internal regulations manual that apply to all employees and were noted to be consistent with PS2 requirements. The policies were improved as required by IFC under the previous loans agreements, to include provisions on non-discrimination and equal opportunity, safe working conditions, prohibition of forced labor and child labor, sexual harassment and to set up a grievance mechanism accessible to the entire workforce. Kirene mainstreamed the same clauses in agreements with its contractors.

Working conditions and terms of employment. Kirene’s workforce is composed of 484 direct workers, including 454 permanent (94%) and 30 temporary (6%) workers. This includes 96 women (20% of the total workforce), of which 11 hold supervisory and managerial positions. There is a pool of 200 daily workers hired from surrounding communities for casual tasks, mainly for truck loading/unloading. Permanent workers have written contracts established in accordance with local labor regulation, which specify their entitlements and obligations, including working hours, probationary period, remuneration package and leaves. The lowest salary – for permanent and temporary workers– is about 50% above the minimum wage in Senegal. Workers are informed of HR policies and procedures upon appointment. Under the new project, 25 new positions will be created and a limited number of experts from the equipment supplier will supervise the installation of the new equipment.

Kirene does not work with labor agencies. Daily workers are hired and managed directly by the HR department; they can find their names, schedules, tasks and working hours posted weekly on the notice board at the main gate, however they do not have a written record detailing their entitlements. The plant operates 24 hours a day and stops only for scheduled maintenance or when required. Operational staff are organized in 4 teams, alternating on 8 hours rotational shifts and running seven days a week while allowing sufficient rest days for each worker. Administrative staff work 40 hours a week.

There is a control system at the main gate to verify identity, including contractors and daily workers, and to monitor attendance and overtimes. Workers (including daily staff) have access to an onsite clinic permanently open, and to staff shuttles; they also receive meal tickets to access the canteen and are entitled to participate in company events.

To ensure employees are clear on their entitlements, Kirene will (i) ensure that all employees, including daily/casual workers, sign off on their duties (work schedules, security contributions, etc.) and their benefits (access to the canteen and subsidy of meal tickets, access to company shuttles, etc.); (ii) implement a payslip system for daily workers compliant with PS2 requirements (ESAP#9).

Non-discrimination. Kirene’s HR policy on non-discrimination and fair treatment commits the company to treat all employees fairly, with dignity and respect, and ensure there is no discrimination, including no-gender based discrimination in recruitment, remuneration, access to training, promotion, dismissal, or retirement.  Kirene has committed to avoid and reject the abuse of authority and any other type of physical, psychological, or moral harassment, and any other behavior that could create an intimidating, offensive or hostile working environment.

Protecting the Workforce. The HR policy stipulates that no child labor or forced labor will be tolerated in Kirene’s operations. This requirement is enforced by security at the main gate access control.

Workers organization. Kirene’s policy encourages workers to associate with or join workers’ organizations. A labor union composed of 10 delegates elected by the workforce is in place. This organization acts as a channel for the voicing of employee grievances to management. It is affiliated with the national union of food industry workers of Senegal. Delegates meet Kirene’s HR department and senior management once a month or when needed.

Workers grievance mechanism. Kirene has documented a workers grievance mechanism in line with its HR policies, as required by IFC in previous investments. The grievance mechanism allows for submission of anonymous grievances and is available to contractors’ workers who are also included in related training and awareness campaigns conducted by the HR department. During the project review, IFC was alerted by a complaint voiced by a group of daily workers accusing the company of failing to provide on-time salary payment and preventing workers' access to lunch on company premises. Kirene argued that this situation was a controversy created by daily workers not fully aware of entitlements granted by the company. To prevent reoccurrence, Kirene will implement the recommendations articulated in ESAP#9 above.

Occupational Health and Safety. In fulfilment of ESAP requirements from the previous IFC’s investments, Kirene formulated OHS policies and implemented an OHS management system to address key risks and hazards at its operations. OHS SOPs have been developed and are continuously updated based on hazard identification and risk assessment conducted under the coordination of the EHS Officer. Incidents are identified, investigated and categorized then tracked in the OHS corrective actions register. Personal protective equipment (PPE), such as hearing protection, uniforms, masks, anti-slippery shoes, hygienic caps or gloves are provided to workers according to their assigned workplace. A workplace noise measurement program is implemented at selected workstations to confirm noise levels as per WBG EHS Guidelines. Regular training is provided to employees on safe working SOPs, including hazardous material handling, PPE usage, machine safety, accidents reporting and food safety requirements as per HACCP/ISO 22000. An EHS committee established and included the plant manager; it holds monthly meetings to review safety issues and improvements and is involved in accidents investigations under the EHS officer coordination. Workers can access the onsite clinic in case of injury and are provided with health checks at scheduled periods. Further welfare measures for workers include canteens and change rooms with sanitary fittings.

