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
Environmental and Social Policy and Management System. BT has developed a Quality, Health, Safety Security and Environment (QHSSE) Policy following AGL’s Corporate QHSSE Policy, which commits BT to assess and manage E&S and labor aspects of its operations. BT has also adopted a corporate Integrated Management System (IMS) certified for ISO 9001:2015 (Quality), ISO 14001:2015 (Environment), ISO 45001 (Occupational Health and Safety – OHS) that is reflected in a Quality, Health, Safety and Environment (QHSE) Manual, which are aligned with IFC PS1 and local E&S requirements. BT’s E&S objectives include zero incidents, accidents, or impact on the environment. BT’s IMS also includes an OHS Management System that is aligned with IFC PS2 and AGL’s corporate standards. The company has also developed a BT-specific ESMS that is certified for ISO 9001:2015 (Quality), and ISO 14001:2015 (Environment) and address the container terminal-specific E&S requirements. These systems are aligned with internationally recognized standards (e.g. Code of Practice on Safety and Health in Ports (ILO, 2005), Convention on Occupational Safety and Health in Port Handling; the International Maritime Organization (IMO) Code of Safety Practice for Dry Bulk; and the International Maritime Dangerous Goods Code, and Code of Practice for the Safe Loading and Unloading of Bulk Carriers).
Identification of Risks and Impacts. PAC commissioned an ESIA dated August 2021 (go to Global ESIA_Port of Benin Modernization Project) for the entire Port of Cotonou Modernization Program, addressing the impacts of the main components of the port modernization master plan, including the AFs to the BT project and addressing cumulative impacts and mitigation measures. As part of the Global ESIA update, the following additional studies and plans were completed: Climate Change Risks Assessment, Cumulative Impact Assessment, Biodiversity Assessment and Biodiversity Action Plan.
Separately, BT completed an ESIA for the diesel power station relocation (see Attachments) in conformity with national law and aligned with IFC PS, which the Benin Environmental Agency (ABE) approved in March 2023. As part of the IFC project, the company will develop a project-specific ESIA and corresponding E&S Management Plans (ESMPs) in line with IFC PS1 for future civil works (surface pavement, internal access construction, stormwater drainage, access gates, scanning zone, perimeter fencing, lighting towers, custom offices, and renewable energy installation) (ESAP #1).
Management Programs. BT has core ESMPs and multiple standard operating processes (SOPs) to manage existing operations, including for: (i) Emergency Preparation and Response, (ii) Dredging Management, (iii) Environment Assurance and Protection, (iv) Waste Disposal, (v) Dangerous Substances Management, (vi) Individual Safety and Health Protection, (vii) Hiring and Training, (viii) Stakeholders Engagement, and (ix) Port Facilities Safety. Furthermore, the ESIA for the relocation of the diesel power station has an E&S Management Framework (ESMF) section on which the EPC Contractor has built to develop a project-level ESMP that sets out measures to identify and manage the diesel station relocation. BT will ensure that EPC Contractors develop project specific ESMPs that meets the requirements of the ESIA and IFC PS for the remaining civil works. To date, only works covered by an ESIA and Construction ESMP are in progress. (ESAP #2).
As part of this IFC investment, BT will also prepare a Climate Change Management Plan addressing physical climate risk including heatwaves, heavy rainfall, and flooding, and defining measures such as improving shaded resting areas, hydration stations, and planned breaks for workers during hot weather and will require EPC contractors to incorporate these measures in their emergency planning (ESAP #3).
Cumulative Impacts. The ESIA for PAC’s Modernization Program, which is aligned with IFC PS1, acknowledges that its various activities will result in cumulative E&S impacts and PAC is developing a Cumulative Impact Management Plan. PAC, in collaboration with BT, will follow the E&S mitigation hierarchy in addressing cumulative impacts, including (i) air quality baseline and monitoring; (ii) energy efficiency and use of low-sulphur fuels; (iii) truck maintenance; (iv) adequately dimensioned wastewater treatment plant; (v) monitoring sea turtles and marine mammals; (vi) follow internationally recognized standards and Good International Industry Practices (GIIP) and, (vii) robust OHS measures, including in relation to traffic safety and sexually transmitted diseases.
