PS5 Land Acquisition and Involuntary Resettlement, PS7 Indigenous People and PS8 Cultural Heritage are not expected to apply to this project for the following reasons: no land acquisition is needed for the project as the malting plant is already operational and will not be expanded. No Indigenous People areas or cultural heritage was encountered during appraisal and assessment of this project as InVivo’s grain procurement and storage, and malting facilities in Ukraine are located on consolidated areas of agriculture and/or industrial zones.    

 This is a category B project according to IFC’s 2012 Environmental and Social Sustainability Policy. The project is expected to have limited and site-specific E&S risks and impacts that can be avoided or mitigated by adhering to recognised Good International Industry Practices (GIIPs), guidelines or design criteria. Key E&S risks associated with the Group’s malting and grain sourcing operations relate to completion of a stakeholder risk analysis and corrective actions to be developed as part of InVivo’ community engagement plan for the agro division Project’s countries. Due to the current war in Ukraine, the implementation of this stakeholder engagement plan (SEP) has been delayed.                                                  

 Environmental and Social (E&S) Assessment and Management System. The Group has effectively developed and implemented a corporate Integrated Quality, Environmental, Occupational Health and Safety (QHSE) management system (MS) compliant with international management standards, such as: ISO 9001:2015 (quality) for the agro and malting division; and ISO 14001:2015 (environmental), ISO 45001:2018 (occupational health and safety) and ISO 50001:2014 (energy) for the malting division. The scope of this QHSE MS applies to its core businesses, including the malting and agro operations in Ukraine. Given the reviews of earlier IFC investments, the QHSE is robust and includes all elements of IFC PS1. The Group’s performance-based requirements include national regulations and international standards (e.g. EU regulations and Directives, IFC PSs). A Hazard Analysis and Critical Control Points (HACCP) framework has been developed for all agriculture and malting facilities and comes under the responsibility of the Food Safety Manager of the malting division and International QHSE manager for the agro division.

E&S Policy. As part of QHSE MS, the Group has developed policies regarding the environment, workers safety and sustainable supply chains. In 2020, the Soufflet Group adopted an overarching 2030 Corporate Sustainability Strategy, known as “We Do Fair” (https://www.soufflet.com/en/our-commitments). This Strategy was integrated in InVivo’s Corporate Sustainability Strategy. “We Do Fair” strategy consisted of 5 pillars; i) Protecting ecosystems and climate; ii) Developing a responsible and sustainable economy; iii) Guaranteeing products of a high food safety and nutritional standard; iv) Contributing to regional development; and v) Ensuring staff members’ safety and developing skills. For each pillar, key performance indicators (KPIs) have been determined, including reduction targets, such as Greenhouse Gas (GHG) emission, water consumption, and wastewater treatment. These will be addressed in the applicable PSs below. The malting division translated the five pillars in a 2030 division strategy with measurable KPIs and annual targets. In addition to the Group’s strategy, the agro division will implement a new QSHE policy focusing on (i) cross-country integration; (ii) reinforcement of HACCP risk assessments; (iii) guaranteeing conformity of products and traceability of grain procurements through an enterprise resource planning (ERP) system.

Identification of Risks and Impacts. As part of its corporate QHSE MS, EHS risks and impacts are identified at all Group’s operations in Ukraine, according to Standard Operating Procedures (SOPs) developed within the QHSE MS. EHS risk assessment is the foundation on which management programs are established and reviewed annually. The scope of risk assessment also covers contractors’ operations, including development of corrective measures, audits of the Group’s requirements on implementation and enforcement by contractors performing work at company’s facilities. For new facilities, the Group conducts a gap analysis against aforementioned Group’s performance requirements. All facilities undergo an annual internal audit against applicable national legal and regulatory requirements, IFC PSs and WBG EHS Guidelines. Any deficiencies are documented, including the preparation of a plant-level Corrective Actions Plan (CAP), completion timeline, and assignment of CAPEX/OPEX. Due to the pandemic the annual audits were not completed by the Group QHSE staff, but by the local QHSE staff and now all audits are suspended due to the war. The most recent audit reports for the Ukrainian operations showed no material findings.  

