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.
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, and readily addressed through good international industry practices (GIIP), including those reflected in the E&S Action Plan (ESAP) attached to this document. Key E&S risks and issues for this investment are (i) Afropa’s capacity to develop and implement plant-level E&S/food safety management systems (ESMS/FSMS); (ii) capacity and competency of its ESMS/FSMS functions; (iii) fair labor and safe working conditions, including terms of employment and OHS working conditions for direct employees and contractors, including Gender-based Violence (GBV) risks; (iv) emergency preparedness and response plan, including life and fire safety (L&FS) at both facilities; (v) energy/water usage and efficiency; (vi) pollution prevention and control; (vii) traffic safety and use of security forces; (viii) community engagement and community grievance mechanisms.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Policies. Afropa does not have a written E&S policy. The existing operations are managed through undocumented OHS management programs, neighboring community’s welfare, resources efficiency, solid waste management, and fair recruitment. To appropriately define its E&S commitment and address the risks posed by the current operations and proposed expansion/refurbishment, Afropa will develop plant-level E&S management system (ESMS) aligned with IFC PS1 for its two plants. Specifically, the ESMS will include the following elements: (i) policy; (ii) identification of risks and impacts; (iii) management programs; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) stakeholder engagement community grievance mechanism; and (vii) monitoring and review (ESAP#1). The E&S management procedures to be developed and implemented as part of the ESMS will include: (i) environmental, (ii) occupational health and safety (OHS), (iii) resource efficiency (energy/water use and efficiency, including water use ratio - WUR); (iv) effluent, ambient air quality, noise and solid/hazardous waste management and storage; (v) emergency preparedness and response procedure, including L&FS; (vi) stakeholder engagement procedure and community grievance mechanism; and (vii) a community health and safety procedure, including food/road safety and use of security.
Identification of E&S Risks and Impacts. Elements of a legal register has been sighed during IFC appraisal, including review of copies of operational permits and licenses for the beverage facilities in Liberia and Sierra Leone. These included lease agreements and EIA regulatory monitoring and compliance documents, for Liberia and Sierra Leone. The E&S risk assessment and mitigation measures at the Liberia beverage facility is part of the quality certification obtained from the Liberian authorities. Afropa undergoes comprehensive inspection of its operation from Liberia Standards Authority, Ministry of Health, and Labor Inspectorate on a regular basis. Afropa will develop an E&S risk assessment procedure and matrix for its Liberia and Sierra Leone plants, including risks associated with Afropa’s water / beverage production activities, owned vehicles, warehouses, and laboratory. The E&S risk assessment matrix will also include third-party contractors (ESAP#2a). As per regulatory requirement in Sierra Leone, Afropa has commissioned a PS-compliant ESIA study and will implement the resultant E&S Management Plans (ESAP#2b). Afropa will also seek a qualified water consulting firm to conduct a specific risk assessment of impacts on groundwater resources due to water abstraction and wastewater discharge, as per agreed the Terms of Reference provided by IFC during the appraisal (refer to PS3 section on raw water supply) (ESAP#2c).
E&S Management Systems. Afropa is in the process of establishing an integrated ESMS, including EHS’s standard operating procedures (SOPs) and management programs for the facilities in Liberia and Sierra Leone (ref. ESAP#1). Performance-based EHS requirements of this E&S management system will be based on compliance with national EHS/HR legal and regulatory requirements, IFC PSs requirements and WBG EHS Guidelines for beverage production.
EHS organizational structure and competency. The facility’s general manager for the Liberia facility is responsible for overseeing statutory EHS compliance. The operations manager and a team composed of line managers, HR manager, technical manager, and production manager, are responsible for EHS monitoring and reporting. The operations manager reports to senior management through weekly meetings to discuss operational issues, including quality and EHS issues. Afropa will recruit a full-time E&S officer to be responsible for the implementation and co-ordination of the ESMS for its Liberia and Sierra Leone plants; management, monitoring and reporting on EHS performance; coordinating investigations of workplace injuries and incidents and corrective actions and reporting; managing environmental, occupational health and safety, resource efficiency, EHS training including road safety training and management of community grievance mechanism (ESAP#3a). Afropa will develop and implement an annual EHS training program applying to its facilities. The training topics will be informed by Afropa’s policy commitments, risk assessments, and findings of internal/external audits (ESAP#3b).
Emergency Preparedness and Response. The facilities in Liberia do not have a documented emergency preparedness and response procedure. Afropa has provided for first aid kits, fire suppression equipment and emergency assembly points. Afropa will develop and maintain an emergency preparedness and response procedure and plan for its Liberian and Sierra Leone facilities. The procedure will describe potential emergency scenarios and specifies responsibilities, measures, and resources necessary in line with national laws and PS1 requirements (ref. ESAP#1). The emergency procedure and plan will be communicated to neighboring communities.