Organizational Capacity and Competency. BT has a dedicated EHS Team headed by an EHS Manager who reports to BT’s General Director. The EHS Team is supported by AGL’s Corporate ESG Director, who oversees E&S aspects across the group. BT’s EHS Manager is assisted by a supervisor and a team of specialists and liaises with the Contractor and subcontractor teams. A dedicated project implementation team has been put in place to oversee Contractor’s activities. Going forward, the company will require each Contractor to deploy an EHS organization with at least one experienced EHS professional to manage relevant risks during construction (ESAP #4).
Emergency Preparedness and Response. PAC has a robust emergency preparedness and response (EPR) system that supports the different concessionaires. Additionally, BT has an EPR Plan, resources, alert system, and response team for its operations. Also, there is a central port coordination and interface unit that focuses on EPR across the entire port complex.
Monitoring and Review. BT’s IMS includes procedures to monitor key performance indicators (KPI) related to waste management, OHS, labor, and life and fire safety (L&FS). Also, internal audits are conducted annually to evaluate E&S performance and compliance with the national requirements. All incidents are summarized by the compliance team and discussed in quarterly management meetings for root cause analysis and implementation of corrective actions. Furthermore, an annual external audit is completed by an independent E&S consultant, and the reports are submitted to the national environmental regulatory agency. E&S indicators are shared with AGL corporate. As part of IFC’s investment, BT will enhance its E&S Monitoring Plan by including OHS leading and lagging indicators such as record of near misses, first aid, injuries, L&FS measures, usage of personal protective equipment (PPE) as well as energy and water consumption, waste optimization, and will ensure that monthly records from both construction and operations activities are logged (ESAP #5).
PS2: Labor and Working Conditions
BT directly employs 443 staff (8% female and 92% male) and 99% of the total workforce is recruited nationally. An additional 126 contracted workers complement BT’s current workforce providing services such as security, food, cleaning. BT relies on contractors’ services to load and unload container ships when required. An average of 330 daily laborers are involved with this task which are sourced through the Bureau D’Embauche Unique (BEU), a government entity established in 2023 responsible for the hiring and management of dockworkers in ports and port logistics in Benin. An additional 600 third-party construction workers will be engaged at the peak of the project’s construction for 1 year. BT mandates all contactors to follow applicable national law and monitors its contractors to ensure compliance.
Human Resources Policies and Procedures. BT has HR policies that apply to all employees and are consistent with national labor regulations and IFC PS 2 requirements, including: (i) non-discrimination and equal opportunity; (ii) safe and healthy working conditions; (ii) compensation and fair benefits; (iii) prohibition of child and forced labor; (iv) employee training and development; (v) industrial relations and relation with management team; (vi) protection of vulnerable and third party workers as well as workers in the supply chain; (vii) zero tolerance for gender-based violence and harassment; and (viii) freedom of association. The HR procedures are reflected in the Reglement Interieur specifying work hours and shifts, overtime, leave, health and safety provisions, discipline, and sanctions. The Collective Bargaining Agreement – CBA- further expands and complements BT’s Reglement Interieur on the workers’ terms and conditions of employment.
Working conditions and terms of employment. Employees are engaged under indefinite (CDI: Contrat à Durée Indeterminée) and fixed-term (CDD: Contrat à Durée Déterminée) contracts that describe the working conditions and terms of employment, and an employee handbook is also provided. Work is divided into shifts with a maximum of 42 hours a week and, in the event of overtime, rates are paid per national labor requirements. All employees are enrolled in the mandatory social insurance scheme.
