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 Impact
E&S Policies. Ferme Jambo currently has a rudimentary ESMS that will require enhancement to ensure it is commensurate to the E&S risks and impacts associated with the proposed project, and these are adequately identified and managed. Going forward, as a component of their ESMS enhancement, the company will define and implement an overarching E&S Policy that will apply to both the farm and milling operations (ESAP#1). The policy will detail the key environmental, social, and safety objectives and principles that will guide the company to achieve sound environmental and social performance aligned with the requirements of local legislation, IFC Performance Standards (PS) and principles and criteria of a credible agricultural standard (e.g., Rainforest Alliance or Global Gap for crops).
Identification of Risks and Impacts and Management Programs. The company currently identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. An Environmental Impact Assessment (EIA) was completed in 2016, as per the requirements of the general environmental law 11/009, for the existing farming operation. Key E&S risks identified included fugitive dust emissions, soil pollution due to accidental spills, occupational health, and safety (OHS), and noise. An EIA for the existing milling operation was completed in 2023. In addition, in 2023 the company conducted supplementary topographic, hydrology, and hydrogeological studies to inform their proposed irrigation requirements. Given the changes in proposed farming activities and irrigation infrastructure, coupled with the period of time since the farm EIA was completed, the company has already begun updating the two existing EIAs to ensure they reflect the current project description, incorporate any supplementary study findings, and adequately identify and assess potential project construction and operational impacts in accordance with local legislation, IFC PS1, and relevant World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines (ESAP#2). At the time of disclosure, the finalization of this updated EIA was underway.
In 2014, Ferme Jambo was granted the land use rights to approximately 7,000 ha of land and implemented an involuntary resettlement program to unencumber the land currently utilized for cultivation. The resettlement process included both physical and economic displacement of approximately 253 households. This was a government led resettlement process overseen by the Ministry of Land Affairs and conducted as per local legislative requirements, including the general property (Land Law) and Law 11/022 relating to the acquisition of agricultural land. In parallel with the EIA update, an independent resettlement assessment of the company’s resettlement activities was conducted in February 2024 to understand the process followed, the status of displaced persons, and identify any residual/ongoing impacts linked to land acquisition and resettlement for the project. The company currently utilize approximately 5,103 ha (Block A), and plan to expand this by an additional 2,000 ha (Block B) in the near future. While the company has received the land use rights for this land (Block A), community members still actively cultivate and reside on the Block B land and have yet to be compensated or relocated. As per ESAP#3, Ferme Jambo will define a Resettlement Policy Framework (RPF), aligned with the requirements of local legislation and PS5, defining their resettlement approach for all future resettlement activities, including those associated with Block B.
As a component of the original mill and farm EIAs, Ferme Jambo developed an E&S Management Plan (ESMP) defining the key E&S mitigation, management, monitoring measures, and roles and responsibilities. Going forward, the existing ESMP will be updated and refined to ensure impacts identified in the updated EIA (as per ESAP#2) are adequately managed as per PS1 requirements and applicable/relevant sections of the WBG EHS Guidelines (ESAP#4).
Organizational Capacity and Competency. The company currently operates with limited technical resources; hence the management of E&S risks, impacts and mitigation is the responsibility of the farm and mill managers respectively. To ensure appropriate E&S resources are commensurate to the scale and complexity of risks and impacts associated with the increased operations, the company will hire a qualified and full-time E&S manager to oversee the implementation and monitoring of all E&S management measures at both farm and mill. In addition, the company will also hire a local Community Liaison Officer (CLO) to oversee the implementation of the company’s stakeholder engagement framework and grievance management mechanism, and support on any future resettlement activities (ESAP#5). The company will also develop and implement an annual E&S training schedule covering key E&S management issues and OHS risks. E&S training will be conducted at both the farm and mill on an ongoing basis as per the defined schedule (ESAP#6)
Emergency Preparedness and Response. In relation to emergency preparedness, the company has a basic system in place consisting of a documented fire safety manual, periodic independent fire safety trainings, and equipment maintenance through an independent service provider. The company will develop and implement an Emergency Preparedness and Response Plan, including the identification of areas where accidents and emergency situations may occur (for both the farm and mill), individuals that may be impacted, response procedures, provision of equipment and resources, designation of responsibilities, communication, and periodic training for effective response (ESAP#7). The emergency preparedness and response activities will be commensurate to the nature of the operational risks and will be periodically reviewed and revised.
