All land purchased by Marifala was on a willing buyer-willing seller basis. There was no involuntary resettlement or, economic displacement. Therefore, PS5 is not applicable. The project is not impacting any indigenous peoples or cultural heritage. Therefore, PS7 and PS8 are also not applicable.

This is a Category B project according to IFC's 2012 Policy on Environment and Social Sustainability. The proposed project will have limited adverse E&S impacts which are readily addressed through existing mitigation measures and good international industry practices (GIIP). Key E&S risks and issues for this investment are: (i) company’s E&S management systems and staffing during the construction and operation of the wood processing facilities, warehouses and showrooms; (ii) assurance of fair, safe and healthy working conditions during the construction and operation phase for Marifala’s employees and contract workers, including occupational health and safety (OHS), emergency preparedness and life and fire safety; (iii) management of air emissions, wastewater and solid and hazardous waste; (v) community impacts due to its wood processing and sourcing operations, road traffic and use of security; and (vi) supply chain E&S requirements for raw materials, especially MDF.

 PS1: Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Policy. Marifala has draft corporate policy statements on (i) health, safety, and environment (HSE), (ii) code of conduct (CoC), (iii) anti-harassment, (iv) human rights, (v) human resources, (vi) workers accommodation, and (vii) community grievance. Marifala will upgrade and formalize these draft policies to align its E&S performance against IFC PSs for its projects and operations. The policies will be approved by Marifala’s Board of Directors and a communication/training plan will be delivered to all permanent and contractor’s workers (ESAP#1a).

Identification of E&S Risks and Impacts. Selection of the site for the greenfield factory by Marifala was based on E&S screening factors, such as pre-disturbed landscapes, land use, and limited social and ecological sensitivities. An E&S impact assessment (ESIA) study was conducted for the construction of the factory according to Guinean regulatory requirements, which included multiple specialist studies such as ecological, soil and geological, and socioeconomics. Based on IFC’s review of the local ESIA and consistent with PS1 requirements, Marifala will update the ESIA study (ESAP#1b) to cover the following issues: (a) road traffic impact assessment and community risks associated with transport of raw materials, finished goods, and personnel; (b) cumulative impact assessment from the proposed expansion and its supply chain including other raw materials like aggregates, sand, and laterite from borrow pits, and (c) gender base violence assessment.

Environmental and Social Management System. An E&S Management System (ESMS) is under development and covering Marifala’s wood processing factories, warehouses and showrooms. To date, Marifala has implemented E&S stand-alone management procedures and plans for its operations, including waste management, Occupational Health and Safety (OHS), emergency response and general operations procedures. Marifala has an overarching register capturing the E&S risks involved in its wood processing and furniture manufacturing operations. This document includes OHS risks developed from consultations with third-party wood suppliers and wood processing experts. To meet IFC PS requirements, Marifala will complete the development of its ESMS (ESAP#1c) including specific E&S procedures for overseeing contractor’s performance in relation to environmental, social, labor and working conditions, and OHS aspects, including contractor selection requirements / qualifications, monitoring procedures, and corrective actions in case of non-compliance. For the operations phase, Marifala will update and implement a factory-level ESMS, including the following elements: (i) identification and assessment of E&S risks and impacts; (ii) E&S management plans / programs at wood processing and furniture manufacturing factory, warehouses, showrooms, workers accommodation and wood sourcing activities, (iii) E&S organizational capacity; (iv) emergency preparedness and response, including L&FS provisions, (v) stakeholder engagement and community grievance mechanism; (vi) a legal register / permitting plan to track all licenses and permits; (vii) road traffic and Security Management Plan (SMP), including rules of engagement, appropriate conduct toward workers and community, and training requirements; (viii) Supplier Code of Conduct covering PS6 requirements; (ix) E&S monitoring/reporting procedures, including Key Performance Indicators (KPIs).

