The proposed investment is a Category B project in accordance with IFC’s 2012 Policy on Environmental and Social Sustainability. E&S risks and impacts from Category B project are limited, site-specific, and can be readily addressed through accepted mitigation measures described in this document and the attached Environmental and Social Action Plan (ESAP). Key E&S issues associated with this investment are: i) existence and effectiveness of Entobel’s Environmental, Health and Safety (EHS), Human Resources (HR) and Food Safety (FS) management systems, including Environmental Permitting and mitigation measures for solid, liquid (organic-waste/wastewater), and packaging waste; ii) organizational capacity for implementing, monitoring and reporting on company ESMS; iii) labor and safe working conditions of direct employees, effective management on Occupational Health and Safety (OHS) standards (including third party employed workers); iv) Emergency Preparedness and Response (ERP); v) supply chain E&S risk management; vi) monitoring of EHS parameters (air emissions from process/boilers), effluents; vii) water and energy use and efficiency; and, viii) stakeholder engagement/community grievance mechanism.

Environmental and Social Assessment and Management System: The Dong Nai facility is required an ESIA and an environmental permit in accordance with the Vietnam Law on Environmental Protection (LEP) 2014, ref. feed mills (which Insect Protein and Oil production facilities are classified as) with an annual capacity of 1,000 tons or greater. The Company has yet to obtain its environmental permit as the land use designation for this factory is in the process of being re-defined with the local authority. Upon resolution, the local authority will conduct an Environmental Assessment or issue an Environmental Permit. There was an incorrect categorization of land for the Dong Nai facility as agricultural land instead of industrial land, due to which, they were operating the Dong Nai plant without an environmental permit. Proof of construction and completion permits for the building have been provided as well as the land use certificate for the facility. The land categorization issue has been resolved in Jan 2022. Regarding environmental permit requirement, the Dong Nai facility is required to have an environmental registration in accordance with the latest Vietnam LEP (2020). Entobel has submitted an Environmental Registration to the People Committee of Tan An Commune in accordance with LEP 2020. However, it does not include an environmental monitoring plan (EMP) for ambient and point source air emissions, wastewater discharge or monitoring criteria as applicable. As set forth in ESAP#1 Entobel shall develop an official environmental monitoring plan (EMoP) for the Dong Nai Facility Operations, in accordance with the Environmental Registration and in compliance with IFC PSs/WBG EHS Guidelines to address all E&S risks, applicable to the operations including standards for key environmental metrics, such as wastewater, ambient and workplace noise, air quality and heat, lighting, hazardous and non-hazardous and domestic waste management. It is noted that - as aligned to Vietnam’s Department of Natural Resources and Environment (DONRE) expectations, Entobel has self-initiated an environmental monitoring program with the focus on ambient workplace monitoring (workplace air quality) at the Dong Nai Facility (by their own volition) and used certified environmental monitoring consultants (ref. ESAP#4 below).

In accordance with the Vietnam 2014 Law on Environmental Protection, Entobel has an approved ESIA for the planned Vung Tau Feed Manufacturing Plant with the approval decision No. 96/QD-BQL dated 16 June 2021. The ESIA based on anticipated 10,000 MT powder production per annum highlights: i) main impacts to be derived from domestic wastewater/municipal wastes; ii) ambient air from dust exhaust and odors, including storage of by-products, BSF farming (odors from larvae rearing) and processing, dust from substrate, and warehouse storage; iii) boiler stack air emissions, ambient air quality and noise. The ESIA includes a list of mitigation measures in terms of equipment to limit and control risks, including air filtration systems to recover dust material from the powder production line. The document specifies minimum standards for monitoring of workplace/ambient parameters consistent with an Agri-Product feed mill facility and WBG EHS guidelines.