 Management Programs. QHSE management programs and plans of the agricultural input distribution, grain procurement and malting operations are based on QHSE policy commitments mentioned above, outcomes of risk identification process, overall E&S performance (based on KPIs and corporate target), and findings of internal audits and authorities’ inspections. Plans are developed or updated annually. InVivo entities have adopted Group-level targets for environmental protection, reduction of GHG emissions, energy efficiency, and waste management. The Group applies KPIs which are monthly reported to the management at the division level and at the Board level, which include water and energy consumption, solid waste recycling or reuse, lost time accidents and near misses. The latest monitoring results were shared for the Ukrainian operations and for the Group as part of the public 2020-21 CSR (Sustainability) report.

Organizational Capacity/Competency. Soufflet had established an organizational structure that defines roles, responsibilities, and authority to effectively implement its QHSE MS, which has remained in place after the acquisition by InVivo Group in December 2021. At the Group level, a Corporate Social Responsibility (CSR) Director is appointed overseeing all divisions and setting the CSR (Sustainability) strategy and monitoring CSR/EHS performance of all divisions. The malting division has a CSR Director, 22 QHSE managers managing the 27 malting facilities, one Safety Manager and one Food Safety Manager. In addition, there is one central laboratory with 12 lab technicians. The agro division has an International QHSE Manager who oversees the input distribution, grain procurement operations with local staff assigned with a QHSE role at each location. InVivo Group has three technical committees, covering Quality, Environmental, Occupational Health and Safety, involved in QHSE monitoring. During the 2021 appraisal (ref. #45465), IFC held conversations with two CSR Directors and the International QHSE Manager which provided IFC with assurance that the local QHSE staff is experienced and is competent with respect to management of relevant E&S aspects of the project, as contemplated by IFC PSs. Observations made during the past site visits to the Soufflet operations confirmed that opinion.

EHS Training. The Group has implemented a comprehensive EHS training program for its operations in Ukraine that encompasses an induction on EHS for new workers and discussion with workers on main EHS aspects. InVivo has implemented a job coaching program, in which local EHS teams are supervised by senior corporate specialists to share the existing expertise across the company. An annual plan for OHS training is developed, as per local Ukrainian requirements, and outcome of risk assessments to be agreed with the QHSE Director. InVivo also has an Environmental and OHS prevention plan for all contractors.

Emergency Preparedness and Response. InVivo has developed Emergency Response Plans (ERPs) at all its operations, commensurate to potential risks, including life and fire safety. These are documented and maintained in accordance with local law. ERPs are a combination of procedures for using, inspecting, and maintaining emergency response equipment; notification of the public and emergency response agencies; and training programs. Specific training on EU requirements (ATEX directives), describing equipment and safe working operations for a potentially explosive atmosphere, is included. The silos in Ukraine are equipped with dedusting systems and safety devices; life and fire (L&FS) equipment, including fire alarm systems, fire hose and fire extinguishers. Silos are being inspected on a regular basis for compliance with ATEX directives and included in the preventative maintenance program. The malting plant in Ukraine uses ammonia for refrigeration purposes, stores and uses chemicals to keep equipment clean, utilizes combustible substances and employs pressurized vessels. For the storage and use of these chemicals and substances emergency preparedness and response scenarios are in place to ensure that workers are protected and understand what measures are to be taken in the event of an emergency. A standard requirement at all malting plants is the installation of clearly marked evacuation routes and lighting throughout the facility. There are trained firefighters along with appropriate equipment in place and annual evacuation drills are held. The ammonia storage areas at the malting plant is equipped with leak detectors, alarms and signage, and have entry restricted to only authorized personnel. During previous supervision visits of malting plants, these measures were observed to be in place. IFC reviewed the cooling room safety inspection checklist which is considered adequate.