Freedom of Association. A labor union is in place with most employees joining the union voluntarily and they hold regular meetings. Union representatives are elected every 2 years composed of 7 union delegates and 7 deputies. There is a collective bargaining agreement (CBA) in place from 2018 and a new CBA has now been negotiated and under review by the Ministry of Labour and Public Service.
Workers’ Grievance Mechanism. BT has a workers’ grievance mechanism (WGM) where workers can report any grievances directly to the HR department. Also, there are suggestion boxes at BT and a corporate whistle-blower and anonymous mechanism (https://aglgroup.integrityline.com/frontpage whistle blowing system) for which grievances are treated confidentially and are protected against any form of retaliation. An AGL-level Compliance Team is represented at BT by the QHSE Director, who holds monthly compliance meetings with representatives from other country offices. The CBA provides an additional platform for conflict resolution that workers can use through the involvement of the union. Going forward, BT will; (i) disseminate and make accessible the WGM to contracted workers in both construction and operations; and, (ii) maintain a central grievance management log for both project and operations workforce, in line with PS2 (ESAP #6). As per BT’s zero tolerance for gender-based violence and harassment policy, the grievance mechanism will include a clear and differentiated process for managing (sexual) harassment related complaints.
Workers engaged by third parties. BT implements a Contractor Management Plan during construction to monitor the labor and working conditions of contractors and service providers workforce to ensure that contract terms are complied with, including meeting national labor laws and BT HR policies, and verify that subcontractor personnel have contracts and are being paid accordingly and on time. In case of non-compliances, BT reaches out to the HR / Management of the Contractor or service provider to ensure that the issues reported are resolved. For contracted workers supporting operation activities, BT will enhance its existing procedures to include monitoring of GBV and labor grievances (ESAP #7) in accordance with IFC PS2 requirements.
Occupational Health and Safety. BT is a pedestrian-free terminal to ensure BT employees, subcontractors, and visitors’ safety at the terminal. Also, there is a zero-tolerance policy on drugs and alcohol. Frequent sensitization and awareness are provided to the teams in daily toolbox talks. BT’s OHS performance is measured through 30 KPIs and reported to AGL’s corporate. The overall management of OHS at the container terminal is good with a Lost Time Injury Frequency Rate (LTIFR) of 0.91 and Incident Rate (IR) of 0.16 which are below industry benchmark.
BT provides training to its personnel and workforce as committed in the QHSE manual, including training on health and safety, first aid, fire safety, and, especially, crane operations safety. As part of the IFC financing, BT will require the EPC contractor to implement an OHS Training Program for the construction workers including induction training, daily toolbox talk, training on emergency response and construction safety (ESAP #8).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. BT is implementing initiatives to reduce energy and water consumption. The company switched from diesel generated electricity to connecting to the national grid in 2022. Also, the diesel power station will only serve as a back-up power source when the national grid is down. Additionally, renewable energy, including solar, will be included in BT’s energy mix to power LED streetlamps. Finally, BT has been labelled as a Green Terminal for 3 years based on its focus on green spaces, energy transition and efficiency. BT also monitors water consumption closely ensuring water demands of the project are moderate. The water is obtained from the municipal water distribution network and is used mainly for domestic and construction purposes.
Air Emissions: Prior to connecting the container terminal to the national gride and subsequent dismantling of the diesel power station, air emissions monitoring was completed regularly with PM 1,0, PM10 et PM 2,5 values all within limits. The relocation of the diesel plant will include revamping of engines to address occasional exceedances in total volatile organic compounds (TVOCs). Upon completion of plant relocation, the company will continue air quality monitoring of the plant at its new location as per ESAP #5.
Greenhouse Gases. BT started a decarbonization program in 2009 with a yearly action plan aiming at a complete decarbonization objective target for 2035. BT’s direct GHG emissions is estimated to be 13,705 tons of carbon dioxide equivalent for 2023. The relocation of the diesel power station will be associated with a refurbishment and revamping of the generators to improve efficiency and further reduce emission levels. Furthermore, the Project GHG emissions mitigation measures (ref ESAP #3) will include the use of climate-resilient equipment and prioritize ongoing maintenance of assets and equipment. Upon upgrade Project completion, total emissions at BT are expected to remain under 25,000 tons of carbon dioxide equivalent per year. The emissions produced during the terminal upgrade activities will be computed as part of ongoing emission monitoring (ref ESAP #5).