Policy. In addition to food safety certifications (e.g., ISO22000 and HACCP), Entobel’s E&S policy is enshrined in its Code of Conduct (copy dated July 31st, 2020) of the Dong Nai Entobel Co. Ltd. This Code clearly defines the company commitments to adhere to International Labor Organization (ILO) standards for its and its business partner operations (especially related to potential risks from forced or child labor). This document defines the business commitment to comply with Vietnamese environmental regulations, reduce waste, improve efficiency, operate to self-sufficiency (in terms of water and energy consumption), and zero waste. A Code of Business Conduct and Ethics (version dated April 19th, 2022) of the Dong Nai Entobel Co. Ltd. includes a commitment that requires all employees to comply with all laws including environmental and safety laws applicable to the Company in all jurisdictions where it operates. In alignment with this Code, Entobel has recently developed an overarching Environmental and Social (E&S) policy which includes policies for environment, occupational health and safety (OHS), labor and human rights, and community health, safety and security. These policies are to declare the core value in the management of the company is environmental protection and social responsibility. Entobel has stated its commitments but mainly to comply strictly with Vietnam’s applicable legal requirements and with other requirements to which the company subscribes. It is required that there have to define the other requirements to specifically include IFC PSs, relevant WBG General EHS Guidelines, supporting standards and/or Good International Industry Practice (GIIP), including risk-based approaches for OHS risks, particularly explosive dust related risks. The labor/human rights policy should include references to eliminating all forms of child or forced labors within the primary supply chain of Entobel through applying a risk-based approach to evaluation of primary suppliers. The scope of labor/human rights policy, including grievance mechanism should expand to include all outsourced or contracted labors. The community health, safety and security should ensure a link to the community grievance mechanism. As set forth in ESAP#2, Entobel shall revise its current overarching Environmental, Occupational Health and Safety and Social (EHSS) policy to include all business operations under the control of the company, be aligned to applicable laws and regulations of the country of operation and be consistent with IFC’s Performance Standards, applicable World Bank Group (WBG) General EHS Guidelines. The policy shall define responsibilities for overseeing and implementing these provisions and be communicated to all levels of the organization and entities Entobel have management control.

Management Programs. Entobel has demonstrated its commitment to food safety and quality assurance management through achieving ISO22001 certification and ensuring quality control on the business outputs and traceability of byproduct sources. This certification includes guidelines on management of by-product inputs, including testing for pathogens and heavy metals. The company commits to reduce energy consumption including use of biomass feedstock boilers, with future plans (Vung Tau facility) to install roof top solar (to the capacity of production facility); reduce water consumption by installing rainwater capture and storage to meet 50% of anticipated production needs with drying systems designed for both water and heat recovery. Entobel has recently developed an EHS management system to guide the overarching environmental and social policy and the above-mentioned commitments/actions. However, there are shortcomings, which required improvements. Environmental policies and management procedures for infrastructure, environmental and pollution prevention and control, dust control, chemical management, waste control, and energy efficiency and renewable energy policy have been developed. As above-mentioned, environmental policies should include the commitment to comply with IFC Performance standards (2012) and relevant WBG EHS Guidelines and expand the scope of the policy to contractors and suppliers where the company have management control. The control procedures for specific environmental aspects (e.g., dust explosion, chemical control) should improve with additional risk assessment,procedural control process in alignment with applicable standards (including relevant WBG EHS Guidelines and GIIP), where appropriate. Labor and human rights related policy and procedures should be improved with focus on additional retrenchment policy/procedure, grievance mechanism with anonymous grievance and channels for harassment issues, appeals process in any disciplinary, performance evaluation, results of the dismissal process, as well as policies for seasonal workers/temporary workers, contractor and supply chain labors. OHS policy and management procedures require additional measures such as general risk assessment framework to determine relevant PPE required, risk assessment for explosive dust from operations, near miss or safety observations reporting, permit to work for high-risk tasks. As set forth in ESAP#3 in accordance with IFC’s PS1, Entobel shall update the Integrated ESMS appropriate to the nature and scale of its operations and commensurate with the level of E&S and OHS risks and impacts for each facility under operation. This ESMS will be consistent with ISO 14001, ISO 45001, ISO 22001, ISO50001 requirements. It will include the following aspects: i) E&S policy; ii) identification and management process of risks and impacts from all operations (including identification of certification and permitting needs for equipment’s/facilities/waste water treatment and acceptable pollutant discharge levels (waste water/flue emissions)) based on local requirements, IFC PSs, and WBG EHS requirements; iii) manual of procedures and work instructions related to the management of E&S issues; iv) management programs, including relevant mitigation measures defined in ESIA studies and/or voluntary standards; v) organizational capacity and competency (inclusive of periodic monitoring and supervision of contractors); vi) training requirements to facilitate the implementation of the ESMS; vii) ERPs, (including procedures for explosive dust risk assessment/mitigation measures); viii) stakeholder engagement plan and community grievance mechanism; ix) supply chain risk assessment and management; and x) environmental monitoring and reporting.

