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 Impacts
Further to the facility-level E&S policies developed under the existing IFC investment in the CIMAF West Africa Project (#42046), the Group has adopted a corporate Sustainability Framework and Roadmap (‘The 2030 Sustainability Strategy and Roadmap’) to guide its operations in achieving sound environmental and social performance. The strategy is built around five pillars: preserving natural environment, circular economy, climate change, social and societal responsibility, and human rights and ethics. The Sustainability Roadmap identifies priority actions to support implementation of the Sustainability Framework by its subsidiaries between 2023 and 2030. The corporate Sustainability Department is responsible for implementation of the Framework and supports the subsidiaries in this regard.
The Group has established a corporate Integrated Management System (IMS) in accordance with ISO 9001:2015 (Quality Management System), ISO 14001:2015 (Environmental Management System), ISO 45001:2018 (Occupational Health and Safety Management System), and ISO 50001:2018 (Energy Management System). The Group’s IMS is broadly aligned with PS1 requirements and commensurate with the scale and E&S impacts of its operations. The corporate IMS is currently being cascaded down to the CIMAF subsidiaries. At the time of appraisal, CIMAF Chad, Bobo Dioulasso, Burkina Faso and Mali were at varying stages in terms of adoption of the IMS and preparation for ISO 14001 certification.
The Companies identify and manage E&S risks and impacts associated with their operations through compliance with applicable national standards and E&S regulatory permits and requirements. Going forward, in order to strengthen its Sustainability Framework, the Group will: (i) augment its corporate E&S Policy defining objectives, commitments and principles related to stakeholder engagement, labor and working conditions, responsible sourcing, contractor management, community health and safety, and land acquisition constantly with the principles of the Performance Standards; and (ii) review and update monitoring and reporting procedures and requirements to ensure E&S key performance indicators are reported by subsidiaries to corporate to measure effectiveness of IMS and support continuous performance improvement (ESAP #1).
The selected sub-projects for this investment are still at the planning and design stage and no construction activities have been initiated. CIMAF subsidiaries in Burkina Faso, Chad and Mali for captive PV plants funded under the project will undertake a limited or focused environmental and social assessments prior to commencement of construction. The scope of focused E&S assessments will be defined through the process of initial screening against the applicable local laws and the IFC Performance Standards. The CIMAF Bobo Dioulasso grinding plant will undertake the ESIA in line with the applicable national legislation and requirements of PSs for the development of a calcined clay quarry and installation of an additional calcined clay processing line prior to commencement of construction. Therefore, the Companies will (i) agree with IFC on the Terms of Reference (ToRs) for each focused E&S assessment for captive solar PV plants and the ESIA; (ii) conduct Focused Environmental and Social Assessments for the solar PV subprojects at CIMAF Chad, CIMAF Mali and CIMAF Burkina Faso (Ouagadougou) grinding plants in compliance with the applicable local laws and with the requirements of IFC PSs; (iii) conduct a full ESIA for construction of the CIMAF Bobo Dioulasso calcined clay quarry and installation of an additional calcined clay processing line in compliance with requirements of IFC PSs; and (iv) based on the identification of risks and impacts process, develop site-specific construction E&S Management Plans (ESMPs) and specifically, a quarry management plan and a quarry closure management plan for the CIMAF Bobo Dioulasso calcined clay quarry (ESAP #2).
At each of the Companies’ grinding plants, the Health, Safety and Environment (HSE) Manager is responsible for IMS implementation and sustainability related issues, supported by the Plant Technical Manager. E&S internal safety meetings and reporting by the subsidiaries occur daily, including task-related safety briefs with contractors. Monthly E&S meetings are held between corporate and the Companies’ E&S teams to review performance per monthly reports, and annually as part of internal and external audits and following completion of audit findings. Given the expanded scope of E&S oversight on the business in accordance with the Group’s Sustainability Framework, and in light of the additional E&S risks related to the decarbonization program, and to strengthen further EHS organizational structure, the Companies will retain subject matter professionals (either as recruited personnel or consultants) for E&S activities where needed, in particular for highly specialized topics such as stakeholder engagement, land acquisition and responsible sourcing (ESAP #3).
As part of the IMS, the Companies have documented site-specific Emergency Preparedness and Management Procedures (EPRP) in the form of Internal Operations Plans (‘plan d’opérations internes’). The plans describe key emergencies scenarios (such as fire and explosions, serious accidents, chemical spills, spillage of hot fluids, natural disasters, or external attacks etc.) and include requirements and annual plans for regular emergency drills. The EPRP requirements will be reflected in the site-specific construction ESMPs.