E&S Monitoring and Review. The facility in Liberia has limited monitoring oversight of E&S parameters which will be broadened to capture IFC PS requirements, including those in the WBG EHS Guidelines for beverage production. Water quality analysis is undertaken at its own lab which is ISO certified. Based on results shared during the appraisal, all water quality parameters are meeting local regulatory drinking water requirements. Afropa will develop a corporate level EHS monitoring framework in line with applicable regulatory requirements, IFC PS requirements and WBG EHS Guidelines, as part of the above mentioned ESMS manual (ref. ESAP#1). The EHS monitoring and reporting system will include the definition of Key Performance Indicators (KPIs) on environmental, HR, OHS and social performance of its operations. Monitoring parameters, frequencies and methodology will be defined in the ESMS, and data will be stored in a centralized database for periodic reporting.
PS 2 – Labor and Working Conditions
Afropa has 48 workers for its two production lines (ref. mineral water and carbonated soft drink) in Liberia. Casual workers, from the facility’ surrounding communities are offered ad-hoc tasks depending on workforce requirement and skillset. The key differences in working terms & conditions between full-time and casual workers are in terms of benefits, above and beyond salary payments. The facility in Sierra Leone will employ a similar number of workers.
Human Resource Policy & Management. There are currently no HR policies and/or procedures in place at the Liberia and Sierra Leone facilities. In accordance with IFC PS2 objectives, Afropa will develop and implement HR policies covering non-discrimination and equal opportunity, child labor, forced labor, freedom of association, and sexual harassment and procedures (covering recruitment; induction; retrenchment, terms and conditions of employment; OHS requirements; performance management; procedures for workers representation or committees in the absence of a union; disciplinary procedures including explicit provisions for sexual harassment, labor grievance mechanism; termination of contract and dismissal; and workers engaged by third parties). These HR policies & procedures and worker’s grievance mechanism will apply to all workers, including those employed by any contractor/sub-contractors and will be readily accessible and clearly communicated at induction and through the provision of additional sensitization and training (ESAP#4). Afropa has designated a resource-person for managing employee contracts. Afropa will strengthen its HR function and management capacity at both facilities to manage additional HR aspects through the recruitment of an HR manager. This manager will be responsible for the development and implementation of HR policy and manual of procedures and handle the worker’s grievances mechanism (ESAP#5).
Working Conditions and Terms of Employment. Afropa employees receive employment contracts, which were reviewed during appraisal. Deficiencies against national Labor Law and PS2 have been identified. The Liberia facility operates 24 hours a day and stops only for scheduled maintenance or when required. Operational staff are composed of two teams, alternating on 12 hours rotational shifts, and running seven days a week. While workers are paid for the overtime at the end of each week, Afropa does not have a procedure to monitor overtime. Administrative staff work 40 hours a week. Afropa minimum wage is set above the statutory minimum wage in Liberia. Afropa’s HR manual will explicitly indicate training period, contract renewal, working hours and overtime, employee duties, salary and compensation, statutory salary deductions, confidentiality, disciplinary measures, offences leading to dismissal, resignation, and termination conditions aligned to national labor laws and PS2 requirements (ref. ESAP#5). To ensure employees well understood their entitlements, Afropa will (i) ensure that all employees, including daily/casual workers, sign off on their duties (work schedules, security contributions, etc.) and their benefits (access to the canteen and subsidy of meal tickets, access to company shuttles, etc.); (ii) implement a pay slip system for daily workers compliant with PS2 requirements.
Staff Accommodation. Afropa provides accommodation to its foreign employees who make up the management team at the Liberia facility. Afropa has started building a dedicated accommodation facility at its facility in Sierra Leone for the management team, including expatriates. The accommodation will be allocated in a nondiscriminatory manner and comply with national and international standards and follows the IFC and the European Bank for Reconstruction and Development criteria and guidelines.
Protecting the workforce. As part of its current recruitment process, all employees are required to present proof of age, such as national ID card or birth certificate to recruitment staff during the application process, such proof is retained in all workers’ personal files for reference. This is applicable at the Liberia and Sierra Leone facilities.
Worker Organization and Grievance Mechanism. There are no unionized workers at the facilities in Liberia and Sierra Leone. Afropa has no documented worker’s grievance mechanism at each facility. The company is supportive of employee rights to freedom of association. Specific provisions for these rights will be explicitly mentioned in the proposed HR policies (ref. ESAP#5). As part of the HR manual, Afropa will develop a worker grievance procedure that explicitly mentions an anonymous channel for raising grievances, has relevant forms developed, a separate route for addressing sexual harassment and related grievances and the establishment of a grievance register as well as appointment of competent staff to handle the grievances. Prevention sexual harassment at the workplace policies and procedures will be formalized (ref. ESAP#5). Afropa will ensure training to Afropas’s management team, permanent and casual workers of such procedures will be provided.
Workers engaged by third parties. To ensure compliance of its contractors and service providers with applicable national labor and OHS requirements, Afropa will develop an appropriate screening for such provisions, including verification of registration with Ministry of Labor and compliance with local labor and OHS provisions, namely payment of workers’ legal benefits, timely payment of wages, OHS training and provisions of PPEs, ILO Convention 138 on minimum age (ESAP#6).