Kirene recorded zero fatal accidents and 4 Lost time incidents (LTIs) in 2021, resulting in a Lost Time Injury Frequency Rate (LTIFR) of 6.25, considerably lower than the previous years’ performance of 9.25, albeit still higher than the international reference value for the food and beverage sector during the same period (3 to 4). In case of any accidents or work-related illnesses, Kirene is required to notify the Ministry of Labor. Kirene will increase its OHS awareness training and strengthen OHS management measures consistent with EHS Guidelines and GIIP to reduce the number of accidents occurrences (ESAP#10).                                               

Energy use and greenhouse gas emissions. Kirene uses electricity from the national grid. Kirene monitors its gross energy consumption for the whole plant and recorded a total energy consumption of 10,284,171 kwh in 2021. The company implemented a consumption reduction program since 2020, which started by replacing all the old tube strips with 15W LED lamps. The acquisition of solar panels with a capacity of 1.8 MW under the proposed project, is expected to cover energy demand for the proposed expansion while providing 25% of the total power needs. 

The project annual GHG emissions will amount to approximately 8,123 tons CO2e which is below the WBG EHS Guidelines reporting threshold of 25,000 tons CO2e. Key contributors to Kirene’s CO2 emissions include the manufacturing process and energy consumption. In anticipation of further emissions increase associated with the proposed expansion, the company has adopted the plan to install one new RGB line instead of PET bottles lines and will further invest in climate related capex for EDGE Green Building certification. The solar panels system is also expected to reduce the company’s carbon footprint by 313 tons of CO2e per year.

Air emissions. The main sources of air emissions are the boilers used to produce steam. Kirene has implemented a preventive maintenance routine per manufacturers’ instructions for these equipments. This practice optimizes efficiency while reducing air emissions. The company considers that stack air emissions from these sources are minimal and does not track their emissions considering the size smaller than 3 MWh and the frequency of usage.

Water Supply and Consumption. Water is a critical resource for Kirene as it comes both as raw material and a commercial product. The exclusive source of supply for the company is groundwater abstracted from three on-site bore wells pumping respectively 40m3/hour, 15m3/hour and 55 m3/hour. Withdrawal permits specifying maximum quantities allowed to be extracted from each well were secured from the Senegalese Ministry of Agriculture and Hydraulics. A fourth bore well is being tested and expected to enter into production with the proposed expansion. In 2016, the Company appointed an external Consultant who assessed the source water vulnerability and prepared a water protection plan. The study confirmed adequate water resources availability and made recommendations for long term growth including the implementation of a rigorous water monitoring program for adequate water balance. At the time of the present appraisal, water requirements for the expansion have not been determined and Kirene had not implemented the water protection plan satisfactorily. The company records its gross water consumption for the facility but does not track groundwater withdrawal and water consumption within the process. In 2021, Kirene consumed 276,805 kl of raw water for the total production. An accurate water usage ratio (WUR) for each product could not be calculated as Kirene had not finalized the installation of water meters in each production line. This lack of an accurate water accounting is likely to result in overconsumption or wastage. Kirene will commission a specific risk assessment for proper scoping of the water usage risk (ref. ESAP#1 and #2). The company will also install water metering equipment in each production line, from source (bore wells) to sub-processes and the inlet and outlet of the wastewater treatment plant to monitor its water efficiency on a monthly basis and benchmark its efficiency against applicable WBG EHS Guidelines and GIIP (ESAP#11). Performance will be reported in the AMR.

Wastewater. Kirene’s facility generates approximately 600m3 of wastewater per day including process effluent and domestic wastewater which is sent to the wastewater treatment (WWT) plant. An 800 m³/day capacity WWT plant was constructed on-site in 2017 in response to IFC’s ESAP requirements for upgrading the previous plant which was determined to be largely undersized. This new WWTP includes a pumping station, an aeration tank, a deaerator, and a clarification tank. Treatment includes screening and grit removal, sedimentation, biological treatment, sludge digestion and disposal. Kirene does not expect a significant increase of wastewater volumes and will keep using the same facility for the expansion project. The treated effluent is discharged in the open greenbelt downgradient of the WWT plant inside the premises, and dried sludge is distributed to farmers as a fertilizer.

Kirene monitors treated effluents quality, including Chemical Oxygen Demand (COD), Biochemical Oxygen Demand (BOD) and Total Suspended Solids; however, results indicate that although these parameters are compliant with Senegalese standards, BOD values constantly exceeded the WBG guidelines (30mg/l) over the last 2 years. Kirene will (i) investigate with its WWTP supplier the suitability of the current operating parameters; (ii) implement the recommended measures to ensure that effluent discharge meets WBG EHS Guidelines; (iii) redesign and expand the WWTP greenfield for better absorbing the treated effluent of the WWTP to avoid surface water and groundwater contamination due to wastewater runoff / infiltration (ESAP#12).

Waste. Kirene has documented a waste management procedure that characterizes its waste by source, type, quantity, potential use or disposal, and presents pollution prevention opportunities. Key measures taken manage plastic waste include banning the manufacture of plastic straws for drinking and adopting water RGB line as part of the proposed project. The company is actively promoting plastic waste recycling to reduce PET bottles waste. For plant waste collection, Kirene has contracted with a licensed operator who collects and sends plastic waste to its recycling facility in Dakar for production of new plastic products, such as chairs, stools or tables. Beyond its production site, Kirene has likewise implemented a plastic waste collection and recovery program, focused on PET bottles, in collaboration with its products distributors and with environmental NGOs. Consumers are encouraged to drop off empty bottles at designated collection points where they are collected and sent for recycling into alternative materials that will be reinserted in the manufacturing chain of new products (garbage cans, trash cans, etc.).