Monitoring and Review. Ferme Jambo’s current E&S monitoring and reporting is largely driven by local regulatory and permitting requirements, with periodic audits undertaken by local authorities. As a component of the ESMP (as defined in ESAP#4), Ferme Jambo will define an internal monitoring and reporting plan for the farming and milling operations, including the definition of key performance indicators (KPIs). The KPIs will be recorded and reported on monthly basis to the company’s management team.
PS2: Labor and Working Conditions
Human Resources Policies and Working Conditions and Terms of Employment. Ferme Jambo employs approximately 100 direct workers (approximately 80% local and 20% expatriate) as well as up to 500 seasonal workers (all local and from within the surrounding community). Direct workers are provided with either term or open-ended contracts, while seasonal workers are provided with weekly contracts. Seasonal workers are employed through local human resource contracting agencies. The respective farm and mill managers have oversight of all HR management and are supported by HR resources on site.
Ferme Jambo have defined their legally required terms of employment and working conditions through the Reglement d’Ordre Interieur (Rules of Procedure), however this does not provide a comprehensive approach to managing labor and working conditions. The company will develop, adopt, and disseminate a centralized and consolidated HR management procedure / handbook that will detail the company’s approach to managing their workforce in a manner consistent with PS2 objectives and local labor law (ESAP#8). This will include, where applicable, working hours, wages, overtime, compensation, and benefits, leave, performance reviews, right of association, health insurance, pension, termination procedures and grievance management. Additionally, the procedure will include an employee code of conduct (including management of sexual harassment and gender-based violence), and protection of the workforce (forced and child labor). The manual will be appropriate to the scale of the workforce and apply to direct, contract, and seasonal workers.
The company provides on-site accommodation at the farm for expat workers and its permanently engaged national staff. Ferme Jambo will conduct an assessment and gap analysis of the existing worker accommodation relative to the requirements of the IFC/EBRD guidance note on Workers’ Accommodation. Based on the findings the company will incorporate these into the time-based action plan to address identified gaps (ESAP#9).
Workers’ Organizations. As per the constitution and recently promulgated Law 23/027, DRC recognizes the right to form groups, unions, associations, and organizations. Currently none of the company’s workers have joined and/or formed a union or workers organization. As per ESAP#8, the consolidated HR management procedure will detail the company’s approach to freedom of association and collective bargaining in line will local legislative and IFC PS 2 requirements.
Non-Discrimination and Equal Opportunity. Ferme Jambo do not have a clearly defined policy relating to non-discrimination and equal opportunity within their workforce. As per ESAP#8, the company will define and adopt an approach in accordance with the requirements of local legislation and IFC PS2 requirements.
Grievance Mechanism. Ferme Jambo does not have a formal worker grievance management procedure, with grievances managed in an informal manner. The company will develop and disseminate an internal Grievance Management Procedure (ESAP#10). The procedure will be accessible to all workers, including seasonal workers and third-party contractors. The procedure will allow for both informal and formal grievance management and will detail defined reporting lines (including the option for anonymous complaints), communication timelines, and external dispute resolution. Furthermore, Ferme Jambo will maintain a grievance log of all received grievances, including their status, and report to senior management on a monthly basis.
