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
Mohinani Group has established an overarching corporate Environmental, Health, Safety and Social Policy broadly consistent with the principles of the IFC Performance Standards. Mohani Group identifies and manages E&S risks and impacts associated with its operations through compliance with respective national standards and E&S regulatory permits and requirements.
At the country level:
Polytanks in Ghana has implemented an Environmental, Health and Safety Management System (EHSMS) broadly aligned with (principles of ISO45001 (Occupational Health and Safety) and ISO14001 (Environmental Management). Polytanks is certified ISO 22000 (Food Safety). The EHSMS includes a OHSE Policy and OHSE Manual.
Sonnex in Nigeria has implemented an EHSMS, including a HSE Policy and HSE Program with company HSE plans and procedures. In addition, Sonnex is certified as per ISO 9001-2015 (Quality Management) and FSSC-22000 (Food Safety Management - 2018).
Mohinani Group chemicals and polymers trading and distribution business will need to develop and implement an EHSS management system in line national law and requirements of IFC PSs (ESAP #1a).
Identification of Risks and Impacts: The EIA for the Sonnex rPET project in Nigeria was conducted in March 2023 in line with the national requirements. The draft EIA for the Polytanks rPET project in Ghana is dated November 2023 and conducted according to national requirements. Polytanks will complete the EIA for rPET plant in accordance with IFC PS (ESAP #1b). Both Sonnex and Polytanks are in the process of EIA review and approvals by the national environmental agencies in Nigeria and Ghana.
Management Programs: Both Polytanks and Sonnex rPET projects EIA include an Environmental and Social Management and Monitoring Program, which cover both the construction and operations phases.
For Sonnex rPET plant in Nigeria construction, the main contractor has provided a construction Health, Safety and Environmental Management Plan and. Sonnex will upgrade construction EHS management procedures covering all contractors working at the site, specifically OHS management, contractors’ management, emergency response, EHS inspections and audits, as per ESAP #1c.
For Polytanks rPET plant in Ghana construction, the main contractor (for civil works) has provided a construction Health and Safety Management Plan and Emergency Response Plan. Polytanks will upgrade construction EHS management procedures covering all contractors working at the site, specifically OHS management, contractors’ management, emergency response, inspections and audits as per ESAP #1c. Both Polytanks and Sonnex will develop operational Environmental and Social Management plans and procedures for rPET facilities in line with the requirements of IFC PS (ESAP #1d).
Monitoring and Review: As part of the HSE management systems, Polytanks and Sonnex regularly monitor key performance indicators (KPIs) such as regulatory compliance, incidents, record of injuries, training, audits, energy consumption, water usage, waste generation. Polytanks has an OSHE Audit and Inspection Procedure and conducts regular internal and external EHS audits (e.g., by Ghana Factories Inspectorate, Ghana Municipal Authority). Sonnex is subject to environmental audits from NESREA (National Environmental standards and Regulations Enforcement Agency), as well as an environmental air quality and noise level monitoring from NESREA.
Organizational Capacity and Competency: Both Polytanks and Sonnex have adequate capacity to manage E&S risks and impacts associated with their operations. Polytanks in Ghana has a dedicated HSE Manager. At the new rPET plant construction site in Ghana, contractor has an HSE officer. Polytanks will provide clarification on roles and responsibilities for HSE monitoring and supervision at the rPET construction site and ensure adequate supervision for all workers, particularly for the mounting of steel structure (ESAP #1c). Sonnex in Nigeria has a dedicated HSE officer. At the new rPET plant construction site, the main contractor (civil works) has an HSE officer on site. Sonnex will clarify roles and responsibilities for HSE monitoring and supervision at the rPET construction site and ensure adequate supervision for all workers, in particular for other (secondary) contractors (ESAP #1c).
Emergency Preparedness and Response: The rPET facilities will be equipped with smoke detectors and automatic fire alarm system, fire hydrant system, fire extinguishers, as well as automatic sprinkler system. Fire prevention and emergency preparedness and response plan for rPET facilities shall include specific provisions in relation to the storage of raw materials (bales), in line with the WBG General EHS Guidelines. The future fire safety system will be audited and verified by a third-party expert on fire safety (ESAP#1e).