Organizational Capacity and Competency. The company is a small business (60 employees) with three key roles in place for the management of the EHS requirements. These include Human Resources (overseeing OHS issues), Production Manager (overseeing environmental monitoring), and Quality Control Manager (overseeing ISO 22001 and supply chain due diligence checks). The company shall be upscaling with an additional 160 workers in the Vung Tau facility and plans to strengthen its EHS / Sustainability function. Recently, Entobel has recruited an EHS manager to support the implementation of the ESMS (ref. ESAP#3 above), oversee monitoring of key metrics/performance requirements, and support continual improvement in both management system and company operations.

Training. Entobel has developed a Training Policy, which includes core competencies for all workers for OHS, emergency response, first aid, workplace functions, reporting OHS needs, etc. However, there is a need to include a list of core environmental and social trainings for all workers (e.g., core procedures for whistle blowing, internal grievance policy and procedures, code of conducts, etc.) and training frequency. In addition, OHS risk assessments is required to determine training needs. This sets the basis for types of training as well as measures (e.g., PPE) required for each position. Entobel develops annual compliance training plans and provides workers training in basic Human Right/ HR policies/ HSE needs (combination of on job training from supervisors/induction training in basic OHS awareness), and fire safety training (supplied by the local fire and police departments). (ref. ESAP#3 as part of requirements for training).

Monitoring and Review. Aligned to Vietnam’s Department of Natural Resources and Environment (DONRE) expectations, Entobel self-initiated environmental monitoring program for the Dong Nai Facility and assessed workplace parameters, ambient noise and air quality. Entobel has developed a Labor Accident Investigating & Handling Procedure. However, it does not include monitoring of OHS leading/lagging indicators (e.g., Lost Time Injury Frequency Rates - LTIFR), energy, water use and efficiency, nor environmental parameters (on a consistent basis). Although Entobel confirms no wastewater discharge from Dong Nai Facility, it does not monitor discharged domestic wastewater levels (volume/quality) from its existing facilities. (ref. ESAP#3)

Emergency Preparedness and Response: Entobel has in place fire certificates for the Dong Nai Facility and relies on preventative maintenance and good housekeeping to reduce dust accumulation. Entobel has developed an Emergency Preparedness and Response Plan. However, it does not include explosive dust and ERP response. As a feed mill operation, explosive dust risks are always likely to be present. A risk-based approach to assess this risk is to be implemented (ref. ESAP#3). COVID contingency measures were applied in accordance with the national regulations (i.e., temperature monitoring, social distancing, hand washing and mask wearing). The company reported no incidents of COVID infection among facility workers.

