IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Policies. Solidiagui has documented an Occupational Health and Safety (OHS) Manual which provides a basic framework for implementing an OHS Management System as per ISO 45001 requirements, including relevant standard operating procedures (SOPs). Solidiagui has also documented an OHS policy which highlights the company’s commitment to promoting good environmental practices, safe working conditions and continuous improvement of Environmental Health and Safety (EHS) performance of its operation in compliance with relevant country laws and regulations. Both documents are generic and do not focus on project-specific risks. Solidiagui will develop and implement E&S policies as part of a PS-compliant ESMS (ref. ESAP#2 below), stating its commitment to meet IFC PSs and World Bank Group (WBG) EHS Guidelines for its beverage operation and achieving certification for ISO 22001.
Environmental & Social Risk Assessment. Solidiagui holds a valid environmental compliance certificate delivered in October 2022 by AGEE which is renewable on a yearly basis. In compliance with this regulatory requirement, the permitting process involved an E&S risk assessment which enabled AGEE to formulate a set of generic Terms and Conditions (T&Cs), including E&S mitigation measures. These measures have yet to be systematically implemented as observed during IFC appraisal. The document also specifies that, in case of expansion, Solidiagui is required to prepare a limited or focused E&S assessment and update the consequent mitigation measures. The company indicated that it has reached out to AGEE for the proposed expansion and expects the new permit requirements to be in place before its commissioning. To ensure that key E&S risks and impacts associated with the proposed project are adequately identified, avoided, or mitigated, Solidiagui will (i) pursue the preparation of a focused E&S risk assessment for the proposed project as required by local legislation and IFC PSs; (ii) develop an E&S management procedure with a dedicated section for the installation phase of the new beverage and dairy products line. Performance-based requirements for this risk assessment and management procedure will include Guinea’s legal and regulatory requirements, IFC PSs, WBG EHS Guidelines, Food and Beverage safety requirements, including a Hazard Analysis and Critical Control Points (HACCP) system (ESAP#1).
Solidiagui acquired its factory plot in October 2020 in the Massayah Industrial Estate which is under the management of AGESPI (“Government Agency in charge of industrial parks in the Republic of Guinea”). The acquisition process was conducted on a willing seller-willing buyer basis and did not trigger any physical displacement.
E&S Management System and Programs. Solidiagui does not have an E&S Management System (ESMS) and did not systematically implement E&S mitigation measures formulated as per its environmental compliance certificate delivered by AGEE. Solidiagui will develop and implement an ESMS consistent with the IFC PSs requirements and applicable to its operation, which will include (i) an overarching E&S policy, (ii) an E&S risk screening and management procedure (as stipulated under ESAP#1); (iii) E&S management programs aligned with the company’s E&S mitigation measures formulated by AGEE and consistent with the World Bank Group (WBG) EHS Guidelines; (iv) organizational E&S function; (v) emergency preparedness and response; (vi) monitoring and reporting; and (vii) stakeholder engagement and community grievance mechanism. Performance-based requirements of this E&S Policy and ESMS will include Guinea’s legal and regulatory requirements, IFC PSs and WBG EHS Guidelines (ESAP#2). To ensure full institutionalization of its food and beverage products safety requirements, Solidiagui will implement a Food Safety Management System (FSMS) which will be certified against ISO 22001. The company will share with IFC a timebound implementation plan for the FSMS, including copy of compliance verification audit once the system is effectively implemented (ESAP#3). Solidiagui will ensure that the E&S Management Plans (ESMPs) resulting from the focused E&S risk assessment process mentioned above (ref. ESAP#1) fully address AGEE recommendations and include a Construction’ EHS Plan (CEHSP) addressing labor and OHS risks. A Manual of EHS Procedures will be prepared to formalize the ESMP’s mitigation measures. The FSMS will be developed with the support of a consultant and include the relevant SOPs on sanitation, Good Manufacturing Practices (GMP), staff hygiene and training, and a customer complaints mechanism.
E&S Organizational Capacity and Competency. Solidiagui’s current organizational structure does not include a specific EHS function. Overall OHS compliance at the factory is under the oversight of the Production manager. Solidiagui will establish and maintain its E&S organizational structure with internal capacity and competency, including assignment of OPEX/CAPEX for the E&S workplan. Specifically, Solidiagui will recruit one qualified and full time E&S Coordinator with clear responsibility and authority to implement the IFC-compliant ESMS (ref. ESAP#2) at the factory, to operationalize ESMPs, E&S Manual of Procedures (SOPs), and regular internal audit to verify implementation effectiveness (ESAP#4).