Management Programs. The corporate HSE policy include statements of commitment to zero environmental impact and the HSE manual highlights a set of HSE procedures and plans. Additionally, the local ESIA includes E&S Management Plans (ESMPs) which define mitigation measures on visual, heritage, soils, ecology, traffic, socio-economic, waste, and hydrological impacts. Marifala will integrate the requirements of the framework ESMPs, and any other additional programs as defined in the updated ESIA Study as per PS1 requirements into a construction phase ESMP (ESAP#1d). The E&S requirements applicable to Marifala’s industrial complex construction covered in the construction-phase ESMP will be implemented by Marifala’s construction team and equally included in tender documents and legal contracts of local contractors recruited to complete specific tasks during the construction of the industrial complex.

Organizational Capacity/Competency. Marifala’s E&S team has two officers across its operations, who are assisted currently by an ESIA consultant. The E&S personnel are responsible for the implementation of the E&S management plans, as defined in the local ESIA Study. They also act as interface / liaison with the community and factory neighbors. The ESIA consultant, recruited in January 2023, has been responsible for the community consultation as part of the ESIA. Marifala has approved a project management organogram for the construction phase of the factory complex which includes (i) a health safety and environment (HSE) officer, (ii) a human resource (HR) Director, and (iii) three HR officers. As part of the IFC investment, Marifala will strengthen its EHS department by appointing a full time E&S manager for the construction and operations (ESAP#1e) freeing up the HSE officer to concentrate on OHS issues. The E&S manager will oversee all environmental, social and community relations activities, including the implementation of the corporate ESMS, the existing ESMPs and proposed new ones as per the updated PS-compliant ESIA study, and the supply chain traceability and risk screening process (ref. ESAP#5).

E&S Training. Permanent and temporary employees at the factories receive EHS training during pre-employment induction and refreshers, which includes emergency response procedures, hazard communication, injury prevention and use of PPE, first aid, fire prevention, chemical handling, and hygiene. As part of the development of the industrial complex ESMS, Marifala will implement a EHS training program on all updated EHS policies, SOPs manuals, general EHS awareness, risk identification, management plans including worker's grievance mechanisms, security emergency response, KPIs for E&S monitoring and reporting as well as equipment safety and on the job training for all high risks workstations (ESAP #1f).

Emergency Preparedness and Response. Marifala has an operational emergency response plan documented in the form of a chain of actions to be undertaken during an incident. The plan identifies muster points at each of its factory and has trained incident commandos and first aiders. Drills are also undertaken as part of this procedure. The plan addresses essential emergency equipment and facilities, such as firefighting equipment, fire alarm systems, and first aid kits. As per IFC PSs requirements and ESAP#1c, Marifala will update the emergency response plan with requirements included in the updated ESIA covering factory construction, offsite scenarios like spills and additional requirements from the transport risk assessment and health emergency preparedness including but not limited to availability of medical personnel, ambulance or factory health clinic and medical evacuation drills and will also ensure that the procedure is communicated to the local communities on measures they take in the event of an emergency.

E&S Monitoring and Review. Marifala undertakes regular E&S monitoring and reporting of its activities through HSE management meeting, weekly inspections, and internal quarterly audits for each factory. The monitoring captures aspects of waste management and overall OHS performance through some key indicators. The Terms and Conditions (T&Cs) of the environmental license based on the local ESIA study required regular reporting of the implementation of the ESMPs to relevant authorities. In accordance with IFC PSs requirements, Marifala will incorporate its monitoring and review requirements into its ESMS along with a consolidated E&S monitoring plan (ESAP#1g) in line with PS1 requirements and applicable sections of the WBG EHS Guidelines (General and Saw-milling and wood-based products).

Supply Chain Risks and Management. Marifala’s business relies on forestry inputs. There is a risk of conversion of natural forests and critical habitats. The project currently sources forestry products (medium-density fiberboards) from third-party suppliers in Europe and its hardwood (not covered under current investment) is sourced locally. The MDF supplier is ISO 38200 certified thus follows the requirements for a chain of custody (CoC) of wood and wood-based products, cork and lignified materials other than wood, such as bamboo, and their products. Marifala has a generic procurement procedure which details how goods and services are procured and controlled. The existing procedure will be updated to meet the recommendations made following IFC’s screening process as detailed in the PS6 section below.