Supply chain Risk Assessment: Entobel sources by-products from food and beverage manufacturers under long term supply contracts. As quality and volume are priorities’ issues, Entobel sources from large corporates with food safety systems and good public image for environmental stewardship. This is considered by Entobel to provide a level of comfort that supplier labor standards are aligned to prevailing national Vietnamese labor regulations. As it is sourcing manufactured/semi processed by-product from Food and Beverage (F&B) entities, consideration must be made on the risk management of the supply chain. Entobel has a minimum standard for its suppliers within its Code of Conduct. Entobel has recently developed several procedures relating to supplier management. These include a Supplier Code of Conduct, Guidelines for Compliance with the Entobel’s Code of Behavior for Suppliers, and Assessment of Supplier. The Supplier Code of Conduct is quite expansive to cover all IFC PS requirements. However, IFC PS 6 Supply Chain requirements (PS6 Paragraph 30) are still missing1. There is lack of risk assessment process to categorize primary suppliers as well as screening step and materials, specifically focused on IFC PS 1 para 10 needs to confirm compliance of the supplier to those E&S considerations, including demonstration of no child or forced labor, OHS systems adequacy and not sourcing raw materials on areas recently converted from critical or natural habitats. There should be additional provisions and screening tools for suppliers (Primary Supplier and Tier of Supplier) to evaluate their systems on screening of source materials to the point of primary production. There should also be provisions for the Code be publicly disclosed in the supplier facilities as well as Whistle Blower channel/and anonymous reporting line. In addition, roles and responsibilities for supply chain management should also be defined. As set forth in ESAP#4 and included within the ESMS, Entobel shall update its current supply chain management policies and procedure using a risk-based approach to supply chain screening to control and where possible, ensure/limit risks from forced and child labor, OHS or materials derived from of primary production from critical or natural habitat, or recently converted from that. Procurement procedures will be develop and include: i) process for mapping and risk screening of byproduct in terms of labor, OHS and biodiversity related risks (including to point of primary production (as applicable) of material) based on country or source/material; ii) supplier evaluation procedure that shall include evaluation of the supplier ESMS and capacity to ensure compliance to Entobel supply chain policy commitments (defined within the Supplier Code of Conduct); iii) evaluation of primary supplier operations including assessment of labor and occupational health and safety standards to screen for forced or child labor risks and management of any significant OHS related risks. This supply chain commitment shall be publicized on the company websites in dual language.

Working Conditions and Management of Worker Relationship. Dong Nai facility has currently 71 employees with a gender split of 48 males to 23 females. The new facility planned in Vung Tau is anticipated to have 120 – 160 employees once operational, expected in September 2023. The company has in place a nascent HR function (equivalent to scale) including a qualified HR manager, with internal HR needs based on compliance to prevailing national labor regulations. Entobel Code of Conduct includes a commitment to adhere to human rights and respect the needs of the workers.

The company states it is compliant to Vietnamese labor regulations. It is stated that every worker receives a contract of employment, and that all workers receive a basic induction, including a review of rights under the labor law prior to contract signing. Entobel has recently developed a set of policies and procedures related to labor and human rights management. These include Internal Labor Regulation, Freely Chosen Employment Policy, Non-Force Labor Policy, Child Labor Policy, Non-Discrimination Policy, Workplace Harassment Policy, Freedom of Association Policy, Recruitment Policy and Procedures, Employee Appraisal Performance Procedures, Labor Discipline Handling Process, Procedure of Promotion/ Demotion/ Transferring, Policy for Female Employee. A Regulation on Periodically Dialogue with Workers is also noted. In general, additional important HR policy and procedures required include a retrenchment policy/procedure, appeals process evident in any disciplinary, performance evaluation, results of the dismissal process, anonymous channels for grievance mechanism and for harassment issues. The scope of labor policies needs to extend to seasonal workers, labors of contractors and suppliers. There is also a need to include a process for communicating policies and supporting procedures to workers and for communicating access to grievance and complaints channels to outsourced labor and or third-party labors engaged by contractors. All communications on benefits and rights should be communicated to the worker prior to signing of contract agreement. As set forth in the ESAP#5, Entobel shall update its HR policies/procedures consistent with IFC PS2 objectives, and Vietnamese labor regulations. These policies and procedures shall also include zero tolerance for proven cases of workplace sexual harassment and gender-based violence and accessible to workers on request.

