This is a Category B project according to IFC’s Policy on Environment and Social Sustainability (2012). Key E&S issue and risks associated with the project include: (i) the adequacy of the Borrowers’ E&S management system and organization; (ii) alignment of labor and working conditions at Borrower facilities and operations with host country and IFC’s PS2 requirements; (iii) occupational health and safety (OHS) during the construction and operational phases of the Project; (iv) waste management including hazardous wastes and materials; (v) emergency preparedness and response including life and fire safety (L&FS) and (vi) stakeholder engagement and grievance redress mechanisms.

 Fosun Group has an Environment, Health, Safety & Quality (EHSQ) Policy which guide the EHS Management Framework. The framework includes environmental management system, occupational health & safety management system and national work safety standards. The Group has implemented management systems certified as per ISO 14001 (Environment), ISO9001 (Quality), OHSAS18001/ISO450001(OHS) and ISO 50001 (Energy) across all its member companies.  Guided by the Groups policy, Guilin Pharma has an EHS Policy with corresponding management systems and programs. As part of this project, Tridem and Guilin Pharma will adopt, develop, and maintain Project-level EHS policy and Management Framework guided by the Groups Environment, Health, Safety & Quality Policy, in line with IFC PS requirements. (ESAP #1).

The Borrowers identify and manage E&S risks and impacts associated with their operations through a risk management framework aligned with applicable national standards and E&S regulatory permits and requirements. Guilin Pharma has conducted detailed hazard point analyses, with required engineering/hardware and management/procedural mitigations articulated to minimize each hazard.  Tridem Pharma has commissioned an ESIA for the greenfield project in Abidjan.

Guilin Pharma has a dedicated EHS compliance team as part of EHSQ department who report to EHS Management Committee.  As part of the project a similar structure will be adopted for Tridem Pharma (ESAP #2).  At the Fosun Group level, the EHSQ department Director is responsible for overseeing EHSQ initiatives across the Group operations. The Borrowers conduct EHS training and utilize case studies to emphasize the importance of work safety, prevention of occupational hazards, fire safety and environmental protection.

Both Guilin and Tridem Pharma have documented emergency response plans for the current operations.  The greenfield Project designs incorporate elements of emergency responses, including L&FS, wide corridors within the distribution hub and assemble points. For the existing facilities, roles, and responsibilities for various teams responsible for evacuation, rescue, and firefighting are defined and displayed at various locations across the facilities. Fire alarm call points, evacuation route maps and hose reels have been placed at strategic locations at the distribution hub in Abidjan and Guilin factory. The EHS compliance team conducts internal audits to ensure implementation of fire safety measure. External audits are also conducted as required by national laws and insurance companies. Workers have been trained in fire safety and operation of fire safety equipment semi-annually. Training will be extended to third party workers during construction.

As part of the Fosun Group EHS management framework, all member companies conduct risk self-assessments based on key performance indicators (KPIs) such as record of injuries, L&FS measures, usage of personal protective equipment (PPE), energy and water consumption, waste generation covering construction and operations. The KPIs are reported monthly to the compliance management team. All incidents and non-compliances are summarized and discussed in quarterly management meetings and the team analyses the root causes and implements corrective actions. The Group EHS audit team visits member companies to assess KPIs achievements.

Fosun Group’s E&S management systems (ESMS) is generally in line with IFC PS requirements and Guilin, and Tridem Pharma will adopt the ESMS to the construction and operational phases.

Fosun Group has documented HR policies and procedures revised in 2021 that are consistent with IFC PS 2 requirements and the national labor regulations and apply to all employees. Both Tridem and Guilin have standalone HR procedure manual adopted from the Groups HR policy. The HR procedures will be customised for the national laws in Cote d’Ivoire. Each worker receives a written contract that describes the working conditions and terms of employment, and an employee manual is also provided.  The manual specifies benefits and welfare for workers including remuneration and promotion, employee schedule, equal opportunities, working hours, rest periods, etc. The company’s HR team also monitors the labor contractors’ compliance with applicable labor laws and compliance with related contract clauses.

