If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the PSs.

This is a Category B project according to IFC's 2012 Policy on Environment and Social (E&S) Sustainability. The proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures and good international industry practices (GIIP).

Key E&S risks and issues for this investment include: (a) the company’s management and monitoring systems to assess and manage E&S impacts from: (i) R&D and MOE scale up technical efforts ; (ii) construction of the demonstration plants in Minas Gerais (Brazil) and the US; and (iii) supply chain of graphite anodes; (b) management of labor and working conditions and OHS practices; (c) emergency preparedness and response; and, (d) potential impacts to Atlantic Forest UNESCO Man and Biosphere Reserve resulting from operations in Brazil. 

E&S Management System (ESMS), Policy and Programs. Given the nature and scale of Boston Metal´s R&D and MOD modular semi -industrial validation efforts in US and Brazil, the Company identifies and manages E&S risks and impacts through compliance with applicable national standards and E&S regulatory permits and requirements. However, due to the Company’s short-term plans regarding development of MOE demonstration plant and further MOE commercial plant developments, BM will establish an overarching E&S policy and management programs (operational procedures, practices and plans) consistently with the principles of the IFC Performance Standards (PSs). Therefore, as per ESAP #1, the Company will establish an E&S policy and corporate level ESMS, aligned with IFC PSs.

Organizational capacity. Boston Metal’s E&S organizational capacity in the US is composed of an EHS officer reporting to the Vice President of People, Culture and Diversity and providing overall EHS support to the Director of Operations. The Brazilian subsidiary is supported by one EHS officer. With the ramp-up of its operations in Brazil and US, Boston Metal will expand its workforce and appoint qualified staff strengthen its capacity to manage environmental and social aspects (ESAP #2).

Emergency Preparedness and Response Plan. Boston Metal R&D premises in the US are located less than 5 miles from the Fire Department. The facility has an Emergency Preparedness and Response Plan (EPRP) outlining the means of egress and location of extinguishers. The EPRP for the pilot plant in Brazil is under preparation.

As per ESAP #3, BM will develop Emergency Preparedness and Response Plans (EPRP) for the new plant in the US and the plant in Brazil, covering construction and operations phases. The Company will assess potential emergency scenarios arising from its activities and identify communities and individuals that may be impacted. The EPRP will be updated regularly to reflect changes in the Company’s activities, cover own employees and contractors and include response procedures, provisions of equipment and resources, communication flows and designation of responsibilities.

Monitoring and Review. The Company’s monitoring and reporting activities are currently limited to OHS incidents and compliance reporting to national authorities (e.g., air emissions). As part of its new ESMS, Boston Metal will establish procedures to monitor its E&S performance and develop key performance indicators (KPIs) that cover HR, OHS, social and environmental aspects such as number of internal and external grievances, incidents, resource consumption and EHS related inspections (ref. ESAP #1). 

Working Conditions and Management of Worker Relationship. At the time of the appraisal, Boston Metal’s workforce in the US was composed of 104 direct workers, including 89 men and 19 women and 4 temporary workers (interns). As per local regulations, employees follow an at-will arrangement. BM’s direct workers benefits include paid vacation, sick leave and health insurance, among others.

Human Resources policies, benefits and obligations are outlined in the Employee Handbook. Boston Metal has an Equal Employment Opportunity Policy that includes provisions against any form of discrimination on the basis of race, color, religion or gender identity as well as provisions to provide equal opportunity employment for persons with disabilities. In addition, the Company has a Policy Against Harassment stating its objective to provide a workplace that is free of sexual or other forms harassment.

In Brazil, the Company currently has 9 direct workers and intends to expand its workforce to 200 workers by 2027. Boston Metal Brazil’s working conditions are aligned with national labor legislation and follow Sindimetal (metallurgist union)’s collective bargaining agreement. As per ESAP #4, the Brazilian subsidiary will develop an Employee Handbook and related policies and procedures, detailing employees’ benefits in line with the requirements of IFC PS2 and the Company’s policies for equal opportunity and harassment,

Employee’s grievances, including reports of harassment are currently managed through direct communications with the VP of People, Culture and Diversity or the line manager. As requested in ESAP #5, Boston Metal will develop a grievance mechanism for workers that is integrated across all its operations and document the grievance procedure. The procedure will indicate, among others, i) available channels to submit grievances (including confidential, anonymous and sexual harassment complaints); ii) roles and responsibilities for treating and responding to grievances; iii) timelines for taking action; and iv) a system to log, track and report grievances and their status.

Occupational Health and Safety. Boston Metal’s R&D premises have a gas detection system that continuously monitors levels of CO, SO2 and O2. Emergency showers and eyewashes are located inside the operation areas and exposure assessment are conducted for research experiments (e.g., carbon monoxide concentration, hexavalent chrome). In addition, the Company has a Safety Manual that outlines the framework for OHS controls, including electrical safety, use of equipment like cranes and forklifts, and machinery safety. However, specific operating procedures and job hazard analysis still need to be developed. At the time of the appraisal, OHS risk management procedures for Brazilian operations were under development. As required by ESAP #6, Boston Metal will further strengthen its OHS risk assessment and management programs by developing : i) job hazard analysis for each foreseen  working position ; ii) standard operating procedures for highest risks identified (e.g., log out tag out, work in heights); and, iii) procedures for the management, communication and investigation of incidents.