Hazardous waste. Kirene’s biomedical waste generated from the onsite clinic is kept in storage boxes then sent to a central incineration facility. Oil and oily rags are kept in plastic containers then collected by the same accredited waste dealer for adequate disposal at their approved facility. Used oil, batteries, ink cartridges, electrical and decommissioned electronic equipment are kept in dedicated bins and locked in a confined area before being taken for recycling or to a licensed treatment / disposal facility. Based on the measures undertaken above, the company is judged to be compliant with PS3 requirements.

Hazardous material. Kirene has developed a hazardous material handling and storage procedure applicable to its entire operations, which provides for the training of workers exposed to such materials. The main hazardous materials stored at the facility include fuel, lubricants, chemical reactants and detergents used in the cleaning process. The cleaning in place system (CIP) minimizes the use of chemicals and water. Hazardous materials are stored safely and handled in a dedicated room demarcated by with a secondary containment wall and suitably compartmented for chemicals segregation. A central hazardous materials register is available at the plant, products containers are labelled and equipped with drip pans. There are emergency showers in critical section and workers conduct emergency response drills. During the site appraisal, ‘Material Safety Data Sheets’ (MSDS) for laboratory reactants and hazardous materials were visible on products used, and workers handling them were adequately protected and trained on emergency procedures                                              

Road traffic safety. Kirene’s facility is located in a peri-urban neighbourhood with a paved access road connecting to the airport highway at one end and leading to the Kirene village 2.8 km away at the other end. The only access gate is situated along the eastern boundary and the rest of the plant is well demarcated with masonry boundary walls. As such, potential adverse impacts from its operations are limited to induced increased traffic which does not represent a significant risk for the local population given there are multiple routes options for the villagers. However, distribution centers for Kirene products are located in the city of Dakar where traffic is heavy and risks of accidents high, with transport of finished goods and personnel outsourced to a local contractor. The risk was highlighted during previous investment and Kirene was required to include clauses on safe transportation within its contracts with service providers. The company developed and implemented since 2016 a safe driver and transport safety training program for third party haulage contractors with yearly refresher sessions provided by expert consultants. The contractor is also required to ensure regular maintenance of vehicles and appoint only drivers with a valid license. IFC found Kirene’s current transport practices to be aligned with PS4 requirements.

Security personnel. Plant security is outsourced to a local contractor, with five unarmed guards found on the premises at any one time. As agreed under the framework of the previous IFC’s investments, Kirene included human rights compliance clauses in the security contract and requires the company to screen its personnel’s employment background and other available records, including implication in past abuse or any criminal record and restricting employment or use of any individuals or companies that have abused or violated human rights in the past. Guards are instructed to exercise restraint and caution, clearly prioritizing prevention of injuries or fatalities and peaceful resolution of disputes with communities. They are also required to report any use of physical force to Kirene for further investigation. The plant manager supported by the HR officer is responsible for enforcing and reporting compliance with these requirements.

Food safety. Microbiological testing of bottled water is conducted as determined by the relevant FSMS procedures in compliance with ISO 22000 and HACCP requirements. Food safety control is equally applied for bottled water, UHT milk, juice or for CSD production.

Infrastructure and Equipment Design and Safety. Kirene maintains a certification of structural and fire safety of its facility audited by a registered fire safety professional. As required under the previous investments, the company appointed a fire safety consultant to advise on adequate measures to improve its infrastructure safety and who inspects the system annually. The system includes automatic fire sprinklers, fire hoses cabinets with alarms and smoke detectors, which were installed in 2019.                                              

Since the initial meetings organized with Diass and Kirene communities before the commissioning of its operations, to discuss land use and employment opportunities, an ongoing relationship has been established with these communities to allow them to voice their needs/suggestions. Aligned with its social engagement policy and its corporate and social responsibility (CSR) program, Kirene has rolled out a robust community engagement program, including initiative such as the free distribution of milk in schools. Each week, the program distributes milk to pupils in 168 schools in Dakar and its suburbs. Kirene has built a health center and water borewells in villages, provided books, and supports vocational trainings and NGOs. It has notably built a maternity clinic in the town of Diass for its employees and surrounding communities; and is still supporting part of the clinic’s operating expenses. The sustainability report is published annually at https://kirene-groupe.com/en/impacts-and-commitments/social/. Kirene has implemented procedures to capture customers and worker’s complaints as required under previous IFC’s agreement, there is however no dedicated procedure to receive and resolve grievances from the general public and local communities. To strengthen and formalize its stakeholder engagement, the company shall update the community grievance mechanism in line with PS 1 requirements for addressing community grievances arising out of company’s industrial operations and local community development projects (CSR). Community concerns and grievances about the company’s E&S performance including gender-based violence & harassment aspects shall be resolved using such mechanism (ESAP#13).