PS2: Labor and Working Conditions

Marifala’s current workforce is 314 individuals (91% male; 9% female) and is anticipated to grow to 700 with the proposed expansion. During construction phase, some tasks will be contracted, such as civil works, concrete works, electrical works, plumbing and fencing. Most workers will be accommodated in living quarters to be constructed within the industrial complex.

Human Resources Policies/Procedures. Marifala is in the process of formalizing its corporate HR policies and procedures which define its HR approach. The procedures currently available are: (i) roles and responsibilities of HR and management; (ii) HR planning; (iii) temporary workers management, (iv) recruitment; (v) training; and (vi) wages / compensation. Marifala has a set of rules in its CoC which presents the overarching expectations of Marifala employees. As per IFC PSs requirements, Marifala will update its HR manual for specific guidance on (i) prevention of child and forced labor; (ii) non-discrimination and equal opportunities and zero tolerance policy on sexual harassment; (iii) OHS; (iv) workers accommodations; (v) freedom of association and collective bargaining; (vi) supply chain management system and supplier code of conduct; and (vii) Grievance management for workers which should be accessible for workers to raise complaints on GBV including survivor centered approach and training of HR to address this issue (ESAP#2a).

Working Terms & Conditions. Marifala meets national labor law requirements for working hours - maximum of 8 hours a day and 40 hours a week with a maximum allowable paid overtime of 2 hours a day. Marifala workers are contracted through various labor contracts including (i) internship conventions for interns, (ii) permanent contracts, (iii) fixed term contracts, and (iv) apprenticeship contracts. Terms of contracts are well defined with remuneration and other incentives, including living conditions, transport and lodging and enrolment of employees into the national social insurance scheme.

Non-discrimination and Equal Opportunity. Marifala applies a practice of non-discrimination and equal opportunity in recruitment as both males and females are employed at their factories and showrooms despite the uneven distribution. The tailoring sector and showrooms are dominated by female employees while the wood processing units were male dominated. Marifala however does not have a written policy in place to ensure that its non-discrimination and equal opportunity drive is clearly communicated and understood. As part of the update/strengthening of its HR Management System, Marifala will develop such policy and procedures including ensuring that interns or apprentices of age group between 15 and 17 are not exposed to any form of harmful child labor through choosing adequate workplace conditions (i.e., OHS conditions including exposure to machinery, toxic substances, dust, noise, and ventilation), work hours, and nature of the tasks (ref. ESAP #2a).

Workers Organization. Marifala does not have a collective bargaining agreement with a trade union that represents the workers from the wood sector. The employees do not belong to a union for the moment, but they are free to unionize as confirmed by the HR manager and employees interviewed. The workers have a social commission through which employees’ concerns are channelled with no personnel delegates elected to date. As per ESAP#2a, freedom of association and collective bargaining will be formalized and communicated to the workforce.

Protecting the workforce. All Marifala workers are contracted through Marifala's HR recruitment procedure, which is compliant with applicable national legislation including, working hours, remuneration and age limit and other labor requirements consistent with pillars of the International Labour Organization (ILO) to which Guinea is a signatory. No employee is less than 18 years of age.

Workers engaged by third-parties. Marifala hires its workforce directly and only uses third party service providers for its security agents. Third-party contractors are directly managed. A Contractor / subcontractor management plan / procedure will be developed as part of the ESMS (ref. ESAP#1c) to establishes policies and procedures for managing and monitoring the labor/OHS performance of third-party employers like security company currently providing agents to secure the factories and showrooms. If the third-party is not able to provide a grievance mechanism, Marifala will extend its own grievance mechanism to serve workers engaged by the third-party workers.

Worker’s Grievance Mechanism. Marifala has no formal grievance management procedure for employees. Marifala’s internal rules however permit the anonymous filing of complaints or suggestions through suggestion boxes installed at its factories. There is no complaint register but a disciplinary register is maintained by the HR department to track disciplinary actions. As part of the strengthening and formalization of the HR manual and grievance management process as per PS2, a workers grievance procedure will be developed and communicated to all employees (ref. ESAP#2a).