Monitoring and Review. There are various types of internal QHSE audits conducted at InVivo’s operations. The QHSE Managers conduct equipment and staff safety audits of selected facilities. HACCP and safety audits are conducted by the Group’s audit department depending on site performance and implementation of CAPs are closely monitored with an agreed upon schedule outlined in the QHSE management system framework. The company has installed a QHSE document control software. All Group documents and processes are stored in this software and are at the disposition of all QHSE managers. All events (human or material incident/accidents/complaints) are registered and classified by the site as minor or important. The CSR Director and Management at the Group level has access to all events, and can make interventions, and follow up on every event they consider important, or upgrade specific events, ranging from minor to important, if deemed necessary. Statistics of events are shared and analysed by technical committees, and quality committees, among others.

The Company has implemented a QHSE monitoring and reporting systems, including performance indicators related to resources efficiency, environmental protection, reduction of GHG emissions, accident reduction and waste management. Management of each division reviews the EHS performance of all facilities on a quarterly and annual basis. Corrective actions are decided based on performance and mitigation measures included in QHSE management programs. The external reporting of individual facilities is carried out in accordance with local legal EHS requirements. Since 2012, Soufflet published a CSR (Sustainability) report covering all its operations (https://www.soufflet.com/en). The E&S commitments, targets and performance data included in the ESRS are based on the 2020/2021 report. Reporting to IFC on continuous improvement of E&S performance, ESAP items and the E&S management system is provided through Annual Monitoring Reports (AMR).

Supply Chain Management System. In June 2020, Soufflet launched the program “Sowing Good Sense” (https://www.youtube.com/watch?v=htLnXNZnzY8) which is continued by InVivo. This sustainable approach, which involves all Group’s sourced commodities – wheat, barley, rice, pulses and vines – is based on five pillars: provenance, environment, naturalness, distribution of value, and quality. Ukraine is involved in the “Sowing Good Sense” program for the malting division. Using the farmers database included in the ERP, the agro division established full traceability of all the grains they procure. In principle, the malting division procures its barley in the same country. In case the malting division cannot procure enough to meet demand, they will import from another country through its agro division.

Using the Sustainable Agriculture Initiative (SAI), Farm Sustainability Assessment (FSA, https://saiplatform.org/fsa/) tool, the malting division aims to procure 80% sustainable cultivated barley by 2030. To assess sustainable primary agricultural production, SAI has set guidelines, including respect for the bio-physical environment (soil, water and biodiversity) at the farm level. Currently, the agro division is testing the FSA tool, through independent verification by Control Union to assess, improve, and validate on-farm sustainability in their grain supply chain. The outcome of the 2021 verification was that most of the farmers scored Silver which means that the farmers’ sustainable farming practices are recognized by leading companies: 100% coverage of essentials, 80% of basic, and 50% of advanced. A small group of farmers scored Gold: exceptional farming practices. 100% coverage of essentials, 100% of basic, and 75% of advanced. The certificates are valid for three years. If this approach is confirmed, the Group will repeat the verification audit after three years or sooner if they add new farmers to their sourcing base. This has not yet further progressed in 2022. 

Soufflet adopted a responsible purchasing approach committing all of its divisions for an initial period from 2020 to 2025. This continues after the acquisition by InVivo where the Group aims to get 80% of strategic suppliers (except farmers) to obtain compulsory EcoVadis assessments. EcoVadis ratings cover a broad range of management

systems including Environmental, Labor & Human Rights, Ethics and Sustainable Procurement. For the malting division a global assessment was done in April 2021, resulting in a Silver Rating. The Silver Rating means that the division score is in the top 25 percent globally of all companies. Going forward, the agro division suppliers in Ukraine will also be included in the EcoVadis rating, but this has now been postponed due to the war.

 As of June 2022, the Ukrainian malting operations had 82 permanent employees and no contractor. For the agro division, the workforce was composed of 152 employees and 77 contractors. There is no planned retrenchment foreseen for the operations in Ukraine. At the beginning of the war in Ukraine in February 2022, InVivo halted all its operations to ensure the safety of its employees. At the end of April 2022, the malting plant started operating again. Re-opening of the agro division operations was on downgraded “cash and carry” mode, from early March, to support the Ukrainian farmers in their spring campaign (sowing, treatments, fertilization). The activity is increasing gradually but still much lower than the previous years. If it is not safe to operate, InVivo will suspend, where needed, its activities based on State and regional administration and Group crisis unit orders. InVivo continued to pay salaries and implemented a temporary policy of paying salaries 2 months in advance during the non-operational period and this is ongoing.