Working Conditions and Terms of Employment. The company strictly adheres to the Vietnamese Labor Regulation with all workers stated as engaged on full term contracts. A review of sampled contracts confirmed that the workers job description, lines of reporting/supervision, place of works, salary, times of work, and basic entitlements and rights are defined. The company does not include references to the HR policies and procedures, nor statutory entitlements to annual leave. Although the company is committed to adherence to national regulations, the contract of employment should include details on benefits and entitlements and references to relevant HR policies as these will define the entitlements and rights for the workers. As set forth in ESAP#6, Entobel shall revise its employment contracts to include, in addition to existing information, rights to statutory benefits and entitlements. All workers are paid in accordance with the minimum wage requirements for Dong Nai Province. Stated by the company, it does not engage seasonal nor temporary workers, all workers on full-time fixed term or open-ended employment agreements.

Workers’ Organization: As per the Vietnamese labor code, the company has a worker’s organization and the management meet with this group on a regular basis to discuss key issues, complaints and requests.

Non-discrimination and Equal Opportunity: The company firmly believes in the power of meritocracy. The company has a formal policy on non-discrimination and equal opportunity (ref. ESAP#5).

Grievance Mechanism: The company stated that it has an open-door policy and that all workers could bring grievances or concerns to managers or HR. Entobel has recently developed an Internal Grievance Policy and Procedures and the Whistleblowing Policy and Investigation Procedures. These will require updates to include a mechanism for anonymous grievances, as well as extend to employees and outsourced workers and or third-party workers of contracted groups operating within Entobel facilities and locations. Any grievances raised does not limit other legal channels or affect any future legal proceedings or process that the complainant may pursue. All grievances need to be recorded in a grievance log and included in reporting to senior management, include date received, nature, status, resolution, and feedbacks from the complainant. There should also be a separate channel for sexual harassment or GBV to senior HR, assurances of confidentiality, escalation, investigation, protection of the complainant from retaliation. As set forth in ESAP#7, the company shall update its Internal Grievance Policy and Procedures and the Whistleblowing Policy and Investigation Procedures that shall include options for anonymous grievances. This mechanism shall be open to all workers, direct,contracted and third party (as applicable).

Protecting the Work Force: Entobel has developed a Workplace Harassment Policy, as well as Sexual Harassment Policy at workplace for the workers to bring complaints in terms of sexual harassment, or gender-based violence related. Entobel shall develop a GBV and sexual harassment complaints channel that shall be confidential, allow for anonymous complaints to be received. This channel shall be supported by an internal process for receiving, reviewing and investigating based on a victim centered based approach. This channel shall be made available for all direct, contract and third-party workers, as required (ref. ESAP#5 and #7).

Occupational Health and Safety: The company has developed a set of OHS related policies management programs. However, additional OHS assessment and measures are required to cover the Company operation’s needs. These include but not limited to i) general risk assessment framework based on probability and severity and list of operational actions in the workplace that will be assessed against that framework; ii) risk assessment report to include explosive dust risks from operations (including good housekeeping and prevention of explosive dust risks), permit to works for high-risk activities (e.g., hot work, confined space, electrical maintenance, lock out tag out including rescue procedures/electrical work); iii) inspection of safety equipment (frequency) and risks related to equipment failures; iv) HazMat and procedures for storage, handling, disposing, transport and spillage; v) OHS requirements for cleaning or maintenance of equipment; vi) the emergency response plan (ERP) to be based on the risk assessment plan/report and include all reasonably foreseeable events, particularly, explosive dust and ERP response; vii) monitoring of OHS leading/lagging indicators (e.g., Lost Time Injury Frequency Rates - LTIFR) as well as Near Miss or Safety Observations Reporting and include root cause analysis for preventative measures. To ensure the company is compliant to minimum OHS standards, a Feed Mill operation should include procedures for: (i) good housekeeping procedures to minimize dust accumulation; (ii) minimum standards for Personal Protective Equipment’s (PPE); (iii) training needs and training programs (including first aid, and, as applicable, rescue for permit works); (iv) process for sanctions and enforcement; (v) minimum standards for workplace air quality and temperature; (vi) first aid treatment/process for recording and investigating accidents; (vii) warehouse operations and ensuring staffs are qualified in use of equipment’s such as forklift operations. As set forth in ESAP#8, Entobel shall undertake a detailed OHS review of its operations and update the OHS policy, risk assessment and management procedure, to ensure that: i) its operations and OHS practices and work instructions, are in line with IFC PSs, GIIPs, and WBG General EHS guidelines, including relevant PPE to be provided to all workers; ii) accident investigation includes root cause analysis approach, with continuous monitoring/reporting of OHS leading/lagging indicators, and implementation of corrective measures; and iii) the company annually benchmarks its OHS performance with representative Vietnam and international feed mill industry/sector performance numbers. This should cover all workers, including temporary and thirdparty workers.