During construction of the greenfield project, approximately 10 permanent and 60 temporary workers will be engaged.  During operation, the manufacturing facility will employ 150 permanent workers, while the distribution hubs will have 30 permanent workers.

Fosun Group HR policy does not prohibit the freedom to associate and workers right to form and join workers organization. However, none of the workers in Tridem Pharma are unionised and only 10% of workers are unionised in Guilin. The HR policies encourage non-discrimination and equal opportunity for its permanent staff, contract staff and contractor workers. These policies are adopted by both Tridem and Guilin.  The HR policies and HSE construction manual prohibits engagement of child, forced or bonded labor practices.

Guilin and Tridem have documented grievance mechanism for its internal stakeholders. The grievance mechanism allows for submission of anonymous grievances and is also available to the contractors’ workers and they are included in related training and awareness campaigns conducted by HR department.

Tridem and Guilin will use contractors for the distribution hub and manufacturing facilities construction. As part of its contractor management policy, contractors are required to comply with national labor laws through specific contract clauses. The labor engagement practices, and statutory documentation maintained by the contractors are audited internally by the EHS audit teams. No temporary workers housing camps will be built during construction as part of this project.

As part of EHS policy, Fosun has a Corporate EHSQ manual based on Hazard Identification and Risk Assessment (HIRA). Workplace noise, heat and air quality are monitored, and records reviewed during appraisal are well within the applicable standards. EHSQ team collects incident statistics monthly from each member company including Tridem and Guilin. In the last 30 years of its existence, Fosun Group recorded a fatal OHS accident in 2019 caused by fall from height in the steel company. The company has set a target to achieve zero accidents by incorporating workplace accidents as a KPI for managers in each operation unit.

The Borrowers have occupational health & safety management systems in line with Fosun Group EHS policy and aligned to the national work safety legislation and standardization.  The OHS system include (i) procedures for hazard identification and evaluation of operational and maintenance activities risks and developed a risk matrix, (ii) a risk register of significant hazards is in place and communicated to all affected persons; (iii) training plan on OHS and (iv) provision of appropriate PPE.

 Guided by its EHS policy, Fosun Group is implementing initiatives including wastewater recycling, raise employee awareness on water conservation and emission reduction to reduce energy and water consumption across its operations and monitors resource consumption i.e., water consumption, electricity, and other inputs. Based on annual energy and water audits, the company implement measures to achieve resource efficiency in all member companies. During 2021, Fosun Pharma obtained 12 % reduction in its energy consumption and reduced the water consumption by 2 % compared with previous year.

For the greenfield manufacturing project in Abidjan, Cote d’Ivoire, electricity will be sourced from the national grid. Small boilers heated by natural gas will produce steam for the manufacturing facility and the use of standby generator, which is less than 3KVA, is expected to have very limited stack air emissions. The manufacturing process produces volatile organic compounds (VOCs) and other gases including toluene, non-methyl hydrocarbons, HCl, and odor.  All gases are captured within closed ducts, and fully treated before discharge to ambient via process stacks. VOCs are monitored on real-time on-site. Ozon depleting substances, which have been already phased out in the current operations and will not be used in the greenfield facilities.

Water for the greenfield in Abidjan will be sourced from the local utility supply company, supplemented by a borehole.  While the process will initially use 40m3 per day, most of the water will be recycled.  The design includes an in-situ wastewater treatment, which will allow wastewater to be re-used within the facility mainly for gardening.  As part of this project, treated effluent will be tested in the internal laboratory on a weekly basis (ESAP #3) to ascertain compliance with the legal limits as well as the limits specified in the WBG EHS Guidelines for Pharmaceuticals and Biotechnology Manufacturing. Stormwater is channelled outside the complex to recharge groundwater. The sludge is produced from the treatment systems, will be removed regularly, and collected by licensed company.