Human Resources (HR) Policies and Procedures. In Ukraine, InVivo has in place an HR policy and Manual of Procedures and a Code of Conduct, based on the Group HR policies and procedures and local labor regulatory requirements. As per the Group HR policy, the contents are shared with new employees during their induction process. The manual contains information on terms of employment and working conditions, covering employment, recruitment, probation period, transfers, promotion, and termination. It provides details on work schedule, remuneration, including overtime pay, public holidays and leave, health insurance, pension fund, training and development, staff relations and communications (including a grievance mechanism or GM), occupational health and safety, workplace rules, code of conduct and disciplinary actions that could be taken. Based on this policy review, IFC confirmed the alignment and consistency of the Group’s HR policy framework with IFC PS2 objectives.

Working Conditions and Terms of Employment. InVivo’ operations are committed to comply with local labor regulations and the Group’ Policies and Procedures. All workers in the Group’s operations are direct workers under permanent or temporary contracts. Third party workers are only used during civil works or construction of a new plant. Regular working hours and overtime paid are in accordance with the Ukrainian labor laws. In the malting facilities, there are 3 shifts of eight hours. The company offers competitive salaries which are regularly updated, based on benchmarking against market and industry practice in Ukraine. Employees are provided with a contract and the terms and conditions specific to the grade and role of the employee as per the Group’s requirements and Ukrainian Labor Codes. The Company does not envisage any retrenchment in Ukraine during the lifetime of this IFC financing. Should retrenchment be necessary, the company will ensure early consultation with all stakeholders in line with the Group retrenchment procedure and with the Ukrainian labor requirements.

Workers’ Organizations. InVivo does not restrict the freedom of workers to associate. Management encourages workers to establish a worker committee to discuss labor and OHS aspects of their operations. This provision is well defined in InVivo’s HR policy and communicated during worker induction session. These workers organizations are in place in Ukraine.

Grievance Mechanism. A formal corporate worker’s grievance mechanism procedure is in place and provides several alternatives for employees and temporary workers to raise concerns in writing to management other than to immediate supervisors and allows grievances to be presented without the risk of retaliation, in line with IFC’s PS2. In case contractors do not have their own grievance mechanism, the Group will extend their grievance mechanism to third party workers to facilitate the communication of possible grievances. For 2020/2021, InVivo reported no issues raised by workers and contractors in Ukraine.

Gender and Gender Based Violence (GBV). Based on the IFC GBV risk screening, medium risk exists in Ukraine while a low risk exists at the Project level. Sexual harassment stipulations are included in the Group’ HR policy and are explicitly addressed in the HR Policies in the Group’s subsidiaries. The company does not tolerate any form of harassment, and this is communicated to all employees during the induction process. The corporate worker’s grievance mechanism procedure includes expertise to manage sexual harassment cases.

Protecting the Work Force. Neither child labor or forced labor will be or is utilized by any InVivo operation as per the Group HR requirements. The Group only employs persons according to legal age employment regulation.

