This is a Category B project according to IFC's Policy on Environmental and Social Sustainability (2012). Based on information reviewed by IFC, 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 associated with this project include: adequate development and implementation of a comprehensive E&S management system (ESMS) for potential expansions; human resources (HR) management including consistency of such across contractors in different countries; implementation of occupational health and safety (OHS) measures; adequate management of wastes and emissions; and emergency preparedness and response for fuel storage and handling.                                                   

Environmental and Social (E&S) Management System:

Addax follows its parent company, Oryx’s environmental health and safety (EHS) management system. The EHS management system is aligned with the objectives of IFC PS1 and commensurate with the scale and E&S impacts of its operations. The EHS compliance team conducts regular internal audits to review effectiveness of the QEHS programs and procedures and augments them based on monitoring. In addition, annual third-party audits are conducted to ensure compliance with ISO requirements.

Identification of Risks and Impacts:

Addax 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. Oryx/Addax routinely conduct EHS audits of storage terminals with both internal technical teams and external consultants.

Organizational Capacity and Competency:

Oryx/Addax’s has an established EHS organizational structure with knowledge, skills and experience necessary to monitor and maintain the EHS management system.  Each terminal (including those managed by management companies in Mauritania) has a designated safety coordinator, in charge of environmental, OHS, and operational safety aspects. The safety coordinators routinely check the fire safety passive and active systems, road tanker safety, tank loading, and road tanker filling operations.

Emergency Preparedness and Response:

All terminals have fire safety prevention rules, and documented emergency preparedness and response plans. All terminals have appropriate fire prevention and response services, including firefighting water tanks, firefighting hydrants and monitors, alarm systems and foam-based firefighting equipment (except for liquefied petroleum gases that do not need foam-based firefighting). The fire prevention and firefighting systems at all terminals were designed, constructed, and, in the case of the West Africa terminals, recently upgraded according to national building codes, and in accordance with EU building and fire safety codes and standards. The firefighting systems are properly maintained by staff or third parties at regular intervals. The firefighting systems are also fitted with high pressure water pumps, which can be powered by onsite diesel generators in case of power failure. As part of emergency preparedness and response plans, fire/ER drills are conducted monthly at each terminal (quarterly at the Nouadhibou terminal in Mauritania).

Monitoring and Review:

Regulatory inspections are conducted by relevant government departments for compliance with local EHS and operational safety regulations at all terminals. Oryx/Addax conducts annual or biannual EHS/operational safety audits for their own terminals. The partner company in Côte d’Ivoire also conduct its own safety audits. The inspection/audit reports with corrective actions are recorded for implementation and reviews by future inspections/audits.                                                   

Oryx/Addax have approximately 187 employees in four West African countries for this project, of whom 25% are women. Oryx/Addax do not have employees in Mauritania, as the Mauritania project is handled by a local company, Mauri Recrute SARL. The Mauritania terminal management companies have approximately 70 employees at each fuel storage terminal, including three women employees.

HR Policy, Working Conditions, and Terms of Employment:

Oryx/Addax HR policy and procedures are compliant with applicable Swiss labor laws, while the Mauritania recruitment company has an HR policy aligned with Mauritanian labor laws. The corporate HR policies are also consistent with the objectives of the PSs and apply to all employees and all affiliates in the Group. In addition, affiliates issue local HR policies addressing specific local elements where necessary.

Non-discrimination and Equal Opportunity

The HR policy specifies non-discrimination and equal opportunity. No procedures and/or practices have been identified as discriminatory. All the hiring and promotion are merit-based. There is no difference in terms of salary for female and male employees with the same experience. The HR policy has provisions relevant to respectful workplaces, including prevention of gender-based violence (GBV).

Workers’ Organizations and Grievance mechanism:

Oryx/Addax allows collective bargaining and employees are free to join the unions that fit their needs in the local situations. All the Mauritania Facility staff are unionized. All the employees can raise grievances anonymously through the union or HR management tracks. The HR policy has a grievance procedure which articulate how the grievances will be handled and resolved. The procedure is communicated to all employees as part of induction.

