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. For the construction and operation phases, MACCEM has developed an initial ESMS aligned with local laws and regulations. The ESMS is underpinned by several policies, including Environmental and Health and Safety, Community Health and Safety, and Security policies among others. As per ESAP#1, MACCEM will update their existing ESMS, in line with IFC PS requirements and national legislation, and make it relevant to its operations as described in the ESAP, this will include developing an Emergency Preparedness and Response plan, Contractor Management Plan and Air Emissions Monitoring Plan among others. Further, MACCEM will ensure the updated ESMS includes a defined monitoring and reporting framework aligned with the requirements of the ESMP.
Identification of Risks and Impacts. MACCEM has completed a project ESIA aligned with the requirements of the Environment Protection Agency Act and was subsequently granted environmental approval from the Sierra Leone Environment Protection Agency (EPA) in July 2024. The ESIA identifies key project related impacts including those related to air quality, noise, land use, hydrology, waste management, and socioeconomic impacts. Following IFC’s review, the client will update the ESIA to align with the objectives of the IFC PS and share a copy with IFC for disclosure (ESAP#2).
Management Programs. MACCEM has developed a basic project E&S Management Plan (ESMP), and associated management plans relating to specific project risks and impacts. This includes management plans relating to occupational health and safety (OHS), transportation and traffic, chemicals, water, and waste. As per ESAP #3 MACCEM will update its existing ESMP to (i) reflect the specific requirements of the relevant IFC EHS Guidelines and project risks and impacts, including air emission and noise monitoring, and (ii) provide training regarding the implementation and monitoring of the ESMP.
Organizational Capacity and Competency. MACCEM is still in the process of developing its EHS management team, with responsibilities currently falling to the relevant manager on site. The Company has contracted a local E&S consultancy to support with ongoing E&S management, monitoring and reporting. As per ESAP #4, the Company will employ a suitably qualified and experienced EHS officer to provide ongoing management of all EHS aspects of the operation, as well as implementation of the ESMP. The Company will also form an EHS committee which will meet regularly and comprise worker and contractor representatives, management, the EHS Officer, and HR Manager to oversee day-to-day operational E&S risk management and ESMS implementation.
Emergency Preparedness and Response. In relation to emergency preparedness, the Company has a system in place largely relating to the management of Life and Fire Safety (L&FS), including a valid Fire and Safety certificate. As a component of ESAP #3, the Company will develop and implement an Emergency Preparedness and Response Plan, including the identification of areas where accidents and emergency situations may occur (for both within the factory and adjacent residential area), consideration of individuals that may be impacted, response procedures, provision of equipment and resources, designation of responsibilities, communication, and periodic training for effective response. The emergency preparedness and response procedures will be communicated to all workers and will be commensurate to the nature of the operational risks and will be periodically reviewed and revised.
Monitoring and Review. MACCEM’s existing ESMP currently makes provision for monitoring and reporting requirements in relation to air quality, noise, waste, traffic safety, OHS, and community health and safety. Monitoring and reporting are conducted monthly by the E&S consultants, and quarterly reports submitted to both MACCEM management and the EPA. Periodic monitoring is also conducted by the EPA. As a component of ESAP #1, the Company will update and refine the monitoring and reporting framework to reflect any updates to the ESMP. This will include, but not be limited to, monitoring of particulate matter and noise at sensitive receptors adjacent to the operation.
PS2: Labor and Working Conditions
Human Resources Policies. MACCEM currently employ approximately 230 workers across their operations in Sierra Leone, with a male to female ratio of 85:15. It is anticipated a construction workforce of up to 300 workers will be required during the remaining construction period, while the operational workforce for the grinding plant will be approximately 130 workers. The Company has implemented a Local Content Plan, and source the majority of their local labor force through engagement with local community forums.
MACCEM has an HR department responsible for management and oversight of the Company’s workforce. The Company has defined and implemented an overarching HR Policy and Procedure Manual that includes various polices relating to remuneration, discipline, and gender among others.