Occupational Health and Safety. As part of its 2030 corporate sustainability strategy, the Group has set a target of a 50% reduction of lost time accidents by 2025. Soufflet Group activities reported a lost time incident rate per million hours worked of 4.7 in 2019/2020 and 3.3 in 2020/2021, which compares favourably to the 2019 US benchmark rate in food manufacturing of 5 lost time incidents per million hours worked. In the past years, Soufflet had given a lot of attention to safe working conditions and improving the safety culture at their operations. For example, in addition to their training program, the Group’s malting division implemented “Safety Behaviour Visit”. This consists of a short meeting around a working operator during which an action is analysed. The aim is to make operators aware of risks resulting from inappropriate behaviour at work. Safety leading and lagging KPIs include, among others, number of lost time accidents for employees and contractors’ training completion and safety incidents. These are reported via an OHS dashboard for each facility and publicly disclosed in the facilities. When an incident or accident occurs, a flash-card is developed showing the incident or accident, the root causes and corrective measures taken. The flash-cards are then translated and published in all facilities. After several years of zero accidents, the agro division had two lost time accidents in 2019/2020 and one lost time accident in August 2021. For the malting division, the lost time rate and severity rate decreased from 2019/2020 to 2020/2021 by respectively 42% and 33%. For both divisions, the rate is below the 2019 US benchmark rate in food manufacturing. For 2022 year-to-date, no lost time accidents occurred in both divisions in Ukraine.

The Group will report on the progress on its corporate OHS reduction target of 50% and providing data on accidents, root causes and measures taken for employees and contractors in the AMR. InVivo has put in place practices to ensure a safe working environment for all workers. Those jobs that have inherent hazards and risks (such as working at height, in confined spaces, with energized equipment, or with hazardous materials, i.e. ammonia) have been assessed and safe working measures developed and implemented. For example, a lock-out-tag (LOTO) practice ensures that workers engaged with energized equipment are protected from exposure to electricity, pressurized liquids, etc. while they complete their tasks.

COVID-19 Measures. Based on a risk assessment, the Group developed a continuity plan and implemented strict quarantine measures at all its operations, including limiting the number of workers during shifts to ensure social distancing. Trainings on these contingency measures have been added to the EHS training program. In some countries, grain procurement has decreased, and malt production suspended due to the decrease of malt deliveries (due to lock down) to brewers and high malt stocks. There were no lay-offs. When employees need a PCR test for professional reasons, these are reimbursed by the company. Senior management has periodical communications with the workforce to discuss the status and local management check in with their workers on their well-being.

Supply Chain. In general, grain production in Ukraine, due to being fully mechanized, is not known to be associated with the types of social risks and impacts contemplated by PS2 (child labor, forced labor, and significant safety issues) requirements.                                                  

Resource Efficiency. In line with its 2030 corporate sustainability strategy and reduction targets, the Group undertakes continuous efforts to promote pollution prevention and energy efficiency measures. It is fully committed to continue working towards efficiency of energy and water consumption and efficiency, through its internal QHSE audit process. The production of malt is a resource intensive process and involves three main steps, namely (i) soaking the barley - also known as steeping - to awaken the dormant grain; (ii) germination and sprouting; and (iii) heating or kilning the green malt to produce its final color and flavor. Cleaner production (CP) measures implemented by the malting division included the installation of heat pumps reducing energy consumption and costs and the implementation of a new steeping method to reduce water use. All energy and water resource efficiency measures are aimed at increasing efficiency and are expected to be in line with Good International Industry Practices for the malting and agro divisions. Proposed Group-level water reduction use of 20% is scheduled from 2017 and 2030. The malting division is committed to include 30% renewable energies in its mix, while investments in equipment is scheduled to reduce GHG emissions. For the malting plants, the 2020/2021 benchmark for water consumption at the Group-level was 4.13 m3/ton malt produced. The Ukraine malting plant operates below this benchmark.

Greenhouse gas emissions. All malting facilities use natural gas as its main energy source. Back-up diesel generators are used in case of power outage. As part of its Sustainability Strategy, Soufflet set a Group-level target of a 5% reduction in energy consumption, 5% reduction of GHG emissions from the energy (Scope 1 and 2) and 15% in third-party transport (Scope 3) between 2017 and 2025. The malting division has joined the Carbon Disclosure Project (CDP) and completes an annual global evaluation on its carbon footprint, covering Scope 1, 2 and 3. Between 2010 and 2020, the Malting division already recorded a 10% reduction in its GHG emissions on its Scope 1 & 2 carbon footprint. In 2019-20, the Group had a Scope 1 and 2 carbon footprint of 380,000 TCO2 eq. In 2020-21, it stands at 347,000 TCO2 eq., i.e. a reduction of 10%. The emissions of operations in Ukraine do not exceed the 25,000 tonnes of CO2eq annually.