Wastewater. Wastewater from chemical toilets and from lavabos is channelled to a series of closed tanks and the sludge is removed by a licensed municipal service provider for treatment and conversion into manure used in agriculture. Wastewater from workshops and washing areas at the container terminal is channelled to oil water separation systems where it is treated, sampled/analyzed at discharge. Monitoring of both effluents and sludge disposal process is conducted by BT’s EHS team. As part of the terminal upgrade civil works scope (ref ESAP #1), BT will undertake activities to improve on wastewater discharge mitigations including (i) avoiding the installation of rainwater collection basins which discharge rainwater directly into surface water; (ii) avoiding the use and storage of tanks in areas with high risks of accidental releases of hazardous materials (e.g lubricant oils and degreasing solvents from engines, diesel, gasoline) and installation of oil water separators at all runoff collection areas; (iii) regularly maintain oil and water separation systems and retention tanks to keep them in working order; and (iv) install filtering mechanisms (e.g purge samples, filter berms, manhole protection, sediment traps and sedimentation basins) to prevent sediment and particles from entering surface waters and discharge rainwater from neighbouring concession areas (north side) into the port basin through openings provided in the quay wall.
Wastes and Hazardous Material Management. The most common waste generated at the terminal is metallic waste and used oil but also typical construction and operations waste like 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) building rubble, discarded cement and concrete, iv) domestic waste generated by personnel from chemical toilets, and v) food residues and waste from kitchens.
Hydrocarbon products represents a greater proportion of the hazardous material at the container terminal. The diesel power station will include a roofed concrete bunded area (260m3) that will hold four diesel storage tanks with a combine capacity of 240m3. Concreate hardstands designed around the storage area for refilling of the storage tanks will be drained to oil water separators and this facility will also hold 240m3 of water, 12m3 petrol emulsifier and three 60m3/h pumps as fire emergency preparedness. BT stores hazardous materials in well-designed and appropriately drained secondary containments, and non-hazardous waste is stored in sealable skips. Also, BT employs licensed service providers in its waste management with the concessionaire of the hydrocarbon terminal at the port contracted to manage all used oil generated from BT activities. As part of the IFC financing, BT will update it Waste Management Plan to include a due diligence of the treatment facilities of its third-party waste service providers and to ensure that the waste is handled in accordance with WBG EHS Guidelines (ESAP #9).
Handling and Storage of Dangerous Goods. Dangerous goods are managed in collaboration with PAC in accordance with port operating procedure, port police regulations, International Maritime Dangerous Goods (IMDGs) Code and other GIIP. Prior notifications are provided for all dangerous goods and the handling is planned through a software which ensure storage location, segregation, height of containers and need for police escorts are determined prior to vessel docking. Also, the IMO mandates maintenance of records, fire protection procedures, environmental protection procedures, a feedback system in the event of an incident, regular inspection of storage areas and hazardous cargo and Port Police. Finally, any container with dangerous goods that is damaged must have a specific report to PAC and BT prior to its unloading by the shipping line or its representative. Dangerous goods other than Class 1, 6.2 and Class 7 can only remain in the terminal for the shortest possible time. Dangerous goods that are permitted to be stored for longer periods, including those to be used for the terminal like hydrocarbon products are stored in adequately sized bunded areas operated by trained personnel and accompanying safety measures implemented.
Coastal Erosion. Elements of PAC’s Modernization Program, which are AFs to BT, including (1) the deepening and widening of the access channel that modify incident wave direction at the shoreline East of the port; (2) dredging and deepening of the access channel and port basin generating material to be disposed at near shore disposal site altering the bathymetry of the area; and (3) extending of the breakwater to the east that will cause diffraction of incident waves, will potentially exacerbate the risks of coastal erosion to the East of the Port.