Occupational Health and Safety. The main OHS risks of workers in wood processing include: (i) injury from sawing and drilling or rotatory equipment, (ii) intoxication from hazardous chemicals, (iii) illnesses from exposure to dust and noise; (iv) fires, explosions from wood dust collection systems and accidental emissions of hazardous substances, and (v) contamination as a result of spills of liquids used for wood treatment, leaks in tanks, disposal of liquid waste and incidents involving hazardous substances. Marifala has several elements of OHS management system in place at its existing factories. The HSE department has two officers who cover OHS at the level of the factories daily and supported by an OHS Committee constituted by workers from different segments of its production chain. The draft OHS policy and standard operating procedures (SOPs) commits to achieving zero harm on the health and wellbeing of all its employees, contractors, and neighboring communities. Marifala's current drive to OHS is reflected in the safety culture recently rolled out across its activities following a 2021 fire incident which consumed one of its wood processing facilities in Conakry. Marifala’s Lost Time Injury Frequency Rate (LTIFR) according to the limited company’s records (2022 only) is 5.7, higher than the US OSHA statistics for this sub-sector. The existing safety culture requires further strengthening to ensure consistent compliance with GIIPs including but not limited to use of PPE, signage at the factories, staircase safety, use of ladders, working at heights, confined spaces, housekeeping, man-machine interface, pinch points, use of SOPs, medical coverage, and welfare facilities. As part of this IFC investment, the existing HSE manual of procedures will be expanded to meet relevant Guinean regulatory and IFC PSs requirements, as defined in ESAP#1c, #1d, #1e, #1f, #1g & #2a. Marifala monitors its OHS performance using KPIs (frequency, severity, and time lost). These KPIs should include leading and lagging indicators like near misses and first aid cases. Marifala will strengthen its OHS management system, including (i) developing a process to map critical workplace hazards and methodology for continuous risk identification and assessment as part of the OHS management system; (ii) implement corrective action plan (CAP) program, and (iii) develop OHS KPIs for monitoring and reporting (ESAP#2b).

Supply Chain. The MDF supplier for the project follows international standards and implements a supply chain code of conduct which involves prohibition of child and force labor within its supply chain. Other suppliers of leather and foam as well as various local suppliers of material other than wood were not screened. To address any labor risks related to its supply chain, Marifala will develop a Supplier Code and Supply Chain management system consistent with PS2 requirements (ref. ESAP#2a).

PS3: Resource Efficiency and Pollution Prevention

Power Supply. Electricity for Marifala industrial complex at Mafarenyah will be supplied from the national grid. The two existing factories in Conakry are connected to the national grid power supplied by Electricite de Guinee (EDG). Electricity demands for existing facilities is estimated at 420,269kwh. Standby diesel generator sets (gensets) are available at the existing factories to keep the factories operational during frequent power outages. A 1200kva genset has been sourced for use at the proposed industrial complex. 

Water consumption. The construction of the industrial complex will utilize water supplied from a borehole. Water will be used for construction activities, domestic use and dust control. The wood processing and manufacturing of furniture uses limited amount of water. Marifala’s current annual water consumption is estimated at 180,000 litres and projected to reach 624,000 litres following the expansion. Marifala has constructed three boreholes at its two wood processing facilities in Conakry and one newly sunk borehole at the proposed industrial complex site. The boreholes will remain operational during the construction and operations phases of the industrial complex. The combined productivity of these boreholes is not known / monitored. As part of IFC investment, Marifala will undertake a sustainability yield assessment and develop a water management plan including water use efficiencies, as per the updated PS-compliant ESIA, install meters and undertake a water monitoring program (ESAP #3a) in accordance with GIIPs and the WBG EHS Guidelines.

Air Quality. The principal source of air emissions during the construction phase of the industrial complex relates to dust emissions from land preparation, earth moving equipment, transportation of building materials, and construction equipment. During the operation of the industrial complex, the source of air emissions will be residual saw dust that may escape from the dust extraction system within the wood processing factory and dust emissions from transport related operations, including raw materials and finished furniture. The road traffic risk assessment and transport management plan to be developed as part of the ESIA (ref. ESAP#1b) and the construction phase ESMP (ref. ESAP#1d), will include measures for dust suppression and the postponement of dust-generating activities during periods of strong wind. Air emissions from the dust extraction system will be monitored within the complex and at sensitive receptors during construction and operations phase.