Occupational Health and Safety. The company does not have a consolidated Occupational Health and Safety (OHS) policy or manual of standard operating procedures (SOPs), nor have any risk assessments been conducted at the farm or milling operations. OHS requirements are largely driven by local regulatory and permitting requirements. OHS KPIs for leading/lagging indicators and incident reporting is not implemented and monitored in a consolidated and consistent manner. Ferme Jambo will develop OHS SOPs to be adopted at both the farm and milling operations. In a manner consistent with GIIP as per applicable and relevant sections of the WBG EHS Guidelines, the OHS SOPs will address areas that include (i) the identification of potential hazards to workers, particularly those that may be life-threatening or cause long-lasting damage; (ii) provision of preventive and protective measures, including modification, substitution, or elimination of hazardous conditions or substances; (iii) training of workers; (iv) documentation and reporting of occupational accidents, diseases, and incidents (including KPIs); and (v) emergency prevention, preparedness, and response arrangements (ESAP#11). The company conduct periodic fire safety training at both the farm and mill that covers general awareness, prevention, evacuation, and fire safety. The farm and mill are equipped with fire extinguishers, while the mill is also equipped with hose reels and fire doors. Current life and fire safety protocols and training will be incorporated into the overall OHS Procedure as defined in ESAP#11.
Workers Engaged by Third Parties. Ferme Jambo make use of a limited number of third-party contractors, predominantly for labor and security requirements. As a component of their HR management procedure (ESAP#8), the company will formalize and document their third-party / contractor selection and management process/plan that will include the vetting and ongoing monitoring of contractors’ safety, compliance with labor law, and compliance with applicable health, environmental, working conditions and labor standards and policies. In addition, the contractor management process will ensure that all contractors have access to the Ferme Jambo employee grievance mechanism (ESAP#10) should they not have a suitable internal procedure available within their organization.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gases. Given the nature of Ferme Jambo’s activities i.e., primary crop cultivation and milling, energy requirements are relatively limited. Due largely to a limited and inconsistent municipal supply, energy for the farm is provided by a 275 kVA diesel generator. At the mill, energy requirements are mostly fulfilled by municipal power, which provides on average 50%-60% of the energy required, with backup power for the remaining 30%-40% provided by a 500 kVA diesel generator. Based on the energy consumption and agri-inputs consumption such as fertilizer and pesticides, annual greenhouse gas (GHG) emissions (Scope 1) are anticipated to be 2,648 tCO2e/year. The company are currently investigating supplementing their existing energy requirements with solar energy where feasible.
Water Consumption. IFC’s investment will finance the installation of irrigation and associated infrastructure for approximately 3,000 ha out of the total 4,000 ha current farming area. Based on an assessment of the hydrology and hydrogeology studies, it is anticipated that the company will need to utilize a combination of surface and ground water to ensure a sustainable approach that does not impact environmental flow and downstream users. As per ESAP#12, the company will develop and implement an Irrigation and Water Management Strategy defining: (i) their irrigation design detailing a phased approach to expansion, (ii) their water abstraction strategy informed by final hydrology and hydrogeology recommendations and ongoing monitoring of river flows and groundwater resources, (iii) their monitoring strategy and protocols for both surface and groundwater, and (iv) relevant regulatory and permitting requirements. This strategy will be developed/implemented in accordance with PS3 and applicable WBG EHS Guideline requirements.
Waste Management. Ferme Jambo produce limited quantities of non-hazardous waste, including plastic, cardboard, wooden pallets etc. Waste is stored in designated areas and collected by private service providers at both the mill and farm. Food waste is reused as fertilizer. As a component of the ESMP (ref. ESAP#4), the company will develop and adopt a Waste Management Plan defining their waste management strategy and approach to sorting, handling, storage, and disposal which are consistent with applicable legal requirements.
Hazardous Materials Management. Ferme Jambo currently has 14,000- and 40,000-liter diesel storage tanks at the farm. The storage tanks are equipped with bunding to contain accidental spillages. There are no diesel storage tanks at the mill site. The company stores potentially hazardous chemical inputs (pesticides, herbicides etc.) at the farm. These products are stored in a dedicated storage area that is only accessible to certified personnel. The Integrated Pest Management (IPM) program, that will be developed as a component of ESAP#4, will further define the storage and handling requirements of these inputs as required under PS3.
Pesticide Use Management. The company utilizes chemical inputs (insecticides, pesticides, fungicide, herbicide). As a component of the ESMP (ref. ESAP#4), Ferme Jambo will develop and adopt an IPM program in accordance with the requirements of IFC PS3 and applicable WBG EHS Guidelines. The IPM program will cover (i) selection of pesticides low in human toxicity, (ii) packaging and storage requirements, (iii) manufacturing by licensed and approved entities, and (iv) an appropriate application regime.
PS4: Community Health, Safety and Security
Community Health and Safety. Given the remote location of Ferme Jambo’s farming and milling operations, no significant additional impacts to the health, safety, and security of the local community are expected. Malambwe is the nearest community to the farming operation, approximately 3km away, while the milling operation is within the industrial area of Lubumbashi. The community of Malambwe currently utilize both groundwater (via shallow hand-dug wells) and surface water for the provision of potable and non-potable water requirements. While initial hydrogeological and hydrological assessments have determined that increased water requirements on the farm will not detrimentally impact groundwater availability within the community, Ferme Jambo, through their Water Management Strategy (ref. ESAP #12), will monitor the impact on groundwater availability, recharge, and quality including at sensitive receptors within the community. In addition, as per the requirements of the ESMP (ref. ESAP#4) Ferme Jambo will implement an ongoing air quality (predominantly PM10 and PM2.5) and noise monitoring and management protocol.
Traffic Management. The company currently has a fleet of five trucks that transport harvested maize to the mill and distribute the final maize flour to clients and distributors. These trucks are equipped with in-vehicle monitoring systems (IVMS) including GPS tracking and speed governing. As a component of the updated ESIA (ESAP#2), the company will assess the traffic impacts of the project, and where necessary, implement the appropriate management measures through the ESMP.
Security Personnel. Ferme Jambo make use of a third-party service provider for the provision of security services at the farm and mill. The number of guards at the farm depends on the season, and they are unarmed. The mill has 2 guards and 1 policeman on each shift. Given the varying and dynamic security risks associated with the farming and mill operations, as a component of the ESMP (ref. ESAP#4), the company will develop a group level Security Management Plan (SMP) that will include prescriptions for guard selection, rules of engagement (including minimum force), training, equipment, facilities, working conditions, grievance mechanism and others.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Protection and Conservation of Biodiversity. The Ferme Jambo farm is located within the wider Central Zambezi Miombo Woodlands ecoregion. While this ecoregion is characterized by floral diversity, the project area is largely modified habitat due to extensive subsistence cultivation and charcoal production. The farm is also surrounded by large agricultural concessions to the north, east, and west, with no protected or key biodiversity areas (KBAs) within a 10km radius.
Management of Ecosystem Services: The draft updated ESIA reports that many households in the project area are dependent on ecosystem services such as hunting, charcoal production, wood collection, and grass for thatching. Given that the company has already acquired and cleared the project land, further adverse impacts to priority ecosystem services, in relation to the current baseline conditions, are not anticipated.
Sustainable Management of Living Natural Resources. As Ferme Jambo are involved in the primary production of living natural resources i.e., the growing of maize and soy, the company will be required to manage these resources in a sustainable manner, through the application of industry-specific good management practices and available technologies. Ferme Jambo will implement sustainable primary production practices as per the requirements of codified and globally recognized standards as demonstrated by independent verification or certification (ESAP#13). As Ferme Jambo has yet to obtain independent verification or certification to such standard(s), the company will conduct a pre-assessment of its conformity to the applicable standard(s) and take actions to achieve such verification or certification over an appropriate period of time.
