Identification of E&S Risks and Impacts.
GXYX identifies and manages E&S risks and impacts associated with its pig farm and feed mill operations through compliance with applicable Chinese standards and E&S regulatory permits. The company has also developed an African swine fever (ASF) infection risk management as part of the company’s iron barrel biosecurity initiative, including their contractors. The company’s contract farm management includes siting selection criteria for potential farms, E&S risks and impact identification and management practices. The company’s performance-based E&S requirements also include IFC PS and relevant sections of the WBG EHS Guidelines (General and Mammalian Livestock Production). Environmental and Social Impact Assessment (ESIA) and public consultations are conducted as required by local regulatory requirements. GXYX received approvals from the local Environmental Protection Agency (EPA) for the additional facilities targeted by this investment in March 2016.
E&S management systems and programs.
GXYX adopted and implemented EHS policies and an ESMS at the corporate level as part of the previous ESAP agreed upon with IFC. This ESMS is aligned with IFC PS1 requirements and applied to all its subsidiaries and its 1,000 contract farms. GXYX has been certified with ISO 9001 (Quality) and ISO 14001 (Environment) management systems in 2017. The company also received Chinese Good Agricultural Practice (GAP) certificate since 2014 for its pig farming operations. The certificates cover the facilities under this project and confirmed to be effective as of February 2023. The corporate ESMS includes EHS policies and Manual of Standard Operations Procedures (SOPs), including among others: (i) Environmental and Occupational, Health and Safety (OHS) risk identification and assessment, including biosecurity; (ii) emergency preparedness and response; (iii) monitoring and reporting; (iv) internal audit mechanism. All EHS and HR policies and procedures are available on GXYX’s IT based information system and accessible to all employees and applicable to contract farms.
Organizational capacity/competency.
GXYX established corporate/facility-level Environmental Protection Unit (EPU) composed of 140 staffs, including 20 manager level positions, which oversees the effective implementation of the corporate EHS policies, risk management and quality control at all the operations, including contract farms. Each pig farm has one dedicated EHS officer in charge and more EHS officers are allocated depending on the size of the farm. EPU’s function is responsible for the ESMS implementation during operation phase including the monitoring of E&S parameters outlined in the WBG EHS Guidelines for Mammalian Production: wastewater (pH, COD, BOD, ammonia, Suspended Particulates, and total nitrogen and phosphorous); surface and ground water (pH, COD, BOD, ammonia, total phosphorous, and fecal coliform); dust and noise level at feed mills; and OHS (fatalities, non-fatal injuries, lost workdays and vehicle collisions). EPU ensures that all project buildings implement their specific SOPs in line with corporate EHS policy requirements and provide EHS training to all the employees. GXYX conducts environmental, safety, and fire inspections every quarter, and no major E&S issues have been reported for the project facilities, as of February 2023.
Emergency Preparedness and Response.
As part of its corporate E&S risk management, GXYX has developed an emergency preparedness and response procedure for its feed mill operations and preparedness plans exist for different scenarios including fire, dust explosions, vehicle collision, accidents related to work, describing processes and decisions applicable to the project. The roles and responsibilities for various teams responsible for evacuation, rescue, first-aid etc. are clearly defined. Similar procedures for pig farming operation are also in place, covering emergencies related to fire, physical injuries/fatalities, food safety and contagious disease outbreaks. Fire drills and safety training are conducted, as required per regulations, and implemented at every project site.
EHS Monitoring & Reporting.
GXYX has established a corporate monitoring and reporting E&S dashboard, including Key Performance Indicators (KPIs) – e.g., lost-time accidents, labor compliance (working hours, overtime payment, grievances), energy and water consumption/efficiency, wastewater quality, surface/underground water quality, workplace dust and noise, solid and hazardous waste management, animal welfare – and monitors all its operations against these, during construction and operation including contract farms. KPI and annual targets are set against regulatory limits and WBG EHS Guidelines and reviewed monthly by the EPU at corporate and operation-level. All incidents are discussed in monthly meeting. EPU undertakes a root cause analysis and implements corrective actions. Annual environmental monitoring report is submitted to local environmental protection bureaus which are aligned with local regulatory and WBG EHS Guidelines. Monitoring parameters and frequencies are set out in the approved ESIA for all facilities. The company conducts periodical internal EHS audits and receives a third-party audit in relation to worker’s occupational safety protection.
Supply Chain Risk Assessment and Management.
GXYX’s pig farms are supplied from its own feed mill products. These feed mills source corn, soybean meal and other feed grains, from a variety of local and international suppliers. Corn is main feed ingredient and is mainly purchased from large grain trading companies, such as COFCO and imported mainly from United States and Ukraine. Feed grains and soybean meal are mainly imported from the United States (sorghum) and from France, Australia, and Ukraine (barley) and from Brazil and the United States (soybean meal).
The company has a centralized procurement management system coordinated with subsidiaries and has service and supply procurement control procedures and performs a comprehensive assessment of the suppliers, including their raw materials source, quality control systems and some OHS risks. GXYX has updated its supplier assessment procedure to include E&S related screenings covering PS2/PS6 risks and impacts. GXYX introduced procedures to ensure that primary suppliers within its sourcing operations are not exposed to PS2/PS6 issues, such as a supplier site inspection and review guideline for raw material suppliers.
Going forward, GXYX will establish a Supplier Code of Conduct (CoC) to prohibit forced, or child labor and significant occupational health and safety risks; and potential conversion of natural/critical habitats in its sourcing operations including information on persons in charge of CoC enforcement, means to implement the CoC including monitoring and reporting mechanisms as well as key performance indicators (KPIs) to verify implementation effectiveness. (ESAP#1).
As per ESAP #2, by 2027, the company will achieve a sourcing target of 15% of GXYX’s total annual soymeal procurement volume coming from soymeal suppliers which will meet IFC PS2-PS6 supply chain requirements. GXYX will provide verifiable evidence based on disclosed information from primary soy suppliers.