PS2: Labor and Working Conditions
The Group employs 1,425 workers across the business. The Companies employ 271 direct workers (252 men and 19 women) and 229 contracted workers (214 men and 15 women). Additional contracted workers are expected to be engaged for construction and operation of new subprojects; however, workforce estimates are not available at this stage.
Human Resources Policies and Procedures: Human Resources (HR) is managed at the corporate level by the Group HR Director, and the Companies each have HR designates. The CIMAF Code of Conduct outlines the key commitments required of the Companies and their employees, including business ethics, confidentiality, corruption, diversity, harassment, safe working conditions and training. The Group has procedures in place for recruitment, onboarding, and training of staff; subsidiaries report to manage HR in accordance with national regulations. Sites have specific policies in place related to topics including recruitment, induction, training, payment, and leave, as well as separate procedures for the management of worker grievances. In order to ensure a consistent approach is taken across subsidiaries, the Group will work with the subsidiaries involved in the sub-projects to review and update existing HR procedures in accordance with PS2 requirements, including the development of a worker grievance mechanism at all operations in line with the requirements of PS2 (ESAP #4).
Currently, there is no on-site accommodation for the workforce and there are no plans to accommodate workers during the construction or operational phases of the solar PV or calcined clay sub-projects.
Occupational Health and Safety: The CIMAF IMS includes procedures related to the identification, assessment and management of OHS risks. The HSE Manager at each grinding plant is responsible for implementation of site-specific OHS management plans. The grinding plants also have HSE committees that support site specific OHS risk assessments, oversee implementation of regular internal audits, related corrective actions, and report to plant management, who then report to the corporate CTS team. Training, including QHSE induction, on-the-job training, and other site risk-based E&S trainings are conducted at the subsidiaries, guided by annual training plans rolled out at the start of the year. In the first half of 2023, the Companies have delivered training on various HSE topics, including risk management, fire and emergency response, electrical accreditation and driving safety. The Lost Time Injury Frequency HSE statistics compares well with industry benchmarks. At all grinding plants, there is first aid support on site and medical support is provided as required via off-site medical support teams.
Workers Engaged by Third Parties: The Companies currently engage 229 contracted workers; some contractors are involved in the daily operation of the grinding plants while others are contracted for specific tasks or services. The Group’s General Purchasing Conditions include a requirement that contractors comply with the Companies’ HSE procedures. Sample contracts confirm specific requirements related to applicable HSE risks and impacts are captured in contractual agreements or annexed documents. To ensure more effective oversight of contractor’s HSE performance in accordance with the expanded scope of activities proposed under the Green Loan, the Group will work with the Companies to review and update relevant contracting and OHS procedures in order to: (i) better define the different contractor categories (long-term presence on site, long-term supply of locally sourced raw materials, long-term work at the calcined clay sourcing sites, and short-term project construction contractors); (ii) define HSE performance and reporting requirements (including for accidents, incidents and grievances from their workers) for all categories of contractors, including offsite contractors; and (iii) expand the internal audit scope to cover contractors and include labor and working conditions of contractor personnel (ESAP #5).
Supply Chain: The primary inputs into the CIMAF grinding plants (clinker and gypsum) are imported. The main components ratios in the final product vary between 50-80% of clinker and 20-35% of gypsum depending on the type of cement being produced. The remaining portion consists of some secondary inputs, such as limestone or other additives, sourced locally by the grinding plants. It is expected that the majority of materials required for construction of the calcined clay sub-project will be sourced locally in accordance with market availability. The solar sub-projects in Chad, Mali and Burkina Faso will require sourcing materials from both local and international providers. The Group’s General Purchasing Conditions include a requirement that suppliers comply with its HSE procedures, and sample contracts confirm specific requirements are incorporated in contractual documents. The Group’s Form for Creation/Modification of Suppliers includes a question on whether the supplier has plans in place related to quality, health/safety/security, or environment and whether there have been any fatalities at the supplier’s work sites in the last five years. The Group’s Purchasing Department conducts an annual evaluation of its suppliers, scoring them on a range of indicators, including their respect for HSE procedures.
