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
Aqua’s ESMS is largely defined by the requirements of the International Maritime Organization’s (IMO) International Management Code for the Safe Operation of Ships and for Pollution Prevention (ISM) Code, the International Convention for Safety of Life at Sea (SOLAS), the International Convention for the Prevention Pollution from Ships (MARPOL), and where relevant, local / flag state legislative requirements The existing ESMS is largely aligned with the requirements of IFC PS 1.
Given the nature of Aqua’s operations, Environmental and Social Impact Assessments (ESIA) are not required. The company’s existing ESMS and compliance requirements were generally in line with IFC PS requirements. To further enhance its ESMS to cover the Tanzanian operations, the Company is required to develop a Safety and Environmental Protection policy, identify shipboard risks and impacts, define, and adopt a safety management system (including instructions and procedures to ensure safe vessel operation, emergency preparedness procedures, and near miss assessment and reporting protocols), define the job description, scope of work, and appoint the designated person ashore, and detail the monitoring and auditing requirements. Additionally, as the Company are proposing operations around the Seychelles archipelago, which includes several marine protected areas, the Company will, as a component of their risk and impact assessment process, consult marine/biodiversity experts to identify opportunities to reduce their potential impacts in relation to anchoring and mooring, engine noise disturbance, use of anti-fouling paints, and impacts from artificial light at night (ESAP #1)
Although the Company does not have a dedicated E&S Manager at the corporate level, overall E&S management is under the responsibility of the Chief Operating Officer (COO). At the operational level, respective country managers are responsible for E&S management, reporting and compliance. Additionally, each vessel has a designated person responsible for oversight of the vessel, including compliance, environmental, and safety management.
PS2: Labor and Working Conditions
At the time of the appraisal, Aqua employ a total of 195 workers across their five existing vessels, and 78 workers within their various offices. 90% of workers onboard the ships are male, while 56% of office workers are female. The Company anticipate hiring 30 workers for their Tanzanian operation. Given the seasonal nature of the Company’s operations, workers are either provided with open ended contracts, in the case of office workers, while boat crew are provided with employment agreements as per the requirements of the International Labor Organization (ILO) Maritime Labor Convention (2006).
The management of human resources (HR) within the Company is led by a global HR director, with operational responsibility passing to the respective country managers, supported by local HR teams. Aqua has implemented several HR related policies and procedures, including Internal Rules and Regulations, Hiring Policy, Training Policy, Performance Management Procedure, Internship Program, and Grievance Policy. These policies and procedures are available on the Company’s intranet and are adapted as necessary to align with the requirements of local labor legislation.
The Company Rules and Regulations define the applicable labor and working conditions, including hiring, probation, working hours, compensation, leave, occupational health and safety (OHS), harassment and sexual harassment, and termination. Aqua will update the existing Rules and Regulations to apply to their Tanzanian operation and align with local legislation, IFC PS 2, and the ILO Maritime Labor Convention as required (ESAP #2).
Aqua has developed and implemented a worker grievance policy aligned with the requirements of PS 2. The policy and submission form are accessed via the Company’s intranet, and allows for the submission of grievances, including anonymous grievances, through an informal and formal process. The process also defines timelines for feedback and resolution. In 2022 the Company did not receive any worker related grievances.
Aqua make use of various third-party service providers, predominantly for the provision of food and beverage services, as well as ongoing ship maintenance. During planned maintenance, all service providers are required to provide certificate of compliance with local safety and labor standards. Aqua will also develop and implement a Supplier Code of Conduct defining the Company’s minimum requirements of their third-party contractors and suppliers in terms of labor and working conditions and OHS. This will be aligned with PS 2, local labor regulations, and the ILO Maritime Labor Convention (ESAP #3).
PS3: Resource Efficiency and Pollution Prevention
The Company’s activities involve the operation of relatively small passenger boats, and hence do not result in significant quantities of wastes and emissions. The management of pollution and waste is largely governed by the requirements of the ISM Code and MARPOL, including regulating the discharge of sewerage, waste management and air pollution. As per the Company’s 2023 midyear Sustainability Report, the Company have adopted an approach to reduce their ships’ environmental and carbon footprint, including installation of LED lighting, and reducing diesel consumption through route planning and speed control, and the utilization of solar panels where feasible. The Company are currently exploring the feasibility of becoming a Science Based Targets Initiative (SBTi) signatory and defining their greenhouse gas (GHG) emission reduction approach and targets.
Solid waste is separated onboard and delivered to an authorized waste management company for disposal. The Company has also adopted a recycling program for used plastic, glass, cardboard, and aluminum. In terms of managing liquid effluents and waste, all vessels are equipped with chemical free wastewater treatment plants, whereafter wastewater is discharged into the river/sea. Vessels are also equipped with approved sanitation systems and onboard treatment and storage tanks. Hazardous wastes, such as cooking oil, are stored, and disposed of as per defined standard operating procedures.
PS4: Community Health, Safety and Security
Health, safety, and security risks to the local communities are not expected, other than the ones related to passengers, including food and hygiene management, life and fire safety (L&FS), and security.
Vessel safety and seaworthiness is ensured through ongoing maintenance. Vessel maintenance requirements are determined by the vessel, class, and flag requirements, and will likely be 9-weeks of maintenance every season for the Tanzanian operation. Aqua developed and implemented measures, including rescue boats, first aid training, emergency drills and safety briefings.
Food safety and hygiene is overseen by the Company’s Global Food and Beverage Director. Onboard food safety is managed through various risk assessments, quality control and standards, including HACCP protocols, ILO Maritime Labor Convention requirements, and the Guidelines for Food Safety on Merchant Ships and Passenger Vessels. Minimum operating standards cover food preparation and storage, personal hygiene, delivery, and good receiving, and OHS. Potable water onboard is filtered through reverse osmosis plants and tested regularly through microbiological analysis.
Aqua contracts public security to provide security onboard some of their vessels. For their Tanzanian operation, Aqua will complete a security risk assessment and based on the findings, determine the nature of the required onboard security. This will include the number of guards and training requirements aligned with IFC PS 4 (ESAP #4).