Greenhouse gases. Generation of greenhouse gases (GHG) associated with Marifala wood processing and furniture manufacturing expansion project will be limited to fuel combustion and transportation of equipment and employees to the site during construction. A back-up diesel generator (1200kva) will be used prior to connection to the grid and / or when there is grid power outage. During operations, GHG emissions will be associated with fuel combustion during transport of raw materials and delivery of finished goods to showrooms and end users. Marifala’s annual fuel consumption is projected to reach 300,000 liters with the expansion. Marifala will monitor/report its fuel consumption (ref. ESAP#1g).

Noise. During construction of the industrial complex, noise may be generated from equipment, vehicles, machinery, transportation of construction materials and transport of staff to and from site, establishment of site construction areas, and general construction activities. The ESIA concludes that noise levels and impacts will be short-term and are not expected to be significant during the construction phase for communities given the closest sensitive receptors are 300 meters away. During operations, the wood processing and furniture manufacturing machines would generate daytime noise that could be detrimental to the workers within the complex and receptors in the Gore, Oularéyah and Kenede communities in proximity to the industrial complex. Mitigation measures have been included in ESMP section of the local ESIA to reduce negative noise impacts during the construction and operation phases, including engineering barriers, which effectiveness will be verified by regular monitoring of the noise level (within the complex) and at sensitive receptors (ref. ESAP#1e)

Effluent management. No discharge of wastewater will take place during construction or operations of the industrial complex. Moderate volumes of domestic sewage are expected during both phases and will be limited to ablution facilities. Portable sanitation facilities (i.e., chemical toilets) will be used during the construction phase. A septic tank will be used and emptied regularly by a certified service provider during the operational phase. Marifala will update its effluent management plan to include on-site handling, transportation, treatment, and final disposal by qualified providers in accordance with Guinean regulations and applicable sections of the WBG EHS Guidelines.

Waste Management. During the construction phase, solid waste will include (i) packaging material, such as the cardboard, plastic and wooden packaging and off-cuts, (ii) hazardous waste from empty tins, oils, soil containing oil and diesel (in the event of spills), and chemicals; (iii) discarded bricks, wood and concrete, (iv) domestic waste from chemical toilets, and (v) vegetation debris from land preparation. Solid waste currently generated from Marifala’s facilities is disposed at the Daresalam landfill operated by a private company in partnership with the municipality in Conakry. Any hazardous waste (such as contaminated soil from spills) will be temporarily stockpiled in designated areas on site, and thereafter removed from site by a suitable service provider for safe disposal at a registered hazardous waste disposal facility. Marifala will include in its waste management process a due diligence procedure of any third-party waste facilities to be used for hazardous and / or non-hazardous waste disposal (ESAP#3b).

Storage of Hazardous Materials. The manufacturing of furniture presents a moderate risk of hazardous materials. Some limited quantity of solvents and spray paint used to protect wood or color it and diesel used for standby gensets are stored in dedicated hazardous material storage and room within Marifala’s factories. A 1200kva genset has been procured for use in the proposed industrial complex. During construction of the factory, hazardous materials including diesel and hydraulic oil shall be used by construction equipment and plant. The management (handling, storage, usage, and disposal) of these materials including diesel reservoir in secondary containments aligned with WBG EHS Guidelines will be covered in the waste management plan developed as part of the ESMS (ref. ESAP#1c).

PS4: Community Health, Safety and Security

Community Health and Safety. At peak of the operation of the industrial complex, estimated 700 workers will be required. These workers will be drawn from Fandie districts and Conakry, within a radius of 100 km from the project site. Worker’s accommodation will be within the industrial complex. The ESIA has adequately assessed the increase in community health and safety risks during the construction phase, including (i) nuisance from noise and dust, (ii) increase in construction related road use leading to increase in road traffic accident risk, and (iii) risks of increased GBV and sexually transmitted infections (STIs) due to worker / community interactions. As per the updated PS-compliant ESIA (ref. ESAP#1b) and the ESMS (ref. ESAP#1c), Marifala will develop/implement a consolidated community health and safety management plan which will integrate the mitigation measures from the ESIA study to manage gender base violence and community health and safety risks, including transport related risks for communities along transport routes of raw materials and finished products (ESAP#4a).