The Group will work with the Companies to develop a Supplier Code of Conduct that includes requirements on OHS and labor practices in accordance with the requirements of PS2, reporting requirements for suppliers, consequences of non-compliance with such requirements, and mechanisms through which requirements will be formalized and monitored (ESAP #6). In addition, for the solar PV sub-projects, the Companies will undertake E&S screening of shortlisted engineering, procurement and construction contractors and primary suppliers, including screening for alleged child and forced labor in the solar PV supply chain, and will include in the solar PV supplier contract agreements safeguards against forced labor, child labor, and significant safety issues in the panel production or operations of the suppliers and their sub-suppliers (ESAP #7).
PS3: Resource Efficiency and Pollution Prevention
Energy and Water Efficiency: In Chad, Burkina Faso, and Mali, the Companies rely on national power grid electricity to run the grinding plants, while back-up diesel generators are used only during power outages. The grinding plants consume between 30-45 kWh/ton of cement produced due to similarity of size, technology and fuel used. This consumption is within the guidelines provided by the WBG EHS Guideline for Cement and Lime Manufacturing. The grinding plants use a mix of municipal water sources and own boreholes. Water is mainly used for cleaning and sanitation, and consumption at the grinding plants is regularly monitored.
Air Emissions: The main sources of air emissions at the grinding plants include raw material transportation from local sources to the plants, storage and handling of clinker, limestone, basalt and gypsum at the plants, transfer of cement to the silos for storage, and bagging of cement. Back-up generators and operation of vehicles/heavy equipment generate carbon monoxide, carbon dioxide, nitrogen oxides, sulphur dioxide and Particulate Matter (PM). All four of the Companies’ grinding plants have installed built-in bag filters to manage dust emissions and conduct monthly ambient air quality and stack air emission monitoring for PM2.5 and PM10. The ambient air quality monitoring results indicates compliance with the national air quality standards and WBG General EHS Guidelines.
Greenhouse Gas (GHG) Emission: The Group’s decarbonization roadmap is aimed at reducing GHG emission and includes a set of energy use reduction and efficiency enhancement measures, cement production technology modification and increased energy mix into their cement production processes. The Group will consider GHG emissions in the design and choice of processes, technology and equipment for the new calcined clay grinding lines in Bobo Dioulasso; and construction of the three solar power plants (16 MW total installed capacity) will reduce grid electricity and back-up diesel use of CIMAF Chad’s, CIMAF Mali’s and CIMAF Burkina Faso’s production facilities. The Companies will further explore the use of other alternative energy sources (organic waste, used tires, etc.) into their energy mix to reduce GHG emissions. Net GHG emissions at the four grinding plants are quantified respectively as 17,500 tons CO2 equivalent, 9,000 tons CO2 equivalent, 8,000 tons CO2 equivalent and 6,000 tons CO2 equivalent for CIMAF Mali, CIMAF Bobo Dioulasso, CIMAF Burkina Faso (Ouagadougou) and CIMAF Chad.
Total gross GHG emissions due to the production of calcined clay at the CIMAF Burkina Faso grinding plant are expected to be 10,758 tons CO2 equivalent annually. However, with the introduction of renewable electricity generated by solar PV plants, net emissions for the four plants combined will result in a reduction of 59,585 tons CO2 equivalent annually. The Group has established an inhouse GHG monitoring and reporting system to quantify direct emissions from their facilities.
Noise: The main sources of noise at the respective grinding plants include mill/grinders operation, conveyor systems, hoppers, motorized engines and loading trucks. While the 3 grinding plants are located in industrial areas with limited sensitive noise receptors, potential noise nuisance shall be expected from the CIMAF Bobo Dioulasso clay quarry due to clay extraction operations. CIMAF Bobo Dioulasso will develop and implement a site-specific noise monitoring and management plan as part of its operational ESMPs as specified under ESAP #8.
Waste and Effluents: The Group’s grinding plants have retained the services of regulator-approved waste contractors for transport and disposal of both unusable or unrecyclable general and hazardous wastes. To achieve consistency across all grinding plants, the Group will ensure that Chad and Burkina Faso grinding plants adopt the Waste Management Procedure developed as part of the ESMPs resulting from the E&S Assessments / ESIA (as per ESAP #2).
Hazardous materials: For hazardous material used in the grinding plants, safety data sheets have been developed and implemented. The grinding plants follows the Group’s Chemical and Inflammable Product Storage Procedures for the management of hazardous materials.