Emergency Preparedness and Response Plan. Major emergency risks at the factory include fire, explosion and hazardous materials spills. The production hall is equipped with fire detectors, alarm systems, and fire-fighting equipment, with documented records of regular maintenance by a licensed contractor; and there is a team of employees and security guards trained on fire and first aid response. The company reported that no emergencies occurred since the beginning of its operations in 2021. Nonetheless, there is no documented emergency preparedness and response plan (EPRP) validated by local authorities. As part of the ESMS (cf. ESAP#2), Solidiagui will develop an EPRP consistent with PS1 and Good International Industry Practice (GIIP) that will include response to extreme weather events and will collaborate with nearby factories and the estate fire brigade to respond effectively to emergency situations.
E&S Monitoring and Review. The Guinean Environmental Assessment Agency (AGEE) performs E&S inspection on a periodic basis and issues renewal of environmental compliance certification. The last inspection was carried out in December 2022. Solidiagui will develop an E&S monitoring procedure which will specify Key Performance Indicators (KPIs), including OHS leading and lagging indicators, resource (water and energy) usage and efficiency, pollution prevention and control (air emissions, noise, effluents, solid/hazardous waste management) and dairy and beverage products food safety KPIs (ESAP#2). Solidiagui will ensure that needed corrective actions are implemented based on monitoring results.
Supply Chain Risk Assessment & Management. Key raw materials required for Solidiagui’s beverage operations include raw sugar, juice concentrates and skimmed milk powder. Sugar is supplied from the local market on a spot purchase basis, often imported from Brazil. Juice concentrates are respectively imported from Germany to produce Fruitalos juice (Solidiagui’s own brand), and from Vietnam to produce Sagiko juice. Skimmed milk powder will be imported from Belgium. Solidiagui does not currently plan to switch to fresh milk input since there is no sustainable local supply of fresh milk or juice in Guinea. The supply chain risk screening of the raw materials sourcing indicated that sugar is from a Bonsucro-certified sugar producer in Brazil, while there is a low risk associated with the sourcing of Fruitalos juice concentrate imported from Germany. These inputs, as well as the skimmed milk powder, do not originate from regions of concern for significant natural habitat conversion; therefore, PS6 does not apply. However, regarding the Sagiko concentrate sourcing in Vietnam, the input originates in a region of concern for significant natural habitat conversion and therefore PS6 applies. Solidiagui indicated that their supplier may not disclose the region of origination of the fruits in Vietnam, considering this information is confidential. IFC could not investigate further as this seemed a commercially sensitive inquiry. IFC could therefore not complete the biodiversity risk screening for this input and adequately assess the supply chain risk associated with the Sagiko juice concentrate.
PS2: Labour and Working Conditions
Solidiagui has a workforce of 35 workers, which includes 22 with open-ended contracts. The headcount includes 5 female workers of which one is a laboratory technician and the remaining 4 are factory operators. There is a pool of 50-55 daily workers hired for loading/unloading, cleaning and gardening activities. All workers categories are recruited on Solidiagui’s payroll. Solidiagui anticipates that the expansion project will create an additional 50 to 100 direct and indirect jobs.
Human Resource Policy and Procedures. Solidiagui indicated that it has drafted an HR manual and procedures, however these were not available for review during IFC appraisal. The company will adopt and implement human resources policies and procedures appropriate to its scale of operations and workforce that set out its approach to managing workers consistent with IFC PS2 requirements and national labor law (ESAP#5).
Working Conditions and Terms of Employment. Solidiagui’s permanent workers receive written contracts established in accordance with Guinean labor regulations, which specify entitlements and obligations, including working hours, probationary period, remuneration package and leaves. Daily workers however do not have any written record and are not registered. Factory supervisors and staff in administration and commercial functions have permanent contracts, while laborers are hired on temporary terms. Solidiagui’s payroll records confirm that the lowest grade employee salary is above the defined Guinean legal minimum salary; workers are paid overtimes as per approved rates. In Guinea, the minimum age for work is 16 (“Code du travail de la Guinée du 10 Janvier 2014”). Solidiagui checks workers age based on national identity cards. The factory operates 6/7 days on average 16 hours a day through two shifts (8am-4pm and 4pm-00am), this may be increased to three shifts in case of emergency when required for production targets. Shift workers take alternate breaks and Sundays are off. Shifts arrangements are aligned with local legislation and confirmed by the company’s labour inspection report. There are adequate changing rooms, toilets and shower facilities which respect gender sensitivities. Employees undergo a medical fitness test at recruitment certified by an external occupational health doctor as required by the national Occupational Health Authority. As part of ESAP#5, Solidiagui will develop record-keeping procedures and ensure registration of all employees for social insurance as required by local labor legislation. Solidiagui will update employee contracts in a manner consistent with Guinean labor laws and IFC PS2 requirements. To ensure employees are clear on their entitlements, Solidiagui will (i) ensure that all employees, including daily/casual workers, sign off on their duties and their benefits; (ii) implement a payslip system for daily workers compliant with PS2 requirements.