Road Traffic Safety. Marifala’s operations are supported by a fleet of two heavy vehicles, two forklifts, one front end loader, four light-duty vehicles and five motor bikes. Road traffic safety (RTS) risks of Marifala’s operations are currently rated as moderate in the local ESIA but will increase with planned expansion. The ESIA identifies increase traffic on the 800m long access road to the industrial complex and recommends risk mitigation measures, including road upgrade, dust monitoring, road safety signage, speed control and enforcement of a maximum speed of 40km/h along the access road as well as compliance with national speed limits while on surfaced roads. Marifala will ensure that all third-party vehicles hired for the project are in good operable state and the drivers are trained in project EHS requirements, including road safety measures and safe / defensive driving (ref. ESAP#1f).

Security Personnel. Security measures for the industrial complex will include (i) fencing, and (ii) third party security contractors primarily used for access control (unarmed). Marifala will undertake a security risk assessment to include both construction and operations phases of the project. The outcomes of the security risk assessment will determine the contents of the project level security management plan (SMP) for both construction and operations phases. The SMP shall include provisions for security providers in terms of selection of security personnel, rules of engagement (including use of force), appropriate conduct toward workers and communities (including training on HR and GBV), monitoring of security personnel workers and grievance mechanism to receive complaints about the security arrangements and personnel including complaints around gender base violence and sexual harassment (ESAP#4b).

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resource

Marifala is sourcing MDF from Europe to produce furniture at its two factories in Conakry as well as some amount of hardwood from the local market. The timber source areas in Guinea present a risk of significant conversion of natural / critical habitat. The MDF is from certified sources and supplier in Spain. The Guinean hardwood is subject to a government verification process. This process is not fully aligned with IFC PS6 requirements, and the risk of ongoing conversion cannot be excluded, reason why hardwood is excluded from this IFC financing. As part of IFC investment, Marifala will (i) develop a sustainable raw materials sourcing strategy, including a third-party MDF supplier screening protocol to ensure all wood products are sourced from certified or equivalent verified suppliers compliant with IFC requirements; (ii) develop a Supplier Code aligned with IFC PS6 requirements to be signed by all MDF suppliers as part of sales agreement, which will include shifting away from suppliers where risk of natural/critical habitats exists; and (iii) define procedures for monitoring the implementation of the company strategy (ESAP #5).

Community engagement of project affected communities in the vicinity of the proposed industrial complex took place during the ESIA process. The community raised issues related to local employment during the construction and operations phases. In response to past complaints, Marifala has strengthened its engagement with the affected community around its existing factories in Conakry, including agreeing on a timeline for the two wood processing operations to be moved to the new site in Mafarenyah. As part of this project, a stakeholder engagement plan (SEP) will be prepared building from the ESIA consultation process (ESAP#6a). The stakeholder engagement plan will make provisions for ongoing feedback to the community.

Consistent with PS1, Marifala will develop a community grievance mechanism (CGM) prior to construction activities which will be in effect for the duration of the project (construction and operations) (ESAP#6b). The CGM will allow for the submission and management of grievances (including lodging of anonymous grievances) and reporting, feedback loops and monitoring and resolution of identified systemic issues. Like the worker GM, the CGM be accessible for community members to raise complaints on GBV which should be handled in survivor centered manner. Where a resolution cannot be achieved internally, the CGM will allow for external redress using independent parties. The E&S Manager/Supervisor (ref. ESAP#1f) will be responsible to receive/follow-up on grievances and act as the interface between Marifala, its contractor(s) and the communities on E&S matters, including recruitment of local workers and management of grievances from Contractor’s actions and activities.

Company: Groupe Mari Fala SARLU

Point of Contact: Abdoulaye Diallo

Title: Chief Executive Officer

Telephone: +224 657 00 08 16

Email: contact@groupmarifala.com

Mailing Address: BP 1980 Conakry, Republique de Guinee

Website: www.groupemarifala.com