As part of the calcined clay project, CIMAF Bobo Dioulasso will develop and implement a quarry E&S management plan based on the ESIA, and a quarry closure plan, both to be compliant with the WBG EHS Guidelines for Construction Materials Extraction (ESAP #8).
PS4: Community Health, Safety and Security
The solar sub-projects in Chad and Burkina Faso are located in industrial areas on land adjacent to existing CIMAF facilities on the outskirts of N’djamena and Ouagadougou respectively, while the solar sub-project in Mali is located in a rural area approximately 2 km from the existing CIMAF facility on the outskirts of Bamako; for all three sites, there are a small number of structures located within 500 m, which are expected to include some residential structures. The proposed site of the CIMAF Bobo Dioulasso calcined clay quarry is in a rural area approximately 60 km northwest of the town of Bobo-Dioulasso. A small number of structures are located within 500 m and three settlements are located within 5 km of the proposed project site. Transportation routes to be used for all the sub-projects, including for locally sourced raw materials, are still being confirmed but are likely to pass through or in proximity to existing settlements. The solar sub-project in Mali will require construction of a transmission line to connect the site to the national grid; the transmission line route has not been confirmed but is expected to be aligned along the existing access road.
The Group’s Code of Conduct includes a commitment to social responsibility, which is also a pillar of the Group’s Sustainability Framework. It does not, however, have any specific policy requirements related to the management of health and safety risks to and impacts on communities. Operational activities that could create risks to or impacts on communities – such as emissions, noise, and transport – are subject to standard procedures to manage OHS risks (as noted above under PS2). For each site involved in the sub-projects, the Companies will develop a Community Health & Safety Plan identifying the risks to and management measures for risks to and impacts on communities during construction and operations (ESAP #9).
Transportation safety: Specific consideration must be given to transportation risks associated with the CIMAF Bobo Dioulasso quarry site. The site will develop and implement a Transport Management Plan (TMP) to promote safe driving by employees and contractors. TMP will be embedded with the Stakeholder Engagement Plan and grievance mechanism (as per ESAP #10), which should include communication of H&S risks, impacts and management measures with communities near their sites and along their transportation routes.
Security Personnel: The Companies have contracted security service providers that provide unarmed security at the grinding plants. The Group will work with the Companies to develop a Security Risk Assessment and Management Procedure to guide the conduct of the security personnel in line with the requirements of PS4; this will include identifying and managing security risks associated the operations of facilities funded as part of the project, including transportation of raw materials and interaction of security personnel with members of the public (ESAP #10).
PS5: Land Acquisition and Involuntary Resettlement
The Group has done a preliminary and informal assessment of land acquisition and land use impacts for the sub-projects. Each land acquisition process is managed by the subsidiaries directly. The solar PV sites in Chad, Burkina Faso and Mali will be developed on land already owned by the relevant CIMAF subsidiary and adjacent or in close proximity to their existing facilities. The transmission line route for the CIMAF Mali solar PV site has not been confirmed. CIMAF Bobo Dioulasso has applied for an operations permit to develop the calcined clay quarry. The permit area covers 92 ha of unused, largely forested land. The site is located within 500 m of a small number of structures and three settlements are located within 5 km of the proposed project site. The site is reported to be on state-owned land, but CIMAF Bobo Dioulasso has not carried out any consultation with local residents to assess traditional land rights or land use or confirmed the final project footprint. Displacement impacts associated with the sub-projects are expected to be limited to economic displacement of traditional land users; no physical displacement is expected.
In order to manage risks and impacts of land acquisition associated with the sub-projects in accordance with PS5 requirements, the Group will develop Resettlement Policy Framework with requirements that will cascade to its subsidiaries in order to ensure land acquisition and displacement impacts are managed consistently across its operations (ESAP #11). The Companies will also share the TORs for the Focused E&S Assessments and ESIA with IFC to ensure land acquisition is adequately captured in the assessments (as per ESAP #2) and develop a Stakeholder Engagement Plan and grievance mechanism for each site (as per ESAP #10). In addition, CIMAF Bobo Dioulasso will develop and implement a Resettlement Action Plan or Livelihood Restoration Plan for the Bobo Dioulasso calcined clay sub-project in accordance with the RPF and requirements of PS5 (ESAP #12). The Companies will also review the land acquisition process for each of the solar PV sites in the sub-project to confirm land acquisition did not result in any displacement impacts; if displacement impacts are identified, they will be managed in accordance with the RPF and requirements of PS5 (ESAP #13).