Grievance Mechanism. Solidiagui does not have a grievance mechanism for workers. The company will roll out a grievance mechanism for all categories of workers indicating (i) available channels to submit grievances (including separate channels for grievances related to sexual harassment, and for confidential and anonymous complaints); (ii) roles and responsibilities for treating and responding to grievances; (iii) timelines for taking action; and (iv) system to log, track and report grievances and their status in accordance with PS2 requirements. Solidiagui will also (i) implement support services for affected workers (e.g., medical services, counseling, legal assistance, job reassignment, etc.); and (ii) appoint a committee to monitor, channel and resolve received grievances. This procedure will be documented, and appropriate worker sensitization undertaken through in-person sessions and dissemination of information on online platforms and notice boards. Staff involved in managing sexual harassment grievances will receive additional specialized training (ESAP#6).
Workers Organizations. Guinean labor law mandates that employee representatives be formally elected for a minimum of 25 employees. As part of its HR policies update (ref. ESAP#5), Solidiagui will document a procedure demonstrating its support to freedom of association.
Workers Engaged by Third Parties. Solidiagui does not work with labour agencies for its operations. The installation of the dairy products line will require minimal work given the modular equipments are already at the factory. The company will use local contractors as manpower under the supervision of the suppliers.
Occupational Health and Safety. Solidiagui’s production lines are fully automated using modern machines with adequate safety features and limited moving parts. Potential OHS risks are associated with lifting, repetitive work, posture injuries, hygiene and falls on slippery surfaces. Workers are provided with personal protective equipment (PPE) such as hearing protection, masks, footwear, hygienic caps, gloves and working overalls according to their assigned workstations. There is an infirmary on site with a full-time nurse. Solidiagui is yet to develop an OHS management system, policies, standards, and records as required under IFC PSs. Solidiagui will develop an OHS Management System which will include adequate capacity, procedures for hazard identification, risk management, training and performance assurance, occurrence reporting, and performance measurement. These programs will be developed in line with Guinea’s OHS laws, WBG EHS General and Food and Beverage Processing Guidelines (ESAP#7).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gas Emissions. Key resources used at the factory include electricity provided by the national grid, diesel and water. Diesel is used in the boiler for steam production and when needed, to run the 100 kVa back-up generator. The year-to-date electricity consumption was approximately 400 MWh, equivalent to greenhouse gas (GHG) emissions of 184 tCO2e. With the expansion project, annual GHG total emissions are anticipated to be less than 25,000 tCO2e, including emissions from the boiler and the generator which is used less than 500 hours per year. Solidiagui’s vehicle fleet is relatively small as products deliveries are under the responsibility of the different customers/distributors. Solidiagui does not systematically monitor its resources consumption. As part of the ESMS (ref. ESAP#2), Solidiagui will develop an energy efficiency policy and procedures, and will implement relevant energy saving measures.
Water Supply. Currently, process water is abstracted from three on-site boreholes (of an average depth of 60m each) with valid water extraction permits. The water is tested at the factory laboratory to meet the beverage quality requirements. The current water storage capacity at the factory includes one 80 m3 tank for process water and a 30 m3 fire-fighting water retention tank; this capacity will be increased for the expansion project. The company does not record its gross water consumption, nor does it track groundwater withdrawal or water consumption within the process. An accurate water usage ratio (WUR) could thus not be calculated for the existing production line. This lack of accurate water accounting is likely to result in overconsumption or wastage. Although groundwater conditions around Conakry are quite favorable, and the World Bank (WB) and other donors are funding a lot of expansions of the networks over the next 10 years (using surface water), in the mid to long term, there is a risk that the sustainability of groundwater use in the area will come under pressure due to population growth, increasing urbanization and urban density, causing increased use of groundwater. This risk will be amplified by a rising use of latrines and septic tanks resulting in nitrate and bacterial pollution of the surficial aquifer. Solidiagui will seek a suitably qualified hydrogeology expert to (i) install nested piezometer within the premises of its factory (as far away from production well(s) as possible), for monitoring separately the groundwater levels of the surficial aquifer and the lower aquifer, and the water quality of the latter on a monthly basis; (ii) develop a monthly water monitoring program of the groundwater wells, as well as weekly monitoring of water use for various production processes and monthly monitoring of selected water quality parameters, bacterial and nitrate pollution from nearby latrines and/or septic tanks, (iii) develop monthly monitoring of water quantities abstracted and Water Use Ratio (WUR) assessment and benchmarking. Performance will be reported in the Annual Monitoring Report (AMR) to be submitted to IFC. Solidiagui will also pursue obtaining a connection to the SEG network (Société des Eaux de Guinée) such that the factory can switch to the use of surface water as soon as the capacity of AGESPI sponsored system has been increased (while maintaining its own groundwater wells as back-up during outages of SEG’s system) (ESAP#8).