Coastal erosion is a longstanding systemic risk along the coast of West Africa caused by natural processes and the presence of ports infrastructures constructed in the 50s and 60s. The Government of Benin has been implementing multiple mitigation measures, including the construction of groins and other interventions, since the 60s to stabilize the urbanized coast, push back the erosional area, and reduce siltation in the access channel, some of which has been part of the West Africa Coastal Areas Management Program (WACA) funded by the World Bank and Governments of eight West African nations.
As part of the IFC investment, BT will cooperate with PAC (AFs manager) within the framework of the “Comité de suivi” mandated by the Concession Agreement to promote, as feasible, the development of a coastal erosion plan which includes; (i) defining the roles and responsibilities of various stakeholders; (ii) conducting a baseline of the erosion status at hotspots east of ports especially with respect to communities usages of land; and (iii) describing efforts to be undertaken by BT as part of its CSR commitments to mitigate risk associated with coastal erosion (ESAP #10).
PS4: Community Health, Safety and Security
Community Health and Safety. The entire Port of Cotonou is a closed facility with a perimeter fence and the Benin Terminal is segregated from other concessionaires and facilities with its own internal perimeter fence, with no immediate local community in its vicinity. During BT upgrade activities, the EPC contractor will transport, staff, aggregates, spoil and other material across communities outside of the urban area. As part of the ESMPs to be prepared under ESAP #2 the company will develop a Traffic Management Plan in accordance with IFC PSs and WBG EHS guidelines.
Additionally, artisanal fishing boats may be experiencing temporary movement disruptions due to dredging of the access channel and BT will develop a protocol to address potential safety issues as a result (ESAP #11). This protocol will complement the existing health and safety procedures being implemented by PAC in relation to the artisanal fishing boats.
Security Personnel. BT implements a security system sufficiently staffed by unarmed personnel, resourced, trained, and ISPS certified. The security agents are provided two awareness sessions per week and several drills conducted to evaluate responsiveness per the security plan.
PS6 Biodiversity
The Port, which exists since the 1960s, overlaps a Ramsar Site (Basse Vallée de l'Ouémé, Lagune de PortoNovo, Lac Nokoué) and is two km west of a recently declared Donatien Marine Protected Area (MPA). The Ramsar site has a management plan dating from 2004 and includes a variety of ecosystems including swamp forest, flooded grasslands, reeds, floating vegetation and mangroves. In 2018, it was extended to include a marine area with fine sand beaches (turtle nesting habitat), a coastal lagoon and the Cotonou channel (The whole of the city of Cotonou is located within the Ramsar Site boundary). The MPA is known for significant presence of various Endangered and Critically Endangered marine turtles and migratory marine mammals. The Ramsar Site and MPA are not expected to be impacted by the BT upgrade project as many of the qualifying features of the Ramsar site (e.g. birds, freshwater wetland habitats) do not occur in the vicinity of the Port and are likely to be restricted to Lac Nokoue, a designated Key Biodiversity Area that does not overlap with the project.
The project footprint itself is converted habitat consisting of entirely hard-standing laydown areas and buildings. Management of biodiversity impacts of the associated facility by PAC would include amongst others; monitoring of water quality between the MPA and offshore disposal area using a specialized laboratory to sample and analyze marine sediments; noise monitoring using sonometers that automatically emit an alert when noise emissions exceed required levels; and mangrove reforestation using plant species such as Rhizophora racemosa, Ficus tripochoda and Conocarpus erectus, which are of conservation importance. Given this, adverse impacts on the biodiversity values associated with the Ramsar site and MPA due to the AF are also unlikely. However, as the project is within a Ramsar site, BT will consult the relevant authority that oversees the site, identify and implement additional programs, as appropriate, to promote and enhance the conservation aims and effective management of the area (ESAP #12).
