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
E&S Policies and Management Systems: TWM has a corporate Environmental Policy as well as an Occupational Health and Safety (OHS) Policy which are applied to the project. TWM has developed and implemented management systems certified as per ISO 14001 (Environment) and Occupational Health and Safety (ISO 45001) for the waste and environmental management services for collection, transport, storage, separation, treatment and disposal of industrial wastes, project management of civil, environmental and water infrastructure projects and specialist industrial cleaning and maintenance services.
E&S organization: TWM has a dedicated E&S organizational team headed by Special Projects Manager who is supported by OHS Manager. Currently there are three environmental officers and five OHS personnel to manage day today activities.
The Company developed procedure for capacity needs assessment and competency assurance matrix for all levels of operational and management staff. Periodic training is provided to and covers such topics as chemicals and dangerous goods safety, first aid, job safety analysis and risk assessment, fire safety and others.
Identification of risks and impacts: The company identifies and manages E&S risks and impacts associated with its operations through the existing environmental and OHS risk management framework. For the IWMF development an Environmental Impact Statement (EIS) was prepared in compliance with applicable national standards and E&S regulatory permits and requirements. In addition, the company commissioned in 2024 an external consultant to undertake a Supplementary ESIA (S-ESIA). The S-ESIA will be further amended to reflect project developments (e.g., upgrade of IWWTP, building of recycling facility) and associated risks and impacts and include measures to address them in accordance with IFC PSs and GIIP [ESAP#1].
IFC’s review identified a low level of project E&S risks and impacts resulting from a changing climate, including extreme heat, flooding, landslides, droughts and wildfires. The client will manage and mitigate risks and potential adverse impacts by implementing relevant measures identified in their climate change assessment and management plans as a part of the ESMS.
Management Programs: The measures to mitigate the identified E&S risks and impacts were included as part of the EIS and draft S-ESIA. TWM will amend the existing ESMS [ESAP #2] in line with the IFC PSs to include the following policies, procedures and plans: EHS Risk Register, Occupational health and Safety Management plan, Infrastructure maintenance and monitoring procedure and schedule, including third party assessments for key components such as incinerator, IWWTP, landfill, leachate pond; stormwater management plan; contractors’ management plan including screening of suppliers; air monitoring program within the project area of influence; soil, water monitoring program within the project area of influence including priority heavy metals and full scan of organic pollutants; land acquisition procedure (only if and when applies); community health, safety and security management plan; security policy management plan; traffic management plan; energy and water conservation plan. Monitoring programs that will be developed as part of the amended ESMS will be aligned with the relevant WBG EHS Guidelines.
Change management: As described above, the current incinerator will be ceased and the new incinerator will be installed; the company hasn’t finalized yet selection of alternatives to the incineration during the transition period. TWM will develop a change management plan for the transition period between the shutdown of the current incinerator and the installation of a new incinerator. Potential E&S risks and impacts of selected option will be identified and assessed in accordance with IFC PSs [ESAP #3].
Emergency response: TWM has documented an emergency response plan for its current operations. The plan includes drills and related training provided to all staff. The plan will be updated as part of ESAP#2 to include the new/expanded components, including the landfill, new incinerator, new hazardous waste storage area, upgraded industrial wastewater treatment plant, etc. The ERP should include all scenarios of emergency, including effluent overflow/accidental discharge from IWTP, fire, security, extreme weather events. Under the updated plan the fire safety measures will be in line with the requirements of the PNG Fire Safety Code, WBG EHS Guidelines and the PSs. Such measures must include creating access points and clearing the isles for firefighting equipment at the temporary waste storage facilities and installing firefighting system with alarm at the hazardous waste storage facility [ESAP#4].
Monitoring: The company periodically monitors the performance of environmental aspects identified in the EIS and reports the performance annually. As part of E&S construction and operational management framework upgrade described above [ESAP#2], relevant E&S monitoring plans will be developed in accordance with monitoring requirements defined based on EIS and S-ESIA including monitoring by third parties of the key components of the facility.
PS2- Labor and working conditions
As of June 2025, the company employs a total of 247 personnel, all of whom are direct hires. The workforce is composed of 214 males (86.6%) and 33 females (13.4%). In terms of nationality, 228 employees (92.3%) are Papua New Guinea (PNG) citizens, while 19 employees (7.7%) are non-citizens, mostly representing mid-management, supervisory roles.
Human Resources (HR) policies and procedures: The Company has HR Manual, which is currently undergoing updates. In addition to the HR manual, the company has a standalone Code of Conduct that defines the expected standards of behavior for employees and managers in the performance of their duties. Introduction to the Code of Conduct is a part of the HR on-boarding checklist which is signed by each employee. The company will review and update its HR Policies and Procedures to include: prevention of forced labor, freedom of association and collective bargaining, retrenchment principles and procedure, requirements for contractors, prevention of Gender Based Violence and Sexual Harassment (GBV SH) including provision of gender-sensitive accommodation and sanitation facilities. Contractor management procedures will be updated to include enforceable GBVH clauses and monitoring protocols. The company will also review and improve site infrastructure to ensure gender-sensitive accommodation and sanitation facilities are in place [ESAP #5].
Working Conditions and Terms of Employment: Each employee is provided with a written employment contract that clearly outlines the relevant terms and conditions of employment. The current practices indicate that the company operates within the legally permissible limits for working time.
Child and forced labor: The company’s operations do not involve children and employs only individuals more than 18 years. There is no evidence of forced labor. As part of the HR policies update, the company will develop a written policy and procedure specifically addressing forced labor, aimed at preventing the employment of individuals subjected to forced or trafficked labor and identifying any indicators of forced labor within its operations, in accordance with ESAP#5.
Discrimination and equal opportunity: The company adheres to a merit-based principle in employment, with no evidence of discrimination or unequal opportunity based on personal attributes or circumstances for both foreign and local workers. Furthermore, there have been no reported incidents of GBV SH within the company’s operations. Relevant policies and procedures addressing discrimination, equal opportunity, and harassment, including sexual harassment, are firmly established and implemented.
Grievance mechanism: TWM currently operates two grievance handling mechanisms: a workplace grievance redressal system, as outlined in its Grievance Handling Policy and Procedures, and a separate Whistleblower Policy. As part of ESAP#6, the client will review and update its grievance mechanism policy and procedures to align with IFC PS2 including avenues for anonymous complaints and clear procedure on grievance management.
Third Party Workers: The company periodically engages third-party contractors to support its operations and will engage contractors for installation/ construction and upgrade as part of IFC loans. To address E&S issues related to construction and maintenance performed by contracted workers the company will develop Contractors Management Plan that will include requirement for contractors OHS MS, site access and security emergency preparedness and response, training and competency requirements [ESAP #2]. It will also update its HR policies to incorporate contractual obligations requiring third-party contractors to comply with IFC PS2 in all service agreements. It also intends to develop a contractor screening process that includes PS2-aligned criteria, and to establish a performance monitoring and evaluation mechanism to ensure ongoing compliance with PS2 requirements [ESAP#5].
Occupational health and safety: As of 2024, no work-related fatalities have been recorded in connection with OHS incidents or accidents. TWM has established and implemented a structured OHS Management System (ISO 45001 certified) aligned with applicable legislative and regulatory requirements. Management of worker exposure to occupational hazards during the collection, handling, transport, receipt and storage of hazardous waste (including silica dust, chemicals and biomedical waste) is covered under the company’s OHS procedures. The key OHS risk is related to the exposure of IWMF workers to dioxin and furan emissions from the current incinerator that will be decommissioned and replaced with a new incinerator as part of the project. As described under ESAP#2, TWM will amend the identification of OHS risks register based on EIS and S-ESIA recommendations and will align its plans and procedures accordingly.
PS3-Resource Efficiency and Pollution Prevention
Water, Electricity, Raw materials: Potable water for the workforce is transported to the site and meets Public Health Drinking Water Regulation (1984) and non-potable domestic water is supplied mainly via the existing connection from the adjacent AES industrial park. Industrial water for operations, including dust suppression and cleaning services, is sourced from AES, rainwater tanks, and water treated onsite.
The main power supply is provided by PNG Power. For backup power, there are two diesel generators on standby, with additional mobile generators as needed. Diesel fuel is required for heavy and light vehicles, with refueling occurring within impermeable hardstand areas. Bulk fuel storage of 14 kL is expected, which will be stored on overground tanks and within containment. An energy and water conservation plan will be developed as a part of ESMS and implemented to ensure efficiency, with annual targets for monitoring effectiveness [ESAP #2].
Greenhouse Gas (GHG) Emissions: The Scope 1 and 2 absolute GHG emissions (i.e., project emissions) is estimated to be 6,518 ton CO2 equivalent per year. Scope 1 emissions include emissions from diesel fuel consumption and the exhaust emissions from the incineration facility. The scope 2 emission is from electricity consumption.
Pollution prevention:
Air pollution: The principal current source of emissions to the atmosphere is from the flue gases produced by the existing incinerator. Based on previous air emissions monitoring some parameters didn’t meet statutory and WBG EHS Guidelines 2007 requirements with dioxins and furans significantly above permissible levels. A reduction in emissions to air will occur when the current incinerator is decommissioned and replaced. As per ESAP#7 the company will provide performance guarantees for the new incinerator demonstrating compliance with WBG EHS Guidelines. Air dispersion modelling was conducted by third party in 2025 for the new incinerator using emission limits specified in EU Directive 2010/75 on Industrial Waste Facilities Emissions as the reference emission values and included sensitive receptors within the project airshed area of influence. The results of this modelling show that the new incinerator will meet Australian ambient air quality standards.
The company will develop and implement the air emissions monitoring program as part of ESMS amendment [ESAP #2] as per WBG EHS Guidelines. The program will include specific requirements on monitoring of ambient air quality and stack emissions through a Continuous Emissions Monitoring System (CEMS). Additionally, long-term Isokinetic Sampling (CIS) for dioxins will also be conducted.
Ash disposal: Bottom ash and fly ash are produced from the incineration process and require toxicity leachate analysis for classification as regulated or non-regulated materials under US EPA Title 40 – Protection of Environment. Ash that is categorized as non-regulated will be directed to the landfill for disposal. Ash that is categorized as regulated will be stabilized in cement during the fixation process prior to being directed to the landfill for disposal.
Leachate management: The landfill is lined with clay and geomembrane lining to prevent leachate from impacting underlying soils and groundwater. Leachate is pumped from the landfill into a pond that is clay and geomembrane lined. The leachate pond capacity (6.3 ML) was designed considering the worst-case scenario leachate volume for phase 1 landfill development during the indicative period of the IWWTP upgrade. The landfill will predominantly receive inert materials and is expected to generate relatively low levels of leachate. The design capacity for the leachate system is based on the relationship between leachate level and landfill volume and the calculated annual rainfall infiltration volume. In the short term, pending the upgrade of the IWWTP, leachates from the industrial landfill are collected in the leachate holding pond where they will either be evaporated from the pond or recirculated to the landfill.
Design of landfills include gas management system for venting of landfill gases to the environment, and installation and gas extraction wells and installation of gas monitoring probes.
Stormwaters that have come into contact with operational areas are drained to collection sumps and transferred to the wastewater treatment plant for processing. Stormwater from uncontaminated or non-operational areas of the site is discharged directly to the environment (Idler’s Bay and Fairfax Harbor). without collection.
Once the IWWTP is upgraded, surplus leachate will be diverted to the IWWTP, which will receive both leachate from the landfill operations and additional contaminated stormwaters collected at the operational areas of the site. As per the ESAP #2, a leachate management plan will be developed with requirements to mitigate contamination risks. Accordingly, hazardous waste generating leachate will not be placed in the landfill until the IWWTP is upgraded or all hazardous waste is stabilized in the fixation bay and passes the Toxicity Characteristic Leaching Procedure (TCLP) test post stabilization.
Wastewater: The current IWWTP is not sufficient for the treatment of leachate. The IWWTP will be upgraded to allow treatment of leachate [ESAP #8]. As part of S-ESIA amendment [ESAP #1], an assessment of risks and impacts associated with the IWWTP upgrade will be conducted. As per ESAP#9 the company will provide performance guarantees for the upgraded IWWTP demonstrating compliance with WBG EHS Guidelines. Once operational, the IWWTP will treat approximately 46 thousand liters of water daily. Treated wastewater will comply with the applicable WBG guidelines for discharge of effluents to surface water. The company will monitor the quality of treated wastewater and stormwater in accordance with the monitoring program that will be developed as part of the ESMS upgrade described above [ESAP#2].
For the IWMF expansion project, it is anticipated that through the use of engineering controls and good industry practices as defined in the EIS and S-ESIA, there will be no leakage or fugitive discharge of effluents or leachate from the project site to the environment (including to the sub-surface and ground water).
Soil and Groundwater: Contributions of heavy metals, dioxins and furans to surrounding land contamination may have occurred since 2019 related to the operation of the current incinerator and surface water runoff from the plant. Based on the limited soil assessment conducted by TWM in June 2025 few sampling locations along the drainage management system show elevated levels of heavy metals (chromium, arsenic, manganese and cobalt), but no detection of dioxins and furans. The company will conduct additional third party assessment of the drainage management system supplemented by soil and groundwater as well as periodic stormwater testing for adequacy of capacity and potential infiltration of contaminated stormwaters. The stormwater management plan, developed as per ESAP#2, will incorporate findings of soil and groundwater testing in the drainage area as well as stormwater management system assessment. Based on the assessment the current stormwater management system will be updated [ESAP #10].
PS4-Community Health, Safety and Security
Key project- related community health and safety risks include exposure to air emissions, noise, odor and dust. Relevant pollution prevention and mitigation measures are summarized in PS3.
Additional risks to communities include traffic safety including risks from hazardous waste transport through communities, GBV, site security and emergency response including from transport emergencies. To address these issues, as a part of its ESMS [ESAP#2], the project will develop community health, safety and security management plan covering traffic management, emergency response, stakeholder engagement and consultation in line with the requirements of the IFC PSs.
Transportation of waste to the project zone and the circulation of waste collection trucks will be managed in a manner protective of the community health and safety. Work vehicles and machinery will only be operating in the designated zones.
Stakeholder engagement will include the awareness raising on the key E&S hazards of the IWTF operations. Communities in Tuhava and Roku will participate in the emergency drills and will be provided with the access to key E&S information.
Infrastructure and Equipment Design and Safety: As indicated above, the new incinerator will comply with the applicable standards on emissions. Landfills will have geomembrane liners and leachate collection systems to prevent leaks and gas venting systems to safely manage landfill gases. The geotechnical stability assessment was considered in the landfill design. The Company will develop procedures for regular monitoring, maintenance and checks to support the early identification of slope instability, landfill leachate generation, groundwater quality and release of pollutants to the environment. In addition, for the future expansion of landfill, i.e. stages 2 and 3 each, the Company will initiate a third party assessment, particularly in relation to sequencing of cell expansion and constructability [ESAP#2].
Security Personnel: The site is fenced and the Company deploys a third-party security provider. As a part of the ESMS, the Company will develop security management procedures, including security policy and code of conduct addressing such issues as GBV and the use of force, as per ESAP [ESAP #2]. The Company will extend the grievance mechanism described in their stakeholder engagement and consultation procedure to express concerns about the security arrangements and acts of security personnel.
PS6-Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project is located within the Trans-Fly Savanna and Grasslands EcoRegion along the southern coasts of Papua New Guinea. The EcoRegion consists of evergreen savanna and grasslands and plays host to endemic species.?
Intact savanna woodland and grassland occurs on the site with coastal mangrove forests occurring on the seaward fringe of the coastline below the landfill outside of the Project site. Approximately 3.7ha of woodland forest which is considered to be natural habitat has been cleared for the Project within a total site area of 20ha. Approximately 7ha of savanna woodland will remain on the site. To compensate for the loss of savannah woodland to achieve no-net-loss on the site, the remnant forest within the project boundary will be site-aside from further development.
Regarding species values, there are several endemic plants including the IUCN Endangered (EN) plant species Psydrax suborbicularis identified within the Project site which triggers critical habitat. The species is only known from 5 locations surrounding Port Moresby. Other endemic species of reptiles, bats, and flora were also detected within the Project site and area of influence. Several invasive species were also detected within the project site, which will require proactive management. Potential impacts to downslope habitats and mangroves that may occur from leachate and surface water runoff from the landfill are managed under PS3, which requires that leachate and runoff be managed on site and monitored by the Project's ESMS. To manage critical habitat values for P. Suborbicularis and other endemic species within the Project site as well as compensate for losses of natural habitat, the Company will prepare a Biodiversity Action Plan [ESAP #11]. The BAP will include measures to protect set-asides of savannah woodland habitat to achieve no-net-loss and individuals of P. Suborbicularis to achieve net gain for this species. The BAP will also include measures to manage invasive species within remnant natural habitats of the Project site.
PS7-Indigenous People
The IWMF is located on land that is legally recognized as the customary land of the Indigenous Kuriu Ohobididuare clan, who hold State Leases over more than 585 hectares in the region. These State Leases were obtained by the traditional landowners through an Incorporated Landowner Group (ILG) to enable them to commercialize their customary land holdings. The parcels of land where the IWMF site is located are referred to as “Lot 1” and “Lot 2”. Lot 1 (12.59 ha) where the main IWMF site is located was transferred to a State Lease by the ILG in 2015 and subsequently leased to a private logistics company under a 99-year term. TWM acquired the lease for Lot 1 in 2018, with 96 years remaining. Lot 2 (two parcels totaling 8.01 hectares - 2.45 ha and 5.56 ha respectively) is under short-term lease from the ILG since 2020. Long-term lease/acquisition by TWM of Lot 2 will be completed with the ILG after land administration activities are finalized.
The external land audit and appraisal confirmed that the ILG representatives entered into a fully negotiated agreements for sale of the IWMF site lands to TWM.
The IWMF site is not actively used by the community, no displacement impacts have occurred and no cultural or spiritual sites were identified at the site. There are no known land disputes or claims regarding the IWMF site, as confirmed by ILG representatives and community members during the appraisal. Going forward, any future land acquisition or long-term lease arrangements for IWMF expansion must follow a land acquisition screening and due diligence procedure [ESAP#2] developed, as a part of the ESMS to be compliant with PS7 and ESAP#2. Further engagement with the Roku community is required as part of the S-ESIA process, especially to address potential impacts from IWMF expansions or design changes not captured in the original EIS. TWM will develop and implement a Stakeholder Engagement and Consultation Plan (SECP) consistent with PS1 and PS7 to guide ongoing engagement [ESAP #12].
Since 2020, TWM has provided small-scale in-kind benefits to the Roku community including waste clean-up activities and a drinking water project. However, additional and more structured development benefits will be delivered through an Indigenous Peoples Plan or equivalent [ESAP #13]. The IPP will be developed in consultation with the Roku community and include support measures to meet basic community needs, strengthen local capacity, and support both the ILG and the wider Roku community in ensuring the equitable, transparent, and fair distribution of project benefits.