Wastewater. Wastewater effluent is generated by the manufacturing process and the periodic flushing out of production lines and cleaning-in-place (CIP). This effluent is tested then sent to external drains before discharging into the environment. Sanitary effluent is disposed of in septic tanks. The AGEE environmental monitoring inspection in 2022 concluded that the effluent quality complied with Guinean effluent standards and recommended periodic monitoring; however, no further checks have been performed to date. The company indicated during discussions with IFC that it is in the process of implementing an effluent monitoring program and is considering installing a wastewater treatment (WWT) plant. Going forward, to ensure effluents are in line with WBG EHS Food and Beverage Processing guideline values, Solidiagui will (i) pursue the design and installation of a wastewater treatment unit; and (ii) implement a wastewater monitoring program to track effluent quality and ensure they are aligned with WBG EHS Food and Beverage Guidelines (ESAP#9). Performance will be reported in the AMR.
Air Emissions and Noise Monitoring. The main source of air emissions from the factory is the diesel-fed boiler (onsite genset being rarely used). Solidiagui conducts preventive maintenance routine per manufacturers’ instructions to optimize efficiency while reducing air emissions. Noise emissions are relatively low considering the nature of operations. As part of the ESMS defined under ESAP#2, the company will implement an air quality monitoring program consistent with WBG EHS Guidelines and national regulations as committed in the E&S mitigation measures.
Management of Solid/Hazardous Waste. Solid waste generated by Solidiagui’s operations include aluminum cans, plastic wrapping, empty juice concentrates containers and general waste. Beyond the site boundaries, there are significant quantities of PET bottles generated by end-consumers. Factory waste is temporarily stored in dedicated areas and recycled or disposed of by a licensed operator. Recycling is done for aluminum cans (sold to metal dealers) and empty containers. Other solid wastes are collected and disposed at the industrial Estate landfill. Main hazardous waste includes biomedical waste generated from the onsite clinic which are sent to a local licensed incinerator. However, there is no waste tracking record or reduction strategy. To minimize PET bottles waste generated by consumers, Solidiagui indicated that it was exploring collection and recycling options with local dealers but had not yet found a viable solution. As part of the project, Solidiagui will seek the support of a suitably qualified consultant to develop and implement a waste management plan consistent with GIIP and WBG EHS Guidelines, which will incorporate a timebound plan for implementing a PET bottle waste collection and recovery program, in collaboration with its products distributors and/or with environmental NGOs (ESAP#10).
Hazardous Materials. The main hazardous materials stored at the facility include fuel, lubricants, chemical reactants and detergents used in the cleaning process. The cleaning-in-place system (CIP) helps minimize the use of chemicals and water. Hazardous materials are adequately labelled, stored safely and handled in a dedicated room compartmented for chemicals segregation. Solidiagui will develop and implement a hazardous material management plan as part of its ESMPs (ref. ESAP#2).
PS4: Community Health Safety and Security
Food Safety Management System. Solidiagui has organized disinfection posts at the production hall entrance and provides staff and visitors with adequate PPEs. As indicated under ESAP#3, Solidiagui will implement a FSMS which will be certified against ISO 22001 and implement required control measures.
Traffic Safety. Solidiagui’s factory is well fenced, located in an industrial setting, and all operations are confined within the boundaries. Traffic at the factory includes supply and distribution logistics by customers trucks. The site is located away from neighboring communities, which limits traffic risks to off-site distribution operations. As part of the ESMPs (ref. ESAP#2), Solidiagui will develop a Road Safety Management Procedure, applicable to its own transport fleet and to its suppliers and distributors. The procedure will address driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards.
Security Personnel. The security arrangements on Solidiagui premises include armed police and private security personnel. In line with ESAP#2, the company will assess risks posed by its security arrangements in Guinea to those within and outside the project site and develop a Security Management Procedure (SMP), including a training module for management and security personnel. This SMP shall be aligned with the Voluntary Principles on Security and Human Rights and with the requirements of IFC PS4.
PS6: Biodiversity Conservation and Sustainable Natural Resources Management
Among its raw materials essential for its project (e.g. juice concentrates, skimmed milk powder and sugar), Solidiagui imports Sagiko juice concentrate from Vietnam, a region of concern for significant natural habitat conversion, triggering IFC PS6. Solidiagui indicated that their supplier may not disclose the region of origination of the fruits, considering this information as confidential and a key competitive factor. IFC was consequently unable to perform an accurate biodiversity risk assessment for this input and determine the acceptability of the supply chain risk. The supply chain risk screening of the sourcing of sugar indicated that the origination factory in Brazil which is Bonsucro-certified (as such compliant with IFC PS6), while there is a low risk associated with the sourcing of Fruitalos juice concentrate imported from Germany. These inputs, as well as the skimmed milk powder, do not originate from regions of concern for significant natural habitat conversion.