Pollution Prevention. The main environmental risks associated with the silo and malting operations are related to grain dusts and noise. Moreover, it poses risk of explosions or fires if allowed to build up in an uncontrolled way within the facility. To avoid either of these situations, Ukrainian agro division facilities have been built to meet state-of-the-art standards for dust control, utilizing filtered ventilation and enclosed conveyor systems. These systems are well maintained and cleaned regularly to prevent any potential dust related problems. To reduce noise level, engineering and administrative controls are implemented. As needed, for workplace having noise levels above 80 dBA, all equipment is confined inside the production buildings and earmuffs are provided to staff.

The malting plant has a small gas boiler to produce heat that will be used in the kilning process. The thermal power capacity is below 6 MW which is considered a small combustion facility, as defined in WBG General EHS Guidelines. Based on 2021 measurements, air emissions from boilers and burners in the Ukrainian malting plant meet local regulatory and the WBG EHS Guidelines parameters’ values.

Process wastewater is generated by the malting plant only. The Ukrainian malting plant has an onsite wastewater treatment plant (WWTP), which was recently refurbished, discharges treated effluent to the local river Horin. Review of treated effluent monitoring data of the first quarter of 2022 demonstrated that the effluent meets the WBG EHS Guideline limits for food wastewater (aligned with local limits).

Solid Wastes. As part of its Sustainability Strategy, the Group has set a target of 0% of landfilled waste in 2030. The malting division has a target to recycle 90% of its wastes by 2030. InVivo is managing the solid wastes in a sustainable manner in Ukraine. Such wastes (sludge or dust) are used as sustainable energy, animal feed or as a fertilizer (where local authorizations are obtained).

Hazardous Materials, including Pesticide Storage, Handling and Use. Hazardous materials, such as ammonia for refrigeration and diesel for back-up genset and fire system generators, are properly and separately stored and marked with appropriate warning signs. InVivo is not involved in primary agricultural production and, as such, does not used pesticides. Rodent and pest control at the malting facilities is undertaken by licensed companies. The agro division stores and sells fertilizers and crop protection products (CPPs), including pesticides. The Group’s Soufflet activities developed and implemented a pesticide selection procedure which excludes the purchase, use and trade of WHO Class Ia (extremely hazardous or Ib (highly hazardous). In the past years, the Group has updated its policy and procedures to meet IFC’s PS3 requirements on store, use or trade in WHO Class II (moderately hazardous) products. InVivo has an inventory of Class II pesticides and will provide to IFC annual reports on inventory and actions taken to reduce trade in Class II chemical formulation in its agricultural operations to the extent economically viable. Safety operation procedures are in place for pesticides transport, storage and distribution, including warning signs, personal protective equipment (PPE) use, training, product segregation and handling. The agro division facilities, except for Ukraine, accept empty plastic containers for pesticides from farmers; arrange proper temporary onsite storage and disposal according to EU regulations and the FAO Code of Conduct on the Distribution and Use of Pesticides. In Ukraine the required infrastructure is not yet available, but a collaborative platform initiated by Suppliers is being piloted since Q3 2021. The Ukrainian farmers can make a request for returning CPP containers. InVivo is actively raising awareness for this platform with its farmer clients.                                                   

 Community Health and Safety. The Group has evaluated the health and safety risks and impacts of stakeholders that may be impacted by its malting and grain sourcing operations in Ukraine. The main risks are those associated with security and ammonia leaks, dust, odor and noise hindrance operation. The malting plant is located in an industrial zone with a 1km buffer zone between the malting plant and neighbouring communities.

Issues associated with inputs, equipment, and processes at InVivo’s operations are assessed through a variety of means. For example, the company undertakes safety audits and assessments with respect to explosions during plant design, including installation of features to avoid explosions and leaks. Grains present a risk of dust explosion. Measures are in place to ensure that suspended particulate concentrations do not pose a risk (e.g. enclosed conveyor belts). The risk of ammonia leaks, that could also present a risk, are also assessed, and the equipment used for refrigeration is regularly tested and as noted above, a leak detection system is in place to warn of any irregularity.