Supply chain. The Company purchases fabricated graphite and/or carbon electrodes for MOE from well-known international companies. Given the nature of its electrode supply chain, the Company will develop a Supplier Code of Conduct and incorporate contractual clauses in agreements with its suppliers requiring that suppliers and its sub-suppliers comply with its Supplier Code of Conduct which will prohibit the use of child labor and forced labor and includes OHS requirements in suppliers’ own operations ( ESAP #7).

Worker’s Engaged by Third Parties. Boston Metal relies on third parties for specific tasks such as maintenance or electric works. For the construction of its new facilities, the Company will engage the services of contractors for civil, mechanic, electric and hydraulic works. As per ESAP #8, the Company will develop a Contractor Management and Assurance Plan (CMAP), describing the controls to be implemented to ensure EHS risks are being properly managed. The CMAP will make part of contracts between BM and its contractors.

Main resources used in the MOE process include electricity, iron ore and metal oxides. The MOE technology does not require water and hence does not produce industrial liquid effluents.

For steel production, oxygen is the main subproduct generated in the MOE cell and low amounts of air pollutants such as particulate matter and SO2 are produced as a result of the reaction with metal oxides. For high value metals, a carbon anode is used, resulting in low amounts of CO. As requested by state regulations and the Company’s air permit, Boston Metals uses different available controls to further limit air emissions, including dust collectors for particulate matter, oxidizers for CO and dry adsorbents for SO2.

Boston Metal activities produce limited amounts of solid and hazardous waste and include waste oil, refractories from the MOU cell and domestic waste. BM engages the services of licensed third-parties for the final disposal of waste and will do the same for its operations in Brazil. Remaining slag resulting from the metal recovery process for high-value metals will be sent back to the facilities of Boston Metal’s partners for its final disposal.

Main hazardous materials used by the company include liquified petroleum gas, lead-acid batteries and flammable gases. As part of ESAP #9, Boston Metal will develop a procedure for the management of hazardous materials and install secondary containment for hazardous liquids

Road Safety. For the pilot program in Brazil, only one truck per month is expected to transport mine slag containing high-value metals in low concentrations from different sources which may be located 500km away from Boston Metal’s plant in Minas Gerais. Once high-value metals are recovered by MOE, residual materials will be returned to slag owner for final disposal. Materials will be transported in bulk bags. The frequency will increase to a daily roundtrip trip when the plant in Brazil achieves commercial phase in 2027. Due to transport safety risk, Boston Metal will develop a Road Safety Management Plan, addressing driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards (ESAP #10).

Emergency Preparedness and Response. As mentioned above, Boston Metal is in the process of developing its EPRP for its pilot plant in Brazil. As part of the ESMS and to reflect operational conditions, the EPRP will be adapted for the demonstration phase plant (ref. ESAP #1).

Security personnel. At the time of the appraisal, Boston Metal does not engage the services of security personnel for Brazil or the US. To address risks related to physical security once the demonstration plant starts operations, the Company will develop a Security Management Plan, including a security risk assessment in and in alignment with PS4 (ESAP #11). 

Boston Metal demonstration plant in Brazil will be located in the Cerrado Terrestrial Ecoregion, within the Atlantic Forest UNESCO Man and Biosphere Reserve. Boston Metal has purchased 20ha of land, containing Modified and Natural Habitat. Natural Habitat values are associated with the Atlantic Forest and grassland (‘campo limpo’).

At the commercial phase , the MOE plant will occupy around 3ha of land. The Company is currently conducting assessments of the area’s biodiversity values aiming at a baseline characterization. As per ESAP  # 12, before the demonstration phase, BM will submit a baseline characterization report, with focus on the existing biodiversity values within their property, including a technical characterization of the vegetation, and a rapid characterization of fauna based on indicator groups.

The company will set aside approximately six hectares of land containing forest and grassland as a legal reserve, in line with national legislation. As per ESAP # 13, BM will develop a Biodiversity Policy and management procedures to be implemented as part of its ESMS. The biodiversity management procedures will include the mapping of Natural Habitat with their property and mitigation measures to achieve No Net Loss. These measures will include the protection (e.g., against fire, degradation) and enhancement of the conservation status of existing Natural Habitat remnants within the Company’s property, including its legal reserve.

In addition, as per ESAP # 14, BM will engage with the Atlantic Forest UNESCO Man and Biosphere Reserve stakeholders to agree on the implementation of additional programs to promote the conservation aims of the MAB, as appropriate, with focus on the adjacent protected area Refúgio de Vida Silvestre Libélulas da Serra de São José. 

As part of its ESMS (ref. ESAP #1), Boston Metal will develop a Stakeholder Engagement Plan, including a stakeholder mapping exercise and the Company’s plan for an engagement process. In addition, Boston Metal will establish an External Grievance Mechanism to receive, track and address inquiries, concerns, and complaints related to the Company’s social performance from affected stakeholders and communities. The mechanism should be culturally appropriate and readily accessible, allowing adequate channels (including anonymous and confidential) and at no cost for claimers.

  Boston Electrometallurgical Corporation

+1 (781) 281-7657

info@bostonmetal.com

Woburn, MA 01801, United States

https://www.bostonmetal.com/