Workers Engaged by Third Parties. The company engages contractors for preventative maintenance works and specialist cleaning operations (such as cleaning out by-product storage silos). The company has an informal approach of requiring contractors to come from experienced companies and be at a minimum certified with ISO 45001. Entobel requires construction contractors (at a minimum) to sign agreements to comply with minimum standards for OHS and national labor law, including: i) contractors must submit an OHS plan for approval prior to operations being initiated; ii) implement required work safety needs (in accordance with national regulations); iii) accept responsibility for supervision of sub-contractor safety; and iv) report on work safety management performance. Entobel has no formalized process for setting minimum standards for labor, and OHS needs to contractors, nor in communicating needs, evaluating contractor’s ability for compliance nor monitoring. Although the requirement is in place there is no documented process in place to support monitoring of contractor OHS or labor performance and approaches are fully reliant on the EPC. (ref. ESAP#3).

Resource Efficiency. The current energy used for the Dong Nai operation is taken directly from the national grid (Electricity Vietnam) with back up energy supplied by on-site diesel generators. Entobel does not own any transportation fleet. All boiler fuel is biomass in the form of wood/rice husk pellets. Bottled Liquid Petroleum Gas (LPG) is used in the drying process. The company ethos is built on sustainable development and reuse of by-products and efficiency in use of energy in production. It is anticipated the future facility shall consume 1 to 1.5 Kilo Watt Hour (kwh)/kg of insect meal produced. Based on this assumption, it is anticipated that future facility will equate to 15 million kwh per annum for a production capacity of ~10,000 tons of powdered insect meal. The company plans to apply both a policy and management system for its energy consumption, ref. ISO 5001, including installation of solar panel, to be self-sufficient in energy use. Entobel expects to install the solar system after the construction of the new plant, which is expected to be completed end of 2023. The total capacity of the solar system is about 1 MW (ref. ESAP#2/ ESAP#3).

Water. Water supply is mostly required for sanitary purposes for workers and for cleaning the facilities and the silos. Water supply for cleaning process is sourced from industrial zone mains supply. The current water consumption per annum for the Dong Nai plant is estimated at ~30,000 m³. Drinking water for employees is provided daily by a service provider. The new facility shall have ~12x capacity when compared to existing Dong Nai operations and will be designed to recycle wastewater from the drying and evaporation process, as well as employ a rainwater catch and storage system with supplemental water sourced from the industrial park operator. The company anticipates that its production process shall result in 3 liters/kg of product, this will equate to ~36,000m³ per annum. (ref. ESAP#3).

GHG Emissions: Based on the assumption that all current and future energy needs are sourced from national grid and that Entobel may also install solar panel on the production plant (total capacity 1MW expected in 2023) to the capacity of the production facility, to be self-sufficient in energy use, it is calculated that average GHG emissions per annum shall not exceed 25,000tCO2e.