For the transport of grain sourced, InVivo uses third-party service providers. To ensure that the trucks used by these third parties are well-maintained and driven by trained drivers, the contracts is including specific provisions to address these matters. Furthermore, the company ensures that the drivers of those trucks have access to appropriate sanitary facilities either in a designated truck holding area at the facilities or within the industrial zones. All company drivers receive periodical drivers’ safety training. In 2021, there were 5 near misses related to road incidents involving company drivers. The drivers were all retrained on the company’s drivers’ safety rules and in accordance with Ukrainian road safety regulations.

Food/Product Safety Management. As stated above, the malting division has a HACCP framework in place based on the ISO 22000 food safety standard, which is annually checked by an independent certified body. In both divisions, annual internal HACCP assessments are completed. All malting facilities in the Project’s countries have a laboratory for quality testing.

Security Providers. In Ukraine, InVivo has its own security personnel for controlling access to the malting plant and agro division sites. Security guards are trained and certified in accordance with local regulatory requirements and do not carry firearms. In case of a security incident the local police will be called. No incidences regarding the conduct of the security personnel were reported by the company.                                                  

 Sustainable Management of Living Natural Resources. Grain production areas in Ukraine are in consolidated agricultural lands, and as such there is no risk of recent or expected significant conversion of natural habitats. Reviewing the grain production areas, the Global Forest Change (GFC) data confirmed that there has been no recent significant natural habitat conversion. This was validated for the farmers supplying to InVivo during the FSA audit by Control Union. In addition to the FSA/SAI certification, the agro division operation in Ukraine are certified under the International Sustainability and Carbon Certification (ISCC), which ensures that i) biomass is not produced on land with high conservation value (HCV) areas and high carbon stock (HCS); ii) good agricultural practices (GAPs) protecting soil, water and air are applied; iii) human rights, labour and land rights are respected; iv) sustainable material is traceable throughout international supply chains; and v) GHGs reduction targets are met (e.g. European biofuels markets). The FSA/SAI tool and ISCC standard largely align with the PS6 requirements.

Since 2017, as part of a technical assistance program called SOILTEQ (http://www.soilteq.eu/en/), the agro division provides services to farmers regarding Good Agriculture Practices (GAP) considering natural resources and soil technologies in Ukraine. Farmers learn how to improve their soils by changing soil treatment, usage of permanent cover and crop rotation. Besides visiting farmers, they hold workshops twice a year. In addition, InVivo provides climate resilient grain varieties.

 InVivo has implemented a stakeholder engagement approach following the ISO approach by identifying its interested parties or stakeholders for the malting plant in Ukraine. Based on such stakeholder mapping, a risk and impact analysis was completed (focusing mostly on traffic, noise, odor and dust emissions and cordial relationships), which informs the consultation and communication processes with the identified stakeholders. The assessment is annually reviewed and updated, when needed. This process was recently completed for the agro division as part of the 2021 ESAP (ref. #45465). Based on the outcome of the analysis, InVivo’s operations will be communicating its results and seek feedback to ensure satisfaction on the effectiveness of the mitigation measures taken through appropriate communication channels. This approach is consistent with PS1 provisions and GIIPs. Due to the war, InVivo focuses on the wellbeing of its employees and safeguarding its operations and therefore is not undertaking stakeholder engagement activities. As soon as circumstances allow, InVivo will resume stakeholder engagement activities in Ukraine. Going forward, the Group will report on the engagements undertaken in the Ukraine for both divisions and any grievances received in the AMR.

InVivo developed and implemented a corporate grievance mechanism to receive and respond to communities’ concerns for all operations under the previous investments. In the last year, the Ukrainian operations did not receive complaints from neighbours or nearby communities. InVivo is in process of implementing the stakeholder engagement practice with relevant stakeholders, especially those communities in proximity to the malting facility operations, including a formal community grievance mechanism.                                                  

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