Occupational Health and Safety (OHS). Afropa is implementing a basic OHS management system. There is an in-house clinic, workers are provided with personal protective equipment (PPE) and incidents are recorded. Afropa recorded three road accidents resulting in one fatality in the last three years. In 2022, the LTFIR rate at the Liberia facility was 10.6 against a soft drink manufacturing rate of 3.3 (as defined by OHSA 2021). Afropa will formulate OHS policies and implemented an OHS management system, including work permit system, to address key workplace hazards at its operations to improve its OHS performance. The OHS SOPs will be continuously updated based on workplace hazard identification and risk assessment conducted under the coordination of the EHS Officer (ref. ESAP#4). Key OHS leading and lagging KPIs (e.g., recording and investigation of incidents, provision trainings, enforcement of use of PPEs, temperature & noise workplace measurements) will be part of the OHS management system. Afropa will also develop/implement an OHS training plan which will include safe working SOPs, including emergency procedures/fire prevention, PPE usage, machine safety, accidents reporting personal hygiene and food safety requirements (ESAP#7).
PS-3 Resource Efficiency and Pollution Prevention
Resource efficiency (energy/water) and greenhouse gas emissions. Energy supply for the facility in Liberia is provided by five diesel generators located onsite and used for power generation for the operations. The company will connect to the national grid by 2025 when the transmission line is completed. Afropa records monthly its fuel diesel from generators, forklifts, and vehicles. Total GHG emissions for current Afropa operations for 2022 (ref. Scope 1 and 2 – MT CO2-equivalent) was respectively 3,329 and 0 tons. Afropa’s GHG for both facilities are expected to be below PS3 reporting threshold of 25,000 tons CO2e per year. The Sierra Leone site has a connection to the national grid and will have generators to supplement during power outages.
Raw water supply is currently sourced from six boreholes for the Liberia plant, while spring water supplemented by eight boreholes for the Sierra Leone factory. The rainfall pattern and the amounts provide for a potential good recharge of aquifers. Afropa has permitted water extraction permits for its six boreholes in Liberia and for its eight boreholes in Sierra Leone. As part of this project, Afropa will undertake a water resource sustainability study to validate the sustainability of its current water supply, while assessing the efficiency of its water usage within the plants (ref. Water Ratio Usage). The water resources sustainability assessment will conduct geo-hydrological studies and climate risk assessments and propose a water resource monitoring and conservation plan to be implemented by Afropa (ref. ESAP #2c).
Air emissions. The operation in Liberia has a boiler and five diesel gensets as the main source of air emissions. Afropa has a preventive maintenance routine per manufacturers’ instructions for the equipment. This practice optimizes efficiency while reducing point source air emissions. As the size of these gensets are below 3 MWh while usage of the gensets is less than 500 hours/year, there is no stack air emissions monitoring.
Solid and hazardous waste. Afropa does not have a waste management procedure. General waste from the operations, including domestic waste, cardboard and packaging material is sent to authorized landfill sites through licensed service providers. Afropa’s biomedical waste generated from the onsite clinic and microbiology tests of finished product samples is kept in storage boxes then sent to a central licensed incineration facility in Liberia. Given its expansion program and as part of the ESMS (ref. ESAP#1), Afropa will prepare and implement a plant-level solid and hazardous waste management procedure, including on-site storage. The procedure will include the current practice of collection of used PET bottles, shredding and shipping to Ghana for recycling, management of fuel (diesel), lubricants from the trucks repair garage, and chemical reactants and detergents used in the cleaning in process (CIP). In addition, Afropa will install an above ground diesel storage tanks and secondary containment for both sites (ESAP#8).
Performance Standard4: Community Health, Safety and Security Personnel
Infrastructure and Equipment Design and Safety. Afropa maintains annual certification of fire safety of its facility in Liberia audited by the Liberian Fire Service as a statuary and insurance requirements. In Sierra Leone, Afropa will ensure fire suppression systems are installed during refurbishment as per Sierra Leone fire prevention requirements.
Road traffic safety. The Liberia facility maintains a fleet of 40 trucks for distribution of its products. A similar number is expected in Sierra Leone. All Afropa drivers have valid driving licenses. Afropa will develop and implement a safe road safety policy and procedures (ref. ESAP#1). All drivers will be required to achieve a defensive driver training course from a third-party service provider.
Food Safety. To meet food safety specifications at its facility in Liberia, Afropa follows food safety standards and provide training covering personal hygiene, health, and safety requirements, and GMP procedures to ensure that that bottled water is treated. While Afropa does not have certification for ISO 22000, food safety controls are applied. Microbiological testing of bottled water is conducted as determined by the relevant FSMS procedures in compliance with HACCP requirements. These voluntary standards will be applied to the Sierra Leone facility upon its commissioning.
Security Personnel. Afropa contracts a private security company to provide security guards for its facility in Liberia. This service deploys five unarmed guards per shift. Afropa will develop and maintain a Security Management Procedure guided by a specific Security Policy and Procedure consistent with the requirement of PS4 (ref. ESAP#1). This will include the guards’ behavior with community and workers. The policy shall be communicated to the security guards, as part of the induction and refresher training.