Air Emissions and Ambient Air Quality: Main source of air emissions will be generated during drying process and boiler exhaust from the combustion of biomass. These emissions will be aligned to Vietnam standards and WBG EHS guidelines. Noted in the site visits those emissions from both a biomass boiler, and from an LPG fired drying system were present. It is noted from the local environmental protection plan (EPP) that the capacity of the boiler is 7 tons of steam/hour, which is equivalent to around 4 MWth. Entobel confirms the air emission monitoring will follow the national emission standards (i.e., QCVN 19:2009/BTNMT and QCVN 20:2009/BTNMT). These national air emission standards are not in compliance with the WBG General EHS Guidelines (2007) for boiler emission from solid fuel for particulate matters (200 mg/Nm3 vs up to 150 mg/Nm3) and NOx (850 mg/Nm3 vs 650 mg/Nm3). As set forth in ESAP#9, Entobel will monitor its boiler exhaust and benchmark against the national regulations and WBG General EHS Guidelines for air emission, whichever is more stringent.

Wastewater Treatment: Wastewater generated by the Vung Tau facility will be subject to basic treatment at the site prior to discharge into the industrial park’ wastewater treatment system. Based on the ESIA, an estimated 91 m³ of wastewater will be generated per day from operations based on 140 staffs, and the anticipated production capacity of the new plant. Entobel (Vung Tau facility) has a principal contract with the Industrial Park (IP) management for the wastewater treatment. The sighted agreement highlighted wastewater from production and domestic use will be subject to basic treatment before discharging into the IP system, and within the permissible levels of the parameters attached to the contract annex. The Dong Nai facility currently discharges all wastewater (cleaning, and general domestic use) directly into a wastewater pond overseen and managed by the IP operator. It is noted from the site visits that both process wastewater and rainwater drainage combine into this pond. Sanitary waste is stored in septic tanks and removed on a periodic basis by a licensed vendor (ref. ESAP#3).

Solid Waste Management: The production process generates no solid wastes. The by-product for material inputs is trucked in by container and pumped into sealed silos. The by-product after the process is sold as organic fertilizer. The dead BSF are burned in the biomass boiler and spread on local agricultural areas, and all larvae are processed. In essence it is a zerowaste production process. Current and anticipated office and other wastes in the form of office equipment’s will be disposed of by a licensed vendor. Hazardous wastes are minimal and stored in drums and disposed of to a licensed vendor. Entobel has developed a Waste Control procedure although some improvements will be required, including wastes collection, transportation and treatment use of qualified waste disposal agents with relevant business registration license and permits, handled by competent person with adequate PPE, as well as logbook for Hazardous Waste storage area.

Hazardous Materials: The company stores diesel on site (at the Dong Nai facility), and this is to maintain backup generators for a period of forty-eight hours. Small levels of reactants are stored for laboratory testing purposes. The company also stores LPG in pressurized tanks 20 units at 45kgs per unit. Each unit fitted with standard safety valves. The units are stored in a separate room adjoining the drying location, with adequate ventilation to limit risks from leaks and gas build ups. Entobel has developed the Emergency Preparedness and Response Plan, including the Chemical/ oil Spill Response Plan. (ref. ESAP#3).

Pesticide Use and Management: The company apply mechanical means to manage vermin. Insect pests are controlled using sealed by product storage containers. Due to the production cycle all by-product is consumed within seven days from delivery. The future operation shall include larvae growing rooms that will be hermetically sealed. This is to limit risks from non BSF flies entering the production process.

Community Health and Safety: The new facility is to be in a purpose-built industrial park. It is stated by the company that the company operations will be no less than 100m from urban settlements. The current facility is located on an industrial land privately owned by a land-owner, who had constructed several workshops to rent out to different companies/individuals to set up their own operations (i.e., waste recycling factory, wood processing, and a furniture manufacturing factory). Outside of this industrial complex is forest plantation and pig farms. Insects are raised in a controlled environment in confined buildings and mainly at the larvae phase. Hence, the risk of escape from these closed buildings is insignificant.

Security Personnel: The company recruit full time security staffs and plan to apply this moving forward for the new site. All sites are guarded 24 hours. These guards are not armed.

Insect welfare: Entobel would follow and respect animal welfare standards by applying EU legislation in relation to animal welfare in insect rearing.