Occupational Health and Safety:

HAZID assessments have been performed for all terminals. Workplace risk assessments and monitoring are performed annually in compliance with the local regulations and Oryx/Addax procedures. OHS audits are also included in the routine EHS audit programs. All the road tankers are inspected for safety before being permitted to enter the terminals. The safety inspection includes permits check, exhaust spark prevention, brakes, etc.

For the West Africa Facility, Oryx/Addax provides all workers with appropriate personal protective equipment (PPEs) and enforces the PPE use strictly. Annual OHS trainings are also provided to all the staff handling hazardous materials. Regular HSSEQ meetings are performed in all terminals as well as weekly safety talks (toolbox meetings) to improve OHS and operational safety.

For the Mauritania Facility, the management companies provide all workers with personal protective equipment (PPE), and are working to strengthen enforcement of PPE use and OHS training.

Supply Chain:

Addax purchases energy products on the international spot market. Since Addax’s suppliers are mostly large crude refining companies and traders supplied by such crude refiners who do not rely on low labor costs for competitiveness, child or forced labor are not expected to be encountered among Addax suppliers.                                                   

Resource efficiency:

All terminals have two main energy sources: the national grid and standby diesel generator. All pumps are well maintained to ensure energy efficiency. Since no production process is involved in the terminals, the resource consumption is limited for this project.

Fuel Storage:

For the West Africa Facility, all four terminals were upgraded according to the EU building codes and standards. All tank storages areas have secondary containment dikes which hold at least 110% of the large tank volume. Specialized third parties are contracted to clean tanks and inspect tank integrity periodically.

For the Mauritania Facility, the Nouakchott terminal was built in 2005 based on EU building codes and standards for most of the safety features. Third party contractors are engaged to clean tanks and inspect tank integrity periodically. The Nouadhibou terminal was part of an oil refinery built in 1977 but ceased its refining operations in 2000, when it was converted into aboveground storage tanks with 268,000 m3 storage capacity. The renovation, which started in 2012 is ongoing. The management company routinely cleans the tanks and inspects the tank integrity.

Greenhouse Gases (GHG) Emissions:

There is no manufacturing process in these revolving credit facility transactions. Current GHG emissions from the existing operations (based on electricity and fuels) are limited and well below 25,000 tons of CO2-equivalent per year.

Pollution Prevention:

All terminals have vapor recovery installations for volatile fuels (e.g. LPG) to prevent emissions to air of volatile organic compounds (VOCs). Fugitive emissions are minimized through enhanced routine checks and equipment maintenances. There is no other significant air emission source at any terminal.

The only wastewater is sanitary wastewater, which is discharged to port/industrial park sewage systems. Solid and hazardous wastes are limited (mainly oil absorption pads) and are collected by port/industrial park for disposal by approved local environmental contractors.

Coastal Environment Protection:

The coastal environment will not be impacted in case of any catastrophes, such as structural failure or earthquake. There are barriers between all fuel storage tanks and the shorelines at terminals in the West Africa Facility, and the Mauritania Facility terminals are located approximately 2 km from the shoreline. The loading jetties were constructed or upgraded to EU building codes in respect to emergency shutdown, firefighting, and spill prevention features. There are routine EHS inspections and drills for coastal environmental protection according to International Maritime Organization (IMO) procedures.

The petroleum tankers are required to comply with all applicable environmental standards of IMO. The characteristics of the tankers must be certified to the standards by an independent control specialist in the field and approved by the manager of the terminals. Besides the certification, the petroleum tankers used for transportation of products financed under the Facilities must be less than 20 years old.                                                   

All terminals are located inside port/industry zones and there is no residential community near any storage terminals. Nevertheless, Oryx/Addax developed a Community Engagement Plan to manage its relationship with general public outside of the port/industry area and contribute to local community development programs. Oryx/Addax and the Mauritania management companies also have customer care numbers and websites as part of their external communication strategy.                                                   

Contact Person:  Stephen Paris, Chief Financial Officer

Company Name:  Addax Energy SA

Address:    12, Rue Michel-Servet ; CH-1211 Geneva 12 ; Switzerland

Email:    Stephen.Paris@oryxenergies.com

Phone:    + 41 58 702 9000