In Ghana, the industrial zone where the new rPET plant is located, is in proximity to a sanitary landfill. Therefore, Polytanks will as part of the ESIA, assess the risks associated with the potential landfill gas migration, fire and explosion risks, and identify mitigation measures in line with WBG EHS Guidelines for Waste Management facilities and GIIP. Based on the ESIA mitigation framework, Polytanks will manage the risk conjointly with the industrial zone authorities, landfill operator and local authorities. (ESAP #1b).
At existing facilities, Sonnex has an Emergency Response Plan, a Fire Prevention Procedure and conducts quarterly Emergency Preparedness/Response drill. Sonnex has fire alarms in place, fire extinguishers, fire hydrants, designated fire marshals, fire prevention and firefighting training; and holds a Fire Service Certificate from Lagos State Government Fire and Rescue Service. Polytanks has an emergency evacuation procedure and an Emergency Preparedness Plan (for Tema tank site) Polytanks has fire detection and fire suppression systems in place, including fire alarms, fire extinguishers, fire pumps, fire hydrants, standby water; is certified by the Ghana National Fire Service and had fire safety training by Ghana National Fire Service in 2022. Because fire is a key risk associated with their activities, Polytanks and Sonnex shall ensure that a Fire Prevention Procedure and Emergency Preparedness and Response Plan are available for (and specific to) each facility, in line with WBG EHS Guidelines and Good International Industry Practice as per ESAP#1e).
In the chemical and polymers trading business, the Group sells 50% of the materials directly to end customers while 20% is used for internal consumption in the manufacturing business. The remaining 30% is sold through stocks and sales subsidiaries using warehousing and third party contracted logistics companies located in Kenya, Tanzania, Uganda, Ghana, South Africa, and Nigeria. The Group receives regular inspections and audits on EHS aspects from its end customers and insurance service providers. For each product, the Group follows Material Safety Data Sheets (MSDS) for handling and storage purposes. As part of its EHSS management system, the Group will develop and implement a specific plan to address potential risks associated with Life and Fire Safety as well as Supply Chain, in line with the IFC PSs and the applicable WBG EHS guidelines. The plan will (i) be contractually cascaded at warehouse and third-party logistics contractor level; (ii) include, but not limited to, specific measures for fire prevention, detection and alarm system, compartmentation, smoke management and fire suppression and control (ESAP# 1a).
PS2: Labour and Working Conditions
Polytanks in Ghana employs a total of 1667 workers of which 320 are direct workers. Remaining 1347 workers are contracted workers employed through three different employment agencies. 65 workers are currently employed in the construction phase of the new rPET plant. During the operations of the rPET Project, Polytanks will increase its direct workforce to 70 workers. Sonnex employs a total of 825 workers, of which 371 are direct workers while 453 are workers engaged by third parties. The construction of new rPET plant employs a total of 100 contracted workers, while 80 workers are expected to be employed by Sonnex during rPET plant operations.
Human Resources Policies and Procedures: The Mohinani Group has a Staff Information Handbook (‘the Handbook’) which defines the general human resource (HR) framework and principles being followed by the Group’s subsidiaries. The Handbook covers aspects on i) terms and conditions of employment; ii) health and safety at work; iii) compliance with relevant labour laws; and iii) gender considerations. The country HR team delivers HR induction trainings to all staff joining the Group. In Ghana and Nigeria, the employee handbooks are aligned with national labour law requirements and are applicable to all direct workers.
The implementation of HR policies and procedures is led by a corporate Chief People’s Officer and supported by HR managers responsible for the implementation of national requirements at country level. No internal labour audits have been performed in any of the facilities in Ghana and Nigeria. The Group will develop and implement a labour monitoring procedure applicable to both rPET facilities and to all workers including those employed by employment agencies and contractors. The procedure will, but not limited to, (i) define the criteria to be monitored based on national and PS2 requirements; (ii) set a frequency for monitoring and reporting; and (iii) address gaps identified in the monitoring findings (ESAP #2a).
Working conditions and terms of employment: In both Polytanks and Sonnex, terms of employment and rights and responsibilities of workers are formalized in contracts detailing the nature and category of employment, the wages (above the statutory minimum), working hours including payable overtime, allowances for night shifts and sick and parental leaves. Other benefits include access to private health insurance and pension as required by the national labour laws. In Sonnex, a medical facility is located on the operational sites and is accessible on a full day basis to all direct and contracted employees.
For the rPET facilities, the Group will develop a set of site-specific HR policies based on the Group’s Staff Information Handbook and aligned with PS2 and relevant local regulations. (ESAP #2b).
Freedom of Association: The Group’s Handbook supports freedom of association and collective bargaining for its worker. A worker’s union is present in each plant in Sonnex and Polytanks. In Polytanks, the collective agreement is reviewed on annual basis for salary reviews and each two years for all other benefits and working conditions. In Sonnex, the collective agreement is reviewed each three years. The unions’ executive committee also benefit from training on industrial relations paid by the Group on an annual basis.
Workers Grievance Mechanism: A labour Grievance mechanism (GM) is introduced to all new employees during induction for both Sonnex and Polytanks. Employees can report their grievances to either site managers, HR managers or labour union leaders. HR email addresses and suggestion boxes are available for anonymous grievance raising. The GM lacks procedures for non-retaliation; a register for grievance management and resolution and does not extend to contracted employees. As part of the update of the HR manuals, Polytanks and Sonnex will enhance and operationalize their labour Grievance Mechanisms by: (i) establishing a grievance log; (ii) setting up a procedure for lodging and treating anonymous complaints (iii) including a reference prohibiting retaliation, and (iv) expanding its applicability to contracted employees (ESAP #2b).
Occupational Health and Safety (‘OHS’): The Group’s EHSS Policy is committed to provide a safe workplace to all employees and contractors. The health and safety management at Polytanks and Sonnex is based on a series of safe systems, including (i) a risk assessment procedure; (ii) employee safety guidelines; (ii) regular Audits and Inspections; and (iii) emergency preparedness and response. As per statutory requirements in both Ghana and Nigeria, the Group established an OHS committee per plant composed of key worker representatives. H&S signs are widely spread and visible in all sites and the number of work-related accidents statistics for direct and contracted workers is low. Both Polytanks and Sonnex provide an OHS training schedule, including hazard identification and accident prevention, PPE usage and care, fire prevention, basic safety awareness, basic knowledge of first aid, hazardous material training, machinery safety, electrical safety, fatigue management.
During the IFC appraisal site visits, several OHS risk management related gaps have been observed at both existing sites and project construction sites, in relation to Personal Protective Equipment (PPE). In order to address these key gaps in line with IFC PSs and WBG EHS guidelines, Polytanks and Sonnex will: (i) clarify and enforce PPE needs based on work activities and safety data sheets; (ii) ensure first aid measures are available and in working condition (e.g. eye rinsing station); and, (iii) ensure that the working at height procedure is properly implemented (specifically at the Polytanks rPET construction site) (ESAP #2c). Polytanks and Sonnex will conduct a third-party audit of OHS aspects (including construction) in order to establish and maintain consistency of OHS procedures/practices across Polytanks and Sonnex operations and projects aligned with WBG General EHS Guidelines (ESAP #2d).
Workers engaged by Third Parties: The majority of the workers (72%) employed in the current operations of the Group are hired by third party employment agencies (three agencies in Ghana and one in Nigeria). Both Sonnex and Polytanks contracts with third party employment agencies stipulate fiscal and social obligations to the workers, including tax payment and social security. No additional benefits are delivered to workers in addition to the salary. Each employment agency has a designated HR focal point located in each operating plant, in charge of employee relations, payroll and on-site recruitment. The Group will prepare and implement a contractor management plan aimed at ensuring compliance with Mohinani Employee Handbook and OHS requirements and in line with the requirements of IFC PS2. The plan will also include a procedure for on-site recruitment that will be implemented by the employment agencies. In addition, as part of improving contractors’ management procedures, Polytanks and Sonnex will develop EHS requirements to be included in contracts, as well as strengthen monitoring and supervision of labour and OHS practices of contracted workers for current operations and construction (ESAP #2e).
Supply Chain Assessment and Management: The Group’s PET collection strategy includes sourcing post-consumer PET bottles from franchised companies (primary collection centers) located in their respective country of operations. The Group signed service agreements with 12 franchised companies in Nigeria and controls 3 collection centers serving 8 franchised collectors in Ghana. In the service agreements, franchised companies provide information on legal registration of the entity, evidence of tax registration. The Group will update the service agreements templates and include: (i) evidence of a lawful occupancy of the land of the collection centers (i.e. leaseholds; freeholds; tenancy agreement) and (ii) a specific reference of the Suppliers Code of Conduct (ESAP #2f). Each franchised company collects PET bottles from a variety of collectors ranging from individuals to family collectors, aggregators, restaurants, and other market entities. Franchised companies employ contracted or daily workers at collection centers for sorting and bailing of PET bottles. In some instances, collection centers hosts contracted or daily workers in accommodation close to sites. Each collection centers receives a motorized baling machine from the Group for exclusive production of PET bales. Transport of ‘bales’ from the franchised companies to the rPET plants will be provided by the Group. In Sonnex, the PET collection team is composed by a manager and a supervisor who oversee the commercial relations with the franchised companies and conduct monitoring visits of the affiliates. In Polytanks, each collection center is managed by a regional officer and two zone coordinators in charge of establishing relations with franchised companies and verify the compliance with national requirements.
In Nigeria, waste pickers (scavengers or baban bola in local parlance) are mainly informal suppliers that collects PET bottles from mixed waste disposal sites. In some instances, they can be semi-formalized group that aggregates different types of waste from scavangers before selling them to the Group’s franchised companies. Franchised companies paid waste pickers in advance on an agreed price per collected bag. No contracts are signed between franchised companies and waste pickers. The main risks are identified are (i) the incidence of child labour existing in the sectors and (ii) exposure to toxic substances and hazardous materials and unsanitary working conditions of the waste pickers.
Sonnex requires franchised companies to sign a Supplier Code of Conduct detailing provisions against (i) child labour; ii) forced labour; iii) discrimination; iv) harassment; and iv) health and safety conditions of workers. Sonnex will strengthen the Supplier Code of Conduct by including provisions on handling hazardous waste and will request each franchised company to cascade the Code of Conduct at waste picker/collector level (ESAP #2g). The Group will conduct a third-party specialized audit of the PET supply chains in Ghana and Nigeria following the ToR agreed with IFC to identify key E&S risks and agree on specific corrective actions to be implemented as a result. The Group will also set up a platform to share lessons learnt and good practices between Sonnex and Polytanks in managing supply chain risks (ESAP #2h).
PS3: Resource Efficiency and Pollution Prevention
Air Quality and Noise: rPET Projects air emissions will be limited to emissions from the on-site gas-fired generator and backup diesel generators (Sonnex), forklifts (diesel and gas) and potential dust during construction. Sonnex will ensure generator exhaust compliance with WBG EHS Guidelines as per ESAP #3a.
The main sources of noise associated with the rPET Projects will include PET bottle recycling operations (from production machines), generators and vehicular movements. Noise impacts will be reduced by enclosing and insulating noise emitting equipment. Polytanks and Sonnex will ensure compliance with WBG General EHS Guidelines as per ESAP #3a.
Energy usage: At the Sonnex rPET facility, electricity supply will be through a 1125kW and 1500 KW gas generator (from existing gas line about 20m from the site) and two diesel generators as backup (capacity 150 kVA and 60kVA). It is estimated that 124,800 SCM/month of gas will be consumed during operation phase. At the Polytanks rPET facility, electricity will be supplied by Enclave Power Company located in the free zone. Backup power will be supplied through installation of a 1500 KW diesel powered standby generator. It is estimated that the monthly consumption of electricity will be about 3500 KW.
Water and Wastewater: At the Sonnex rPET facility, water requirements will be sourced from three (3) on-site boreholes. Abstracted water will be routed to a 120,000-litres water storage tanks after passing through a filtration system. It is estimated that at full capacity, 216 m3 of water per day will be utilized for the PET bottles recycling process, mainly for washing. The generated wastewater will be treated onsite and reused for at least 5 cycles of washing before it would be channelled to the onsite Wastewater Treatment Plant (WWTP) prior to being discharged. At the Polytanks rPET facility, a borehole will be drilled to supply water, in addition to the water supply from the Ghana water company. Two water storage tanks of capacity 10,000 litres each would be provided as backup. The anticipated water consumption will be about 90000 litres per day. Polytanks and Sonnex will ensure wastewater discharge compliance with WBG EHS Guidelines for metal, plastic, and rubber products manufacturing as per ESAP #3a.
Greenhouse gases (‘GHG’): Greenhouse gas emissions (“GHG”) from the rPET projects are expected to be mainly associated to the use of vehicles during construction and for transportation of raw materials/product during operations and the use of gas for energy supply during operations. The project gross emissions are estimated in the order of 100 tCO2eq/year.
Solid Waste Management: The EIAs for both new rPET plants identified waste streams generated during the construction and operational phases. The overall volumes of both solid and hazardous waste generated by the projects during both phases are expected to be low. It is anticipated that the sub projects in Ghana and Nigeria will produce construction and operation related non-hazardous wastes, such as paper, cardboard, plastic, food waste, scrap metals, concrete waste, and a limited quantity of hazardous materials such as spent lubricating oils. Non-reusable waste will be placed in appropriate on-site storage containers and periodically disposed of at a government approved landfill by an accredited vendor. Hazardous waste will be properly labelled and stored prior to evacuation by an accredited contractor for further processing. Polytanks and Sonnex will develop site specific Waste Management Plans for both sites aligned with local legal requirements and WBG EHS Guidelines as per ESAP #1e.
Hazardous Materials Management: The main hazardous materials to be used in association with rPET Projects include lubricating oils, hydraulic fluids, and diesel for backup generators. Hazardous materials storage and filling area will be equipped with secondary containment and emergency response equipment (absorbents) will be available (ESAP #3b). Because management of hazardous materials is a key risk associated with their various activities, Polytanks and Sonnex shall develop a Hazardous Materials Management Plan to establish consistency of practices in accordance with WBG EHS guidelines and GIIP (ESAP #3c).
PS4: Community Health, Safety and Security
Infrastructure design and safety: In Ghana, the new rPET plant as part of the industrial zone will be located in proximity to a landfill and Polytanks will, as part of the ESIA, assess the risks associated with the landfill operation, adjust design of the new rPET plant as necessary and manage the risk conjointly with the free zone and local authorities. This shall include an assessment of the risk of landfill gas migration from the landfill and associated explosion risk, as well as assessment of hazards at the site that could have an impact on the landfill (such as fire hazard in the bale storage area) (ESAP #1b).
Life and Fire Safety: As part of the technical design for PET bales storages and warehouses for rPET finished products Polytanks and Sonnex will include adequate fire prevention, means of egress, detection and alarm systems, fire suppression and control (e.g., automatic sprinkler systems, manual portable extinguishers, fire hose reels) in line with the WBG General EHS Guidelines. The fire safety systems will be audited and verified by a third-party fire safety certified professional (ESAP #1f).
Community health and safety: Polytanks’ rPET facility is located within the Tema Free Zone Enclave, a 700 ha – multipurpose fenced industrial park 15 km away from residential communities. Sonnex’s rPET facility is located within an industrial park with 5 communities located at 5 km radius. For Sonnex, trucks coming from the collection centres will unload bottle bales directly in the rPET facilities, thus avoiding staying for extended periods in the area. Interface with surrounding communities will be minimized as the facility will have sufficient space in the premises for onloading/offloading purposes. Sonnex will prepare a road traffic risk assessment in view of the expected increase of truck traffic during the operation phase and will include findings and mitigation measures in the project revised ESMP (ESAP #4a).
Security Personnel: Both Polytanks and Sonnex contracted unarmed security personnel to provide site security and conduct routine ID checks at the gates. In Polytanks, there is additional security screening performed when entering the free zone.