Working Conditions and Terms of Employment. Labor and working conditions at MACCEM’s operations are defined by the relevant Sierra Leonean statutory requirements and the existing sectoral collective bargaining agreement (CBA). Terms and conditions of employment are clearly defined in the HR Policy and Procedure Manual, including remuneration, working hours, leave, benefits, training etc. All workers are provided with written employment contracts detailing their terms of employment.
Workers’ Organizations. As per the HR Policy and Procedure Manual, the Company recognizes worker rights to join and/or form unions as per the Regulation of Wages and Industrial Relations Act. In the absence of a union, the Company also recognizes workers’ right to form a committee with their chosen representatives. There is no active union at the operational level, however, the majority of MACCEM workers are represented under the existing national sectoral collective bargaining agreement that defines labor and working conditions.
Non-Discrimination and Equal Opportunity. As detailed in the HR Policy and Procedure Manual, MACCEM has adopted an approach of equal opportunity and non-discrimination, including during the recruitment process. In addition, the Company has defined a management approach on sexual harassment and bullying. As noted, from a recruitment perspective the company prioritizes local content across their operations.
Grievance Mechanism As per the HR Policy and Procedure Manual, the Company has defined an approach towards the management of worker grievances, however, no documented procedure has been developed or implemented. As per ESAP #5, the Company will develop and implement a grievance management procedure aligned with the requirements of IFC PS2. The procedure will be clearly disseminated to all workers, and include provision for anonymous, and gender specific reporting. MACCEM will maintain a grievance log and establish a grievance committee responsible for the oversight and management of worker grievances.
Occupational Health and Safety. The Company has developed a Health and Safety Policy and associated OHS Management Plan detailing the requirements in relation to risk assessments, use of personal protective equipment (PPE), training and awareness, and incident reporting and investigation.
In relation to worker dust exposure, the Company has taken measures such as installation of fabric filters, enclosed systems, automatic bag filling and use of appropriate personal protective equipment (“PPE”). There is limited evidence at this stage relating to the adequate implementation of the OHS Management Plan. In this regard, as per ESAP #6, the Company will implement the already defined OHS Management Action Plan (included in the OHS Management Plan), including, but not limited to, development of standard operating procedures (SOPs), definition of roles and responsibilities, competence training and awareness, and development of defined incident reporting and investigation procedures.
Workers Engaged by Third Parties: MACCEM does not make extensive use of third-party contractors, with the majority of their operational activities managed by their direct workers. Contractors are utilized for areas such as security and raw material transportation. In addition, the construction contractor will be on site for approximately 12-15 months. The Company will develop and implement, as a component of ESAP #3, a contractor E&S management procedure that will include OHS and labor requirements and monitoring and audit specifications, reporting requirements, in line with PS 2 requirements. In addition, renewed contracts with contractors will include the requirement for compliance with the contractor E&S management procedure.
Supply Chain: MACCEM currently source bulk cement from large reputable suppliers in Europe. The Company will source the clinker and gypsum for their grinding plant from equally reputable, large-scale suppliers in Egypt. Small quantities of additional additives, such as a limestone mix, are sourced locally. The Company currently has a limited supply chain management system. In this regard, as a component of ESAP #3, the company will (i) develop and adopt a Supplier Code of Conduct that explicitly prohibits any form of child and/or forced labor and includes specific requirement in relation to OHS, (ii) implement contractual clauses in written agreements with suppliers requiring compliance with the Supplier Code of Conduct, (iii) implement a verification process to ensure new suppliers have the policies and procedures in place to meet requirements of the Supplier Code of Conduct, (iv) have a communication strategy to inform suppliers about the Supplier Code of Conduct, (v) implement a formal process for supplier engagement, remedy or disengagement in case there are non-compliances that are not addressed.
PS3 – Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gases. The Company currently utilize a mixture of energy sources, including grid and two backup diesel generators (DGs) of 400 and 60 kva capacity respectively. It is anticipated that the operation of the grinding plant will require approximately 2.6 megawatts (MW) of additional energy that will likely be provided from the national grid when available, as well as 1 MW of solar and 2.6 MW from DGs that will be installed.
The Project does not involve the calcination of limestone during clinker or burning of fuel used to heat a kiln. The operation of the bagging and proposed grinding plant will result in a total estimated greenhouse house gas emissions of 22,000 tons of carbon dioxide equivalent per annum.