Fosun Group quantifies its annual greenhouse gas (GHG) emission as a part of its ESG report.  Based on data from the existing distribution hub, the annual GHG emissions are around 24,750 tonnes of carbon dioxide equivalent annually. As part of the Groups policy, Tridem and Guilin will quantify direct emissions from the distribution hubs and manufacturing facility respectively as well as indirect emissions associated with the off-site production of energy used by the project by using internationally recognized methodologies and will report the amounts to IFC though its annual E&S monitoring reporting. Upon project completion, Tridem and Guilin will quantify its GHG emissions by using internationally recognized methodologies and will report the amounts to IFC though its annual E&S monitoring reporting.

Fosun Group has hazardous and non-hazardous waste management policy and procedure including a system of recycling, appropriate sorting, handling, storage, and disposal which are consistent with applicable national legal requirements. All hazardous and non-hazardous wastes are collected for disposal by authorized public service agencies specialized in each type of waste. As a part of the procedures, that will be adopted per Fosun’s ESMS, Tridem and Guilin will carry out special investigations and compliance inspection on solid waste, as well as perform standardized and detailed management on storage places and record ledgers. Tridem Pharma has a standard operating procedure (SOP) on disposal of expired drugs.  During construction, waste management will be part of the EHS management system for the contractor. At the project site, all hazardous materials were noted to be properly labelled and stored in the designated area.

 The current distribution hub in Abidjan is located within an existing industrial complex and the planned greenfield will be in a designated industrial area, away from communities and along a main highway, no significant additional impacts on the health, safety and security of the local community are expected. However, to deal with any local traffic increase, the company will raise driver’s awareness on safe driving.

The design of the greenfield for both the manufacturing and distribution hubs include L&FS specifications.  As required, the Borrowers will ensure an expert of international L&FS standards, upon physical completion of the building, to verify that the fire-fighting systems were installed as designed in accordance with the L&FS section of the WBG General EHS Guidelines and to provide the certification, affirming that the L&FS systems were installed as designed as per an international life and fire safety code and are properly tested. (ESAP #4)

Tridem and Guilin Pharma will have own security workers for access control and guard of property for the greenfield facilities.  The guards will be unarmed and will be trained in emergency response in addition to regular training conducted by company for the security workers on the standard operating procedures for their job including human rights and engagement with the communities.

There is a stakeholders engagement procedure at the Group level. The procedure includes identification of stakeholders, focus areas of engagement, communication channels, frequencies of communication and communication activities and results.  As part of this project, Tridem Pharma and Guilin Pharma will adopt, develop, and maintain Borrower level stakeholder engagement and grievance redress mechanisms procedures, and will document grievance statistics and information in the form of grievance logs, a grievance redress database, and narrative reports on grievance resolutions. (ESAP #5)

Fosun group has a comprehensive whistleblowing mechanism utilizing multiple anonymous whistleblowing channels and guided by Fosun Group Global Whistleblowing Policy. The policy encourages all stakeholders including staff and partners to participate in the supervision and create good business practices. In addition, the Group has a Complaint Management System (certified according to ISO10002:2018) and conducted training for relevant staff to effectively implement the Group’s customer complaint management system.

The Group requires that each member company to establish an internal and external communication mechanism and distribute EHS Management System Manuals and other publications to facilitate the circulation of the EHS management system at each level within the enterprise and visitors.  Tridem and Guilin will adhere to the external communication mechanism and Fosun’s whistleblower policy and mechanisms. At the Group level, Fosun has been publishing its ESG report for the last six years Ref to the 2021 ESG Report here: https://en.fosun.com/development/report.html

The Group’s corporate and social responsibility (CSR) program is managed by Fosun Foundation which has a robust community engagement program, including initiative such humanitarian relief, poverty alleviation (rural revitalization), healthcare, community construction, care for children, young entrepreneurs, education, culture, and art. Fosun Foundation has formed a strong “information network” through close contact with local governments, non-profit organizations, employees, and partners, and has opened channels for the society to collect information on help requests.

Contact Person: Leon Sheng

Company Name: Tridem Pharma SAS

Address: Rm. 1101, BLDG B, #1289 Yishan Rd. Shanghai 200233

Email: l.sheng@tridem-pharma.com