Air Emissions. Primary sources of nonpoint source emissions will relate to particulate matter that could arise from the movement of trucks, clinker handling, storage and grinding. The grinding plant will be an enclosed system and equipped with bag filters, clinker will be stored in a dedicated warehouse and all internal roads will be paved. The existing bagging plant is also enclosed and is fitted with an automatic bag-filling and handling system equipped with dust extraction and recycling units.
Baseline ambient air quality (Sulphur Oxide, Nitrogen Oxide, Carbon Monoxide and particulate matter) monitoring was undertaken as part of the ESIA. Current baseline concentrations are aligned with those defined in the WBG General EHS Guidelines. As part of ESAP #3, MACCEM will conduct an air dispersion modelling exercise once the grinding plant is operational. The results will determine if the project's emissions are expected to comply with WBG General EHS Guidelines. Based on these findings, the Company will develop an air emissions management and monitoring plan.
Noise: Baseline noise monitoring indicated that existing baseline conditions are generally within the WBG EHS Guideline requirements for industrial areas, however, levels within the adjacent community (approx. 100m from the plant) are above the required thresholds. As a component of ESAP #3, once the grinding plant is operational, MACCEM will develop and implement a noise management and monitoring plan. This will include monitoring within the workplace and at potentially sensitive receptors. Should monitoring indicate a maximum increase of 3 dBa, the Company will implement additional mitigation measures.
Water Management: MACCEMs operational processes, including clinker grinding, is largely dry, and hence the Company do not utilize material quantities of water. Primary water consumption relates to general sanitary, office, and equipment cleaning. Water is sourced from the local water company and an existing borehole.
Waste Management: Waste generated by the project primarily includes solid waste such as scrap metals, plastics, pallet timber, packaging material etc. The project may also generate small quantities of hazardous wastes such as paint, glue, used oils, etc. The Company has developed a detailed Waste Management Plan defining the approach to managing various waste streams, a waste hierarchy, handling, transportation and disposal. The Company currently utilize an authorized third-party service provider for the disposal of waste. Sewage is disposed of through the municipal system.
Cement grinding and bagging is a dry process, hence the Company does not produce material quantities of wastewater. Domestic wastewater is stored in an onsite septic tank and collected and disposed of by a local service provider.
PS 4: Community Health, Safety and Security
Community Health and Safety. MACCEM’s Hastings operation is located in a predominantly industrial area, with the Hastings Airstrip to the north and the Jui-Masiaka Highway to the south. A small community is present to the east of the site, and hence, the Company has defined a Community Health and Safety Policy. Dust and noise exposure may be present if not adequately managed. As per ESAP #3, the Company will implement both air quality and noise management plans, including defined monitoring protocols.
Traffic and Transportation: Clinker will be transferred from Queen Elizabeth II Quay in Freetown to the Project site. This entails up to 1,000 trips per month along a ~17km section of the main Bai Bureh Road, traversing multiple commercial and residential areas. As per ESAP #7, MACCEM will conduct a standalone traffic impact assessment to adequately identify and manage risks associated with the transport of clinker. Based on the findings and recommendations of the assessment, MACCEM will update their existing Transportation and Traffic Management Plan to include, as a minimum, a route risk assessment, driver training (for both direct and contract workers), relevant contractual clauses for contractors, vehicle maintenance requirements, in vehicle monitoring, and adequate transport requirements of clinker, such as covering of loads to avoid dust. MACCEM deliver small quantities of bagged cement using its own fleet to customers throughout Freetown. Associated traffic risks will be considered in the updated Transportation and Traffic Management Plan.
Security: MACCEM currently utilizes a third-party service provider for the provision of unarmed security guards. In this regard, the Company has defined a Security Personnel Policy, including the requirement for background checks, training, security awareness, review and audits. As a component of ESAP #3, MACCEM will develop and adopt a Security Management Plan (SMP) guided by the principles of proportionality and good international practice. The SMP will define the Company’s approach to risk assessments, hiring, rules of conduct, training, appropriate conduct toward workers and community members, equipping, and monitoring of security